Privacy Policy

1. Introduction

Jeton Bank Limited, an international bank existing under the Commonwealth of Dominica, and having its registered Head Office, at 1st Floor, 43 Great George Street, Roseau, Commonwealth of Dominica, licenced as a banking institution under the International Banking Act (the “Law”), fully authorised to provide services to clients worldwide, under the prudential supervision of the Financial Services Unit (FSU – http://fsu.gov.dm/ ). A copy of the Public Register of FSU of licenced Offshore Banks can be seen at https://fsu.gov.dm/registered-entities/search-financial-entities

1.1 Please read these Privacy Policy carefully, because they form the legal agreement between You and Jeton Bank Limited in relation to the access and use of Jeton Bank Limited’s products and services.

1.2 Jeton Bank Limited (the “Jetonbank”) takes the privacy of its site visitors, users and customers very seriously and as such ensures that their personal information and confidential information are securely stored. This notice applies to the legal entities that provide Jetonbank services under Jetonbank’s name. This Privacy Policy aims to assist you in understanding what data we collect, why it is collected, and what Jetonbank does with your data. The information collected is utilised to understand our customer’s behaviour and eligibility for Jetonbank’s products and services, allowing us to provide a better service to our customers.

1.3 From the moment you access Jetonbank, you agree to our Privacy Policy. It is your responsibility to read, understand, and agree to the terms set out in this document and consent to the use of your data as described. For any questions or concerns regarding our Privacy Policy, contact us via our live chat at https://jetonbank.com/ and refrain from using our website in the meantime. Please be aware that whilst this Privacy Policy sets out our approach to your personal data, you may have different rights under the data protection legislation that applies to you (for UK customers Data Protection Act 2018 and for EEA customers the General Data Protection Regulation (EU) 2016/679 (GDPR) and any other legislation applicable to Jetonbank’s services on relevant jurisdiction).

2. The Information We Collect from You

2.1 We collect your personal information and Confidential Information to provide you with better and more useful services. When you register for your Jetonbank account, you provide us with personal information, including but not limited to, your name, e-mail, date of birth, credit/debit card and bank account information.

2.2 Registration Information: We collect information when you create your Jetonbank account. Depending on how you want to use your account, we may ask you to provide some or all the following: Credit or debit card number, bank account number, relevant expiration dates, phone number, date of birth, ID document number, photos of ID, photo of the individual of registration, video recording of the individual of registration, phone number, industry type, purpose of your account, transaction information. The same documents may be asked from the individual representative of the registering legal entity. We may also request additional information as part of our verification and ongoing monitoring process.

2.3 Additional Information: We may request additional details or answer further questions to verify your information. We may also obtain additional information about you from third parties, including third-party partners. This information includes information about your behaviour, bank accounts or payment methods issued by third-party financial institutions that are linked to your Jetonbank’s products. We also collect information about which tabs you visited on our site, your browser information, your location and your frequency of use of our site.

2.4 Transaction Information: Information about your transactions is collected and reviewed including but not limited to date, time, amount, devices associated with the transaction, the IP address of sender and receiver, sender name and registration information, receiver’s name and registration information, messages sent or received with the payment, device information used to facilitate the payment, and the payment instrument used.

2.5 Merchant Information and Confidentiality: We gather, use, and may disclose data on our merchant accounts. When a merchant registers for a Jetonbank account, they are required to provide information about their business to perform relevant credit and risk assessments. This includes collecting information about the merchant’s key controllers, the directors, partners, and shareholders and confidential information. Jetonbank shall use your confidential information only for the evaluation set out in the Terms and Conditions and Privacy Policy and not for any other commercial or operational purpose, nor in connection with any similar project undertaken by it, nor in any manner detrimental to you, its affiliates, or their respective representatives. In addition to these specific obligations, Jetonbank shall protect and safeguard your confidential information with at least the same degree of care with which it protects and safeguards its own confidential information. By accepting the Terms and Conditions and Privacy Policy, you also agree that you shall not use or disclose Jetonbank’s confidential information other than the way Jetonbank uses or discloses Your confidential information. This information is used to verify our merchants and their key controllers. This includes verifying certain data provided by our merchants and reviewing their eligibility to use our products and services. Third-party partners may be used to validate the information provided by you at account registration. Jetonbank reserves the right to periodically review merchant accounts. This may involve the request for a credit reference from a credit or fraud agency on any merchant account. As part of this review, Jetonbank reserves the right to close an account based on the information found. For different merchant accounts, we may collect information about a merchant’s business and online profile to review a merchant’s size, customer base, and expected transactional activity.

2.6 Maintaining Updated Information: In addition to the information provided upon registration of your account, we also collect the information we receive from you as a result of your use of our services. This allows us to verify your identity periodically and analyse your behaviour to provide you with better customer service. The information collected includes but is not limited to login details, location information, device information, transaction information, third-party information, identity information, and cookies.

