Privacy Policy

Global Private Solutions Limited (also trading as “GPS Money” and "GPS”)

This statement sets out how Global Private Solutions Limited, a company incorporated and registered in England and Wales (registered number 08134425) and having its registered office at Palladium House, 1- 4 Argyll Street, London W1F 7LD and who is authorised and regulated by the FCA under FCA register number 822095 (“we”, “us” or "our") uses and protects personal information that a user (“you” or "your") provides when using our website at www.globalprivatesolutions.com and the Global Private Solutions mobile application (the "Site"), in compliance with United Kingdom (UK) and European Union (EU) data protection laws and regulations, including the Data Protection Act 2018 and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and repealing Directive 95/46/EC (General Data Protection Regulation) OJ L 119/1, 4.5.2016 ("GDPR") (together, the "Data Protection Laws").

Unless otherwise specified, capitalised terms in this Privacy Policy shall have the meaning given to them in our Website Terms and Conditions, which are available here.

If you do not agree to your personal data being used in the manner described in this Privacy Policy then please do not provide your personal data to us. However, please note that some functionality of the Site may be restricted/unavailable where you do not provide us with any personal data we request.

WHAT INFORMATION DO WE COLLECT?

When you register to use the Site you will be required to provide us with certain personal information, including:

your name; and
your contact information, including email address.

We may also collect and process personal information from you:

where you provide us with your personal details, including when you fill in any forms or upload information on the Site;
where you use our software and our services, any personal information about you that is submitted by or obtained from your Account Providers (as defined in the End User Terms which we have entered into with you) via the software and the services;
where you report a problem to us, or if you submit an enquiry to us relating to the Site;
where you provide your credit card or other financial information in order to purchase services;
where you respond to any surveys which, for research purposes, we may ask you to complete;
from your usage of the Site (including technical information such as IP addresses and URLs); and/or
which you email to us or otherwise provide your personal information to us.

WHAT DO WE DO WITH THE INFORMATION WE COLLECT?

We will use the personal information you provide for the following reasons:

where you have a User Account (as defined in the End User Terms which we have entered into with you) to administer your registration, including welcome emails and other emails in relation to account management or system maintenance;
to provide you with the services and access and use of all functionality of the software;
to send you information about the services and software that you have downloaded or purchased via the Site;
to process payments you make for our services;
to collect and use information about your usage of our Site on an anonymised basis in order to identify trends on usage and improve our products and to provide further services to our customers (including sharing such data to our technical service providers to enable them to do the same);
to help the investigation and resolution of any legal issues arising out of the use of the Site or the software;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you where permitted;
to provide you with marketing information about goods and services we offer, which are similar to the goods or services that you have purchased or are considering purchasing from us (you have a right to opt out of these communications at any time by contacting info@globalprivatesolutions.com and we will remind you of your option to withdraw your consent to our marketing to you on future marketing information that we send to you);
to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, including as set out in the "User Activity Data and Cookies" section of this Privacy Policy;
to improve our Site to ensure that content is presented in the most effective manner for you and for your computer; and
as part of our efforts to keep our Site safe and secure.

WHO DO WE SHARE THIS INFORMATION WITH?

We will not transfer, disclose, sell, distribute or lease your personal information to any third parties unless (i) we have your permission; (ii) we are required to do so by law; or (iii) in the following circumstances:

to payments services providers in order for your purchase of services to be processed, in which case we will disclose certain credit card or other financial information about you;
to analytics and search engine providers that assist us in the improvement and optimisation of our Site and other selected technical service providers, including as set out in the "User Activity Data and Cookies" section of this Privacy Policy;
to certain technical service providers who help us to deliver the Site to you (for example third party technology companies who may provide elements of the Site's functionality) or to provide services to you;
in the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets;
if we, or substantially all of our assets, are acquired by a third party, in which case personal information held by us about our users will be one of the transferred assets;
as required to enforce or apply our Website Terms and Conditions;
if third parties claim that any content or material you provide to us (including via your User Account) infringes their rights (e.g. their privacy or intellectual property rights); and
to relevant authorities where you carry out criminal activity (e.g. breach of the Computer Misuse Act 1990).

HOW LONG DO WE KEEP THE INFORMATION?

We keep your personal information for a period of 6 years from the date of collection or, if you continue to be our customer, for a period of 6 years from the end of the customer relationship, to enable us to retain the information we may require for legal and regulatory purposes. Please be assured that we will only keep your information to the extent we require to do so for legal and regulatory purposes.

