PRIVACY & COOKIES POLICY

This Privacy & Cookies policy ("Privacy Policy") together with our Terms of Service (which can

be found at Quppy.com ("Terms of Service") sets out the basis on which any Personal

Information we - Quppy Europe OÜ an Estonian company with the address at Harju maakond,

Kesklinna linnaosa, Parda tn 3-326, Tallinn, 10151, Estonia (hereafter “Quppy”) collect from you

("you", "your", or "customer"), or that you provide to us, will be processed by us.

This Privacy Policy together with our Terms of Service and any other Quppy agreements will

apply to your use of:

and sets out the basis on which any personal data we collect from you, or that you provide to us,

will be processed and used by us.

We are the controller within the meaning of the General Data Protection Regulation, we

determine the purposes and means of processing your personal data.

If you have any questions about your personal information or this Privacy policy, please direct

your questions to support@quppy.com

We will collect and process the following data about you Information you provide to us,

"Submitted Information" is information you give us about yourself by completing forms on the

Wallet and/or the Site, or by corresponding with us i.e. by e-mail. It includes information you

information, details of your bank Wallet including the bank Wallet number, bank sort code, IBAN,

details of your debit and credit cards including the long number, relevant expiry dates, CVC,

identication document numbers, copies of identication documents (for example, passport

details, driving license and utility bills) personal description, photographs and any other

information you provide us in order to prove your eligibility to use our Services.

Information we collect about you and your device. Each time you visit the Wallet or our Site we

will automatically collect the following information:

• technical information, including the internet protocol (IP) address used to connect your

number, the MAC address of the device's wireless network interface, or the mobile phone

• information about your visit, including the full uniform resource locators (URL), clickstream to,

through and from our Site (including date and time), services you viewed or searched for, page

response times, download errors, length of visits to certain pages, page interaction information

(such as scrolling, clicks, and mouse-overs), methods used to browse away from the page,

device information;

• transaction information including date, time, amount, currencies used, exchange rate,

beneciary details, details and location of the merchant or ATMs associated with the

transaction, IP address of sender and receiver, sender's and receiver's name and registration

information, messages sent or received with the payment, device information used to facilitate

• details of your use of our Wallet or your visits to our Site including transaction details relating to

your use of our Services, including who you have sent money or electronic money to, foreign

exchange transactions you have entered into, the time, date and location of the place the

transaction was entered into;

• location information; we use GPS technology and your IP address to determine your location.

This is used to prevent fraud, for instance if your mobile phone is saying that you are based in the

UK but your card is being used to enter into an ATM Withdrawal or point of sale purchase in

Germany, we may not allow that transaction to be processed. Our card protection and fraud-

help us deliver our Services to you. These third parties are business partners (such as those we

partner with to oer additional Quppy Services), sub-contractors in technical, payment and

delivery services, advertising networks, analytics providers, search information providers, credit

reference agencies, fraud prevention agencies, customer service providers and developers.

Information we may collect about you from such parties can include credit search information,

information which helps us to verify your identity or information relating to your payment

transactions.

COOKIES AND RELATED TECHNOLOGIES

to our Site or use of the Wallet, such as their Internet protocol (IP) address, how they arrived at

preferred settings, track use of our Site and Wallet and to compile statistics about activities

carried out on our Site. We also use cookies and/or a technology known as web bugs or clear

gifs, which are typically stored in emails to help us conrm your receipt of, and response to, our

emails and to provide you with a more personalized experience when using our Site.

You may set up your web browser to block cookies from monitoring your website visit. You may

also remove cookies stored from your computer or mobile device. However, if you do block

cookies you may not be able to use certain features and functions of our Site.

USES MADE OF THE INFORMATION

We will use this information:

• to carry out our obligations arising from any transactions you enter into with us, i.e. top ups,

transfers, ATM withdrawals, card purchases and to provide you with the information, products

and services that you request from us;

• to provide you with information about other goods and services we oer that are similar to

those that you have already purchased or enquired about;

to provide you, or permit selected third parties to provide you, with information about goods or

• to ensure that content from our Site is presented in the most eective manner for you and for

your computer.

Device Information

We will use this information:

• to administer our Site and the Wallet for internal operations, including troubleshooting, data

analysis, testing, research, statistical and survey purposes;

to measure or understand the eectiveness of advertising we serve to you and others, and to

deliver relevant advertising to you;

• to make suggestions and recommendations to you about goods or services that may interest

you;

• to verify your identity, protect against fraud, comply with anti-nancial crime laws and to

conrm your eligibility to use our products and services; and

• to comply with our legal and regulatory obligations.

• to protect against fraud.

Third Party Information

We will combine this information with information you give to us and information we collect

about you. We will use this information and the combined information:

• to help us better understand your nancial circumstances and behaviour so that we may make

decisions about how we manage your Quppy Wallet;

We may associate any category of information with any other category of information and will

treat the combined information as personal data in accordance with this Privacy Policy for as

long as it is combined. For example, we may use credit reference agencies to carry out credit

searches on you, so that, when you Wallet for credit products or when we suggest credit

products to you via the Wallet, we will be able to tailor our credit oering to your needs. Any such

search under this section may leave a footprint on your credit le. You acknowledge that we may

carry out such credit search in the knowledge that it may leave a footprint on your credit history.

We do not allow joint Wallet holders, however in certain circumstances credit reference

agencies may link your record with your spouse, partner or other nancial associate.

you. We will never disclose identiable information about individuals to advertisers, but we may

from you to enable our advertising partners to display their advertisement to their target

audience.

DISCLOSURE OF YOUR INFORMATION

We will disclose the data we collect from you to certain third parties who use personal data in

delivering their services to us, they use data securely and condentially and under strict

contractual controls in accordance with data protection laws and controls enforced by Quppy.

