By using the Amber Fundme product and services you agree and consent to this Data Protection and Privacy Policy.
Personal Information We May Collect
“Personal Information” means any information relating to an identified or identifiable individual.
We may collect the following categories of Personal Information:
Transaction information, such as personal account number, the merchant’s name and location, the date
and the total amount of the transaction, and other information provided by financial institutions or
merchants when we act on their behalf.
Product and service information, such as registration and payment information, and program-specific
information, when you request products or services directly from us, or participate in marketing
programs.
Website, device and mobile app usage, and similar information collected via automated means, such as
cookies and similar technologies.
Job applications and related information when you apply for a job with us.
Business contact information when you work for one of our business partners.
Personal Information We Receive from Financial Institutions, Merchants, and Other Partners in Connection with
Amber Fundme’s Products or Services
As a processor of payment transactions and provider of related services, we obtain a limited amount of
information in connection with your payment transactions such as the personal account number, the merchant’s
name and location, the date and the total amount of the transaction.
In addition, for certain products and services, your financial institutions, the merchants where you make a
transaction or other partners may provide us with more information about you, or we may collect it directly
from you to provide you with those products and services on their behalf, support their business or perform
processing activities on their behalf.
In the above situations, we act on behalf of and under the instructions of financial institutions, merchants
and other partners which act as data controllers. Unless otherwise authorized by law, we will process your
Personal Information to process payment transactions or for the purposes agreed between Amber Fundme and the
financial institutions, merchants and other partners. Please refer to their respective privacy policies for
more information regarding the processing of your Personal Information.
Personal Information We Collect when Providing Amber Fundme’s Products and Services Directly to You
Amber Fundme may provide you directly with products and services such as marketing programs, rewards
programs, and biometric authentication tools. To benefit from one or more of these products and services,
you can submit information to us directly via various means including: (i) on our websites, (ii) in response
to marketing or other communications, (iii) by signing up for an Amber Fundme product or service, or (iv)
through your participation in an offer, program or promotion. We may also obtain Personal Information about
you through your use of our products or services, from companies that use or facilitate our products or
services, from publicly available sources, or from third party partners. Your Personal Information may also
be passed on to us by your financial institution, merchant or other business partners.
Below is an overview of the types of Personal Information we may collect in relation to programs we offer
directly to you
Registration and payment information: We may collect identifiers and your contact information (such as name,
email address, phone number, billing or shipping address), authentication information (e.g., username and
password), age, date of birth, gender and family status, language preferences, payment details, personal
account number, commercial information, such as merchant’s name and location, date and total amount of the
transactions, card expiration date and card verification code.
Information we process to provide you with the program: We may collect different types of Personal
Information depending on the program. For example, programs designed to offer you location-based services
will typically require the collection of your address or geolocation data. Programs within our payment
solutions may require the collection of your financial account information. Similarly, programs designed to
allow you to authenticate for example, via facial or fingerprint recognition may require the processing of
your photograph and/or biometric information. All these programs are voluntary, and your Personal
Information is only collected if you subscribe to such programs.
Other information you choose to provide: You may choose to provide other information, such as different
types of content (e.g., photographs, articles, comments), contact information of friends or other people you
would like us to contact, content you make available through social media accounts or memberships with third
parties, or any other information you want to share with us, for example when you contact customer service.
In addition, we may collect or use Personal Information for fraud prevention and monitoring, risk
management, dispute resolution and other related purposes. Such information may include identifiers,
commercial information, and Internet or other electronic network activity information, such as the personal
account number, merchant’s name and location, date and total amount of the transactions, IP address, credit
information, location data, merchant details, items purchased and information about the dispute.
Personal Information We Obtain from Your Interaction with Amber Fundme’s Ads, Websites, Apps or Other Digital
Assets
We, our service providers and partners may collect certain information about you via automated means such as
Internet or other electronic network activity information, cookies, and web beacons when you interact with
our ads, mobile apps, or visit our websites, pages or other digital assets. The information we collect in
this manner may include: IP address, browser type, operating system, mobile device identifier, geographical
area, referring URLs and information on actions taken or interaction with our digital assets. A “cookie” is
a text file placed on a computer’s hard drive by a web server. A “web beacon,” also known as an Internet
tag, pixel tag or clear GIF, is a technology that helps us identify when content has been accessed or
visited.
We use this information to improve our online products and services by assessing how many users access or
use our online products and services, which content, products and features of our online products and
services most interest our visitors, what types of offers our customers like to see and how our online
products and services perform from a technical point of view. For instance, we may use third-party web
analytics services on our websites and mobile apps. The analytics providers that administer these services
use technologies such as cookies and web beacons to help us analyze how visitors use our websites and apps.
We, our service providers and partners may also collect information about you in connection with our
marketing activities, including offers and promotions. The information collected for these purposes may
include identifiers and your contact information (e.g., name, postal address, email address, phone number),
electronic identification data (e.g., username, password, security questions, IP address), and data
collected in the context of online marketing programs, including commercial information, Internet or other
electronic network activity information, geolocation data, and inferences drawn from Personal Information
(e.g., personal characteristics, life habits, consumption habits, interests, location data, and voice and
image recordings).
We, our service providers and partners may also collect information about you to provide you with content
and advertising tailored to your individual interests based on inferences drawn from Personal Information.
The information collected for these purposes may include Internet or other electronic network activity
information, such as details about things like the particular pages or ads you view on our websites and apps
and the actions you take on our websites and apps.
We, our service providers and partners may collect certain information about you via automated means such
as, social media tools, widgets or plug-ins to connect you to your social media accounts. These features may
allow you to sign in through your social media account, share a link or post directly to your social media
account. When you visit a website that contains such tools or plugins, the social media or other service
provider may learn of your visit. However, your interactions with these tools are governed by the privacy
policies of the corresponding social media platforms. As we do not control these third-parties’ data
handling practices, we recommend that you review their privacy policies, terms of use, and license
agreements (if any).
In addition, some of our online products and services include advanced fraud prevention technology using
behavioral-based data or biometric information, such as keystroke timing, device accelerometer, scroll
position and mouse-location.
Applicable law means the Data Protection Act of Jamaica and any regulations made thereunder.
Where required under applicable law, we obtain your consent prior to using the above automated means, and
prior to sending you marketing communications, tailored content and advertising.
Personal Information We Collect in the Context of Our Business Relationship with Financial Institutions,
Merchants or other Entity Partnering with Amber Fundme
We may collect Personal Information from individuals working for one of our business partners (including
financial institutions, merchants, customers, suppliers, vendors and other partners), including identifiers,
name, job title, department and name of organization, business email and postal addresses, business
telephone number, queries, answers to security questions, security passwords and other credentials. We may
use this information to provide products and services directly to financial institutions, corporate clients,
merchants, customers and partners, to manage our business relationships and financial reporting, for
transparency and integrity, to protect us from financial crime, to improve our service, for marketing and to
comply with applicable law, as well as for accounting, auditing and billing purposes.
How We May Use Your Personal Information
We May Use Your Personal Information to:
Process your transactions.
Protect against and prevent fraud, and other legal or information security risks.
Provide and communicate with you about products and services offered by Amber
Fundme, and partners.
Provide you with personalized services and recommendations.
Operate, evaluate and improve our business, including anonymization and analytics.
Process your job application.
Serve other purposes for which we provide specific notice at the time of collection, and
as otherwise authorized or required by law.
Generate anonymized and aggregated data to prepare insights to advise Amber
Fundme’s
customers and partners regarding spending patterns, fraud and other trends.
Learn more about you, including your preferences or other characteristics. We treat
these inferences as Personal Information where required under applicable law.
Where required under applicable law, we will only use your Personal Information with your consent; as
necessary to provide you with products and services; to comply with a legal obligation; or when there is a
legitimate and overriding interest that necessitates the use.
We may use Personal Information we obtain about you for the purposes set out below. Depending on the country
in which you are located, we will only process your Personal Information, when we have a legal basis for the
processing.
Processing activity
Legal Basis for Processing (where required under applicable law):
Process your payment transactions (including authorization, clearing, chargebacks and
other related dispute resolution activities).
In most cases, we process your payment transactions as a processor on behalf of your
financial institutions, merchants and other partners which act as data controllers. When
we act as a processor, controllers are responsible for ensuring a legal basis for the
processing of your Personal Information.
In some cases we may process your payment transactions as a data controller, provided that:
You consented to the use of your Personal Information; or
The processing is necessary for entering into, or performance of a contract to which you
are party; or
The processing is necessary for compliance with a legal obligation or other regulatory
obligations.
Protect against and prevent fraud and cyber threats, unauthorized transactions, claims
and other liabilities, and manage risk exposure and franchise quality with respect to the
integrity and security of our payments network.
When we process Personal Information for fraud and cyber threat prevention, we may act as a controller or as a
processor.
When we act as a controller, we rely on one of the following legal grounds:
You consented to the use of your Personal Information; or
The processing is necessary for compliance with a legal obligation or other regulatory
obligations; or
The processing is necessary for entering into, or performance of a contract to which you
are party; or
We, or a third party, have a legitimate interest in using your Personal Information for