WHAT ARE YOUR RIGHTS

You have a number of rights under Data Protection Laws in relation to the way we process your personal information. These are set out in the table below. If you have any questions, comments and requests regarding this Privacy Policy or our data processing practices, please do not hesitate to contact us by emailing: info@globalprivatesolutions.com.

NUMBER	DESCRIPTION OF RIGHT
Right 1	A right to access personal information held by us about you.
Right 2	A right to require us to rectify any inaccurate personal information held by us about you
Right 3	A right to require us to erase personal information held by us about you. This right will only apply where (for example): we no longer need to use the personal information to achieve the purpose we collected it for; or where you withdraw your consent (if we are using your personal data based on your consent); or where you object to the way we process your data (in line with Right 6 below).
Right 4	A right to restrict our processing of personal information held by us about you. This right will only apply where (for example): you dispute the accuracy of the personal information held by us; or where you would have the right to require us to erase the personal information but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims.
Right 5	A right to receive personal information, which you have provided to us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal information to another organisation, at your request.
Right 6	A right to object to our processing of your personal information (including for the purposes of sending marketing materials to you).
Right 7	A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services or products).

HOW WILL WE COMPLY WITH DATA PROTECTION LAWS?

Data Protection Laws require that we meet certain conditions before we are allowed to use your personal information in the manner described in this Privacy Policy. We take our responsibilities under Data Protection Laws very seriously, including meeting these conditions. To use your personal information, we will rely on the following conditions:

Providing the Site: We will process your personal information to the extent that this is necessary for the performance of our obligations under our Website Terms and Conditions; and
Legitimate Interests:We will also process your personal information where this processing is in our "legitimate interests". It is in our legitimate interests to collect your personal information as it provides us with the information that we need to run the Site more effectively. When relying on this condition, we are required to carry out a balancing test of our interests in using your personal information (for example, in order to improve the Site), against the interests you have as a citizen and the rights you have under Data Protection Laws (for example, to not have your data sold to third party marketing companies without your knowledge, or stored in insecure or unstable countries/regions). The outcome of this balancing test will determine whether we can use your personal information in the ways described in this Privacy Policy. We will always act reasonably and give full and proper consideration to your interests in carrying out this balancing test.
Consent: We may market our services and products to you that are similar to the services and products that you have purchased or are considering purchasing from us. Where we do so, we rely on your consent to our marketing to you. You can withdraw your consent at any time by contacting info@globalprivatesolutions.com and we will remind you of your option to withdraw your consent to our marketing to you on future marketing information that we send to you.

SECURITY OF DATA

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to us; any transmission is at your own risk
However, we will take all steps reasonably necessary to ensure that your personal information is secure. In order to try to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Where we have given you (or where you have chosen) Login Details which enable you to access certain parts of the Site, you are responsible for keeping these details confidential. You agree that you will not share your login details with anyone else.
The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our technical service providers, including Microsoft in the United States. This includes staff engaged in, among other things, the processing of your payment details and the provision of support services to us. We will take all steps reasonably necessary to ensure adequate protections are in place to ensure the security of your information in accordance with the Data Protection Laws, including putting appropriate contractual arrangements in place with our technical service providers. If you would like further information in relation to the technical service providers to whom we may transfer your personal data, please contact us at info@globalprivatesolutions.com.

LINKING

As outlined in the Website Terms and Conditions, we may link to other websites, which are not within our control.
Once you have left the Site, we cannot be responsible for the protection and privacy of any information which you provide to these sites. You should exercise caution and look at the privacy statement applicable to the website in question.

USER ACTIVITY DATA AND COOKIES

Our Site uses cookies. Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. These cookies allow us to distinguish you from other users of the Site which helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.
For more information about how we use cookies, please refer to our Cookies Policy.

CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy and expect you to check these pages from time to time to take notice of any changes we make, as they are binding on you. This version of the Privacy Policy is dated 1 July 2018. If we make any substantial changes we will post the changes on this page of the Site and on the home page on our Site, so that you may be aware of the information we collect and how we use it at all times.

COMPLAINTS

If you have any concerns regarding our processing of your personal information, or are not satisfied with our handling of any request by you in relation to your rights, you also have the right to make a complaint to the Information Commissioner's Office. Their address is:

First Contact Team

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

SK9 5AF