We send personal data to the following sets of data processors in order to perform the Quppy

• Cloud storage providers. This is in order to safely and securely store your data with Quppy;

• Banking and nancial services partners. Financial services providers that help us provide the

Services including banking partners, banking intermediaries and international payments

services providers;

• Credit reference agencies. For the purpose of assessing your credit score;

Card manufacturing/personalization and delivery companies. For the purpose of creating your

personalized Quppy card and delivering this to you at your requested address; and

users. In some instances, we may use personal data we have collected from you to enable our

advertising partners to display their advertisement to their target audience. We also use

analytics and search engine providers that assist us in the improvement and optimization of our

Site.

• Companies within the Quppy Group and/or ailiates. In order to provide a unied service

across all of our products and services, we may disclose your personal information to any

member of the Quppy Group and/or ailiates, which means any of our subsidiaries or related

entities. Companies in the Quppy Group will be acting as joint controllers or processors in order

to provide the Services.

• if we are under a duty to disclose or share your personal data in order to comply with any legal

or regulatory obligations or request;

if we need to enforce or Walletly the ToS or any other agreements between you and us or to

investigate potential breaches; or

• protect the rights, property or safety of Quppy, our customers or others.

This includes exchanging information with other companies and organizations for the purposes

of fraud protection and credit risk reduction.

request made by you to execute an international payment, process your payment details,

provide global anti-money laundering and counter terrorist nancing solutions and provide

ongoing support services. We will take all steps to ensure that your data is treated securely and

in accordance with this Privacy Policy.

All information you provide to us is stored on our secure servers. Any payment transactions

carried out by us or our chosen third-party provider of payment processing services will be

encrypted using Secured Sockets Layer technology or a secure virtual private network. Where

we have given you (or where you have chosen) a password that enables you to access certain

parts of our Wallet and/or our Site, you are responsible for keeping this password condential.

Any third party that receives or has access to your data is required to protect such data. We shall

ensure any such third party is aware of our obligations under this Privacy Policy and ensure we

enter into contracts with such third parties, bound by terms no less protective than the

obligations we undertake to you under this Privacy Policy or which are imposed on us under

Wallet applicable data protection laws.

You acknowledge that by using our Services You will be providing us with your data. You consent

to us disclosing that information where required by this Privacy Policy and/or law.

Your data will be retained as long as it is necessary for us to do so, having regard to the purposes

SECURITY

We have implemented security measures to ensure the condentiality of your data and to

protect your data from loss, misuse, alteration or destruction. Only authorised personnel of

Quppy have access to your data, and these personnel are required to treat the information as

condential. The security measures in place will, from time to time, be reviewed in line with legal

and technical developments.

YOUR LEGAL RIGHTS

This enables you to receive a copy of the personal data we hold about you. If you require this,

then please contact us at info@Quppy.com;

• request correction of the personal data that we hold about you. This enables you to have any

incomplete or inaccurate data we hold about you corrected, though we may need to verify the

accuracy of the new data you provide to us. If you require this, then please contact us

at info@Quppy.com;

• request erasure of your personal data. This enables you to ask us to delete or remove personal

data where there is no good reason for us continuing to process it. You also have the right to ask

supersede any right to erasure requests under applicable data protection laws;

• to object to the processing of your personal data. This is in situations where we are relying on a

legitimate interest (or those of a third party) and there is something about your particular

situation which makes you want to object to processing on this ground as you feel it impacts on

your fundamental rights and freedoms. You also have the right to object where we are

processing your personal data for direct marketing purposes. In some cases, we may

demonstrate that we have compelling legitimate grounds to process your information which

override your rights. Quppy is under certain obligations to process and retain certain data for

compliance purposes. Please note that these requirements supersede any right to objection

Wallet;

• if you want us to establish the data's accuracy;

• where our use of your data is unlawful, but you do not want us to erase it;

• where you need us to hold the data even if we no longer require it as you need it to establish,

exercise or defend legal claims; or

• you have objected to our use of your data, but we need to verify whether we have overriding

legitimate grounds to use it. Please note that any requests in relation to the restriction of the

then transfer to an Wallet or third party. Note that this right only Wallet or to automated

information which you initially provided consent for us to use or where we used the information

to perform a contract with you. If you require this then please contact us at info@Quppy.com;

• request for the transfer of your personal data to you or to a third party. We will provide to you,

your personal data in a structured, commonly used, machine-readable format, which you can

then transfer to a Wallet or third party. Note that this right only applies to automated information

which you initially provided consent for us to use or where we used the information to perform a

contract with you. If you require this then please contact us at info@Quppy.com; and

WHAT WE MAY NEED FROM YOU

We may need to request specic information from you to help us conrm your identity and

ensure your right to access your personal data (or to exercise any of your other rights). This is a

security measure to ensure that personal data is not disclosed to any person who has no right to

receive it. We may also contact you to ask you for further information in relation to your request

to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with

you and you fail to provide that data when requested, we may not be able to perform the

contract we have or are trying to enter into with you (including the Quppy Services). In this case,

we may have to cancel your use of our Services, but we will notify you if this is the case at the

time.

CHANGES

There may be links from our site to other websites and resources provided by third parties. This

Privacy Policy applicable to Wallet and only to our Site. We do not control those third-party

websites or any of the content contained therein and you agree that we are in no way

responsible or liable for any of those third-party websites.

MARKETING

We will obtain your express opt-in consent before we share your personal data with any

company outside the Quppy Group of companies for marketing or promotional purposes. You

as they relate to our Services, please contact us at the following e-mail

address: support@quppy.com