3. Usage of Personal Information and Duration

3.1 Registration information is used to verify your identity. This includes verifying certain data provided by you and reviewing your eligibility to use our product and services. We use the information we collect about you to provide you with the products we offer, to notify you about changes to our products, and to improve our products. Transactional information is kept to ensure our service levels and also for regulatory requirements. This includes checks in relation to the Anti-Money Laundering, Know Your Client (KYC/KYB), Politically Exposed Person (PEP) policies and any other checks that Jetonbank is obliged to conduct based on the venue and category of the services provided. Unless otherwise stipulated in this Privacy Policy or there is a regulatory or legal requirement exists, Jetonbank will delete your personal information when your relationship with Jetonbank ceases.

3.2 Internal Use: We reserve the right to obtain and use your personal information and confidential information. By browsing our site, you give us your explicit or implied consent to collect, retain and use your information. The below defines some examples in which we may use your information:

• to develop a more user-friendly site with tailored use,
• to provide you with tailored information regarding our products and services,
• to analyse customer support to improve our services,
• to offer you special features and promotions based on your requirements and,
• to ensure your continued eligibility for our products and services.

This information is only shared with our internal stakeholders on a need-to-know basis with strict data security regulations which we abide by.

3.3 Third-Party Use: We may share your personal information or confidential information with trusted third parties to improve our services, as permitted by data legislation or in the limited circumstances set out below. These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared. We may share your information with trusted third parties when:

• to provide you with special features (services) upon your request,
• to respond to a subpoena, warrant, court order, or as otherwise required by law,
• to conduct or cooperate in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so,
• to interact with our approved business service partners who are held to contractual and legal regulations as to how they are permitted to handle your data, and,
• to gather your IP address, browser type, and access times to improve our website.

In the case of a merger with another company or any rebranding would mean that the new company or brand would have access to the personal information provided by you. The current Privacy Policy would apply unless amended or otherwise stated.

4. Information Disclosure

4.1 You consent to our collection, use, and disclosure of the personal information and confidential information you provided, as outlined below. We may disclose your information:

• to other members within the group structure in which Jetonbank is established for the purposes described in this Privacy Policy including cross-borders outside of the EEA, wherever members of the group are located. In the event of a cross-border transfer of data, Jetonbank is committed to providing appropriate protection for your information and meeting the highest standards of data protection required,
• to trusted third-party partners to validate the information you provided upon registration of your account,
• to provide other relevant data that is necessary to confirm your eligibility for the use of specific products and services provided by us,
• to third-party service and technology providers to understand your behaviour, improve our services, and verify your identity. This may involve the transfer of your information across border outside of the EEA. It will only be transferred to third parties who have agreed to protect and handle your data with the same standards expected at Jetonbank.

As we deem necessary or appropriate under applicable law to respond to police or government requests both within and outside your country of residence, comply with legal processes, impose our terms and conditions, protect our operations and those within our group structure, pursue or limit damages that we sustain, and protect our rights, privacy, safety of Jetonbank or members within our group structure.

5. Cookies

5.1 We use cookies on our site to collect and store certain information when you access Jetonbank. Cookies are small files that may enable us to know some additional information about you. The information provided by cookies may tell us if you have previously visited our site, if you are using the same computer, if you have previously contacted us for support, if you prefer a specific browser, or if you have certain preferences when using Jetonbank.

6. Your Rights

6.1 It is your right to have access to all the personal information we hold about you and your use of our site and services.

6.2 Where applicable, you may have certain rights under data protection legislation, including the right to access, correct, update or delete your personal information; object to or restrict its processing; request to transfer certain of your personal information to another service provider (so called, data portability); or to revoke any consent you have given.

7. Legal Basis for Processing

7.1 We will process your personal information only when we have one of the following grounds:

• based on your consent, for example, to send you marketing messages to the extent consent is required by law,
• where necessary to enter into a contract with you and perform our obligations under that contract,
• where we have a legitimate interest, subject to such processing not overriding our rights and freedoms,
• where we have a legal obligation to collect your personal information or otherwise need your Personal Information to protect your vital interests or those of another person, or,
• exceptionally, when necessary in the public interest, for example when law enforcement agencies request information to investigate a crime.

8. Contacting Us

8.1 In order to contact us regarding any questions you may have for our Privacy Policy, please contact our customer support via chat from the website, or contact your Account Manager.

8.2 Write to us at the following address:

1st Floor, 43 Great George Street, Roseau, Commonwealth of Dominica, Post Code: 00109-8000.

9. Definitions

9.1 Please refer to our Terms and Conditions for the defined terms referred to in this Privacy Policy.

10. Updates and Amendments

10.1 We reserve the right to amend this Privacy Policy at any time and for any reason. Any variation will not reduce your rights under this Privacy Policy without your consent. All changes will be posted on our website, and you may be asked to re-confirm your consent to the terms of this Privacy Policy. If the amendments are significant, we may notify you directly. As a reference, we will retain prior versions of our Privacy Policy.