Privacy Policy


The Company and its affiliates (hereinafter, “we”, “us” or “our”) are committed to protecting and respecting your privacy.

This Privacy Policy (together with our Terms of Service) governs our collection, processing and use of your Personal Information. We define “Personal Information” as information which identifies you personally. (Other terms are defined in the Terms of Service, above.)

The purpose of this Privacy Policy is to inform you of:

  • the kinds of Personal Information which we may collect about you and how it may be used;

  • any disclosure of Personal Information to third parties;

  • the transfer of Personal Information;

  • your ability to correct, update and destroy your Personal Information; and

  • the security measures we have in place to prevent the loss, misuse, or alteration of Personal Information under our control.

Gathering and Use of Personal Information

We may collect your Personal Information if you use our website and attempt to open a Customer account to use the Service. The types of Personal Information which we collect may include:

  • your name;

  • a copy of or information from your government-issued identification document;

  • your address;

  • your phone number;

  • your e-mail address;

  • your date of birth;

  • your tax identification number;

  • your transactional history; and

  • any other personal information you provide to us which we believe is necessary to maintain your account.

We may use your Personal Information for the following purposes:

  • to allow you to open an account;

  • to enable you to complete transactions through our service;

  • if you contact us, to reply to your queries;

  • as required for regulatory purposes;

  • to conduct due diligence on and/or verify your identity;

  • to conduct due diligence on your use of our services; and/or

  • to contact you regarding the Company’s services, including marketing.

We will process your Personal Information only for the purposes for which it has been provided to us.

Disclosure of Personal Information

We use the Personal Information for the purposes indicated at the time you provide us with such information, and/or otherwise for the purposes set out in this Privacy Policy and/or as otherwise permitted by law. We may make available the Personal Information that you provide to us to our financial institution partners, affiliates, agents, representatives, trusted service providers and contractors for these limited purposes. We may share customers' Personal Information with financial institutions, insurance companies or other companies in the case of (including but not limited to) a merger, divestiture, or other corporate re-organization.

We may also share customers’ Personal Information with law enforcement or regulatory agencies, as may be required by law or when we suspect an account is involved in criminal or illicit activity.

Any third party which receives or has access to Personal Information shall be required by us to protect such Personal Information and to use it only to carry out the services they are performing for you or for the Company, unless otherwise required or permitted by law. We will ensure that any such third party is aware of our obligations under this Privacy Policy and we will enter into contracts with such third parties by which they are bound by terms no less protective of any Personal Information disclosed to them than the obligations we undertake to you under this Privacy Policy or which are imposed on us under applicable data protection laws.

Transfer of Personal Information

The Company may transfer Personal Information to the third-party service providers entrusted by the Company with the hosting of the Company’s services and other technical or administrative operations relating to the operation of the Company’s services. These parties may be located anywhere in the world. By providing us with your Personal Information, you consent to such transfer of your Personal Information to third-party service providers inside and outside of the United States. You acknowledge that the transmission of information via the Internet is not completely secure and whilst we will use industry best practices to protect your Personal Information, we cannot guarantee the security of your data when it is outside of our control. Once we have received your Personal Information, we will use strict procedures and security features to try to prevent unauthorized access, including encryption.

Request a Copy of Personal Information

Upon your written request, we will inform you of the Personal Information relating to you that we hold and the use and general disclosure of your Personal Information. Upon written request, we will also give you a copy of the Personal Information we have retained (Personal Information, however, does not include information derived from Personal Information you provided or other information we may be prohibited by law from giving you). There may be a minimal charge for accessing and copying your Personal Information.


Pursuant to our regulatory responsibilities, we have implemented security measures to ensure the confidentiality of your Personal Information and to protect your Personal Information from loss, misuse, alteration or destruction. The security measures in place will, from time to time, be reviewed in line with legal and technical developments.

Retention of Personal Information

We will hold your Personal Information only for as long as it is necessary for us to do so, having regard to the purposes described in this Privacy Policy and our own legal and regulatory requirements. In accordance with our record keeping obligations we will retain Personal Information for, at least, a period of five years after a Customer last uses the Service.


Our policies, content, information, promotions, disclosures, disclaimers and features may be revised, modified, updated, and/or supplemented at any time and without prior notice at the sole and absolute discretion of the Company. If we change this Privacy Policy, we will post the amended Privacy Policy on the kiosk.

Privacy Statement For Customers Whose Personal Information May Be Collected In Or From The EEA

We may collect Personal Information from you when you are located in the EEA in order to streamline your registration process for our services when you are in the United States. As such, we will request explicit consent for the transfer of Personal Information from the EEA to the United States. If you are an individual located in the EEA and you decline to consent to such transfer, you will not be able to register for our services while you are located in the EEA.

We process the Personal Information of Data Subjects who are located in the EEA for one or more of several lawful purposes, including:

  • With your explicit consent:

    • To register you with our services and to provide services, including customer service support;

    • To optimize and enhance our services for all customers or for you specifically;

  • To comply with legal obligations:

    • To conduct anti-money laundering, anti-fraud and identity verification and authentication checks (you authorize us to share your Personal Information with our third-party service providers, who may also conduct their own searches of publicly available Personal Information about you); and

  • For our legitimate business purposes:

    • To monitor the usage of our services, conduct automated and manual security checks of our services, to protect our rights and perform our lawful obligations.

If you are in the EEA, you may withdraw consent at any time where consent is the lawful basis for processing their Personal Information. Should you withdraw consent for processing or otherwise object to processing that impedes our ability to comply with applicable laws and regulations, you may be unable to avail yourself of our services.

We do not engage in automated decision-making.

Our employees are prohibited, either during or after their employment, from disclosing Personal Information to any person or entity outside of our company, including family members, except under the circumstances described above. An employee is only permitted to disclose the Personal Information of a customer to such other employees who need access to such information in order to deliver our services to that customer.

If you are located in the EEA or Switzerland and have questions or concerns regarding the processing of your Personal Information, our contact information is below.

If, as an EEA citizen, you believe that we have not adequately resolved any such issues, you have the right contact the EU supervisory authority.