Last Updated: December 13, 2021
1. Important information¶
We know how important privacy is to our users, which is why we only collect the information we need and will not share your personal information with any third parties, unless it is necessary. Even within Pine Grove, access to your personal information is limited to only those employees who require such information to handle matters related to the Reserve App.
The Reserve App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our app, we encourage you to read the privacy notice of every website you visit.
2. The data that will be collected¶
We need to collect personal information about you to provide you with the services or the support you request. We collect personal data about you when you sign up for a Reserve App account, go through our identity or account verification process, authenticate your account, communicate with us, participate in contests or promotions, or otherwise use our services. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed
(anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, title, username or similar identifier, tax ID, marital status, date of birth, gender, identity document number, nationality and any other information contained in any identification documents you provide to us (e.g. your passport or driver’s license).
- Contact Data includes billing address, residential address, email address and telephone numbers.
- Financial Data includes bank account details.
- Transaction Data includes details of your activity such as the amount, date, time, recipient for each transaction.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Reserve App.
- Profile Data includes your username and password, your preferences, feedback and any survey responses.
- Usage Data includes information about how you use the Reserve App.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Location Data includes information about your device location.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data).
You can choose to provide us with additional information to improve your user experience when using the Reserve App
- Contacts Information. You can choose to let us access and upload your phone contacts to make it easier for you to find the people you want to send money to, to help you invite your friends to the Reserve App, for account and identity verification and fraud prevention purposes, to reduce the risk you will send payments to the wrong person, or to provide other personalized services. You can update your settings to stop sharing your phone contacts with us at any time.
- Other Information. We collect information that you voluntarily provide to us, including survey responses; participation in promotions and contests; support inquiries; suggestions for improvements; referrals; or any other actions you perform while using the Reserve App.
Information about criminal convictions¶
When you register for an account on the Reserve App, we may receive information about your criminal convictions when we perform certain verification or compliance checks. This is done in order to detect or prevent any unlawful or fraudulent acts and to comply with relevant legalobligations.
If you fail to provide personal data¶
If we need to collect personal data by law, or under the terms of a contract it has with you and you fail to provide that data when requested, we may have to restrict or terminate your access to the Reserve App, but we will notify you if this is the case at the time.
3. How we collect your personal data¶
We use different methods to collect data from and about you including through:
- Direct interactions. You may provide your Identity, Contact, Financial, Transaction, Profile, Usage, Marketing and Communications and Location Data by submitting it through the Reserve App. This includes personal data you provide when:
- you create or use your account in the Reserve App;
- you set up a wire transfer to your account in the Reserve App;
- We need to request more information to verify your identity or to meet our legal obligations;
- you request marketing to be sent to you;
- you participate in a survey; or
- you give us some feedback.
- Automated technologies or interactions. When you interact with the Reserve App, we may automatically collect Usage and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties including:
- Technical Data from analytics providers such as Google;
- Contact, Financial and Transaction Data from providers of technical or payment services;
- Identity and Contact Data from verification or compliance services providers; and
- In providing personal data of any individual (other than yourself) to us, you agree that you have obtained consent from such individual to disclose their personal data to us for processing.
4. How we use your personal data¶
We collect all of this information so that we can provide you with the Reserve App safely and seamlessly. The information we collect allows us to:
- Deliver the full functionality of the Reserve App;
- Keep in touch with you - whether it be for providing customer service, notifying you of new features or updates to the Reserve App, or providing security notices or information;
- Verify your identity so that we can prevent fraud or unauthorized activity; and
- Fulfill any other purpose for which the information was collected.
We will never sell or rent your personal data to third parties. We may combine your information with information we collect from other companies and use it to improve and personalize the Reserve App, as well as our content and advertising.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
(i) Promotional offers from us
We may use your Identity, Contact, Technical, Profile and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you (a) have requested information from us; (b) use the Reserve App; or (c) provided us with your details when you registered for a promotion and you have not opted out of receiving that marketing.
(ii) Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside of Pine Grove for marketing purposes.
(iii) Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting support through the Reserve App at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your use of the Reserve App. Opting out will also not opt you out of receiving non-marketing information.
5. How we share your personal data¶
Sharing with third parties¶
We may have to share your personal data with the parties set out below for the purposes set out in Section 4 above:
- Law enforcement agencies and regulators – If we believe that disclosure is reasonably necessary: (1) to comply with any applicable law, regulation, legal process or governmental request; (2) to establish, exercise or defend our legal rights; (3) to enforce or comply with our Terms of Service [MG1]or other applicable agreements or policies; (4) to protect our or our users’ rights or property, or the security or integrity of our services; (5) for an investigation of suspected or actual illegal activity; or (6) to protect us, users of our services or the public from harm, fraud, or potentially prohibited or illegal activities.
- Service Providers - Pine Grove may provide your personal information to other companies who help us provide, maintain, and improve our services (e.g., vendors who help us with fraud prevention and identity verification), as well as financial institutions, payment networks, and other entities in connection with your use of the Reserve App.
- Other Users - We may share personal information about you with the person(s) with whom you transact in the Reserve App. This helps them know they are getting money from you (or that you requested a payment from them). We may also make certain information available to other Reserve App users to help them know they are making a payment to the right person.
- Professional advisers - In order to comply with our legal obligations, we may need to share information about your account with professional advisers acting as processors or joint controllers who provide consultancy, banking, legal, compliance, insurance or accounting services.
- We will share your information with other third parties if you specifically authorize us to do so.
6. How we protect your personal data¶
7. Data retention¶
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. If you want to close your account, know that we may be required to retain certain information you have provided for a number of years.
For further details of retention periods for different aspects of your personal data please contact support through the Reserve App.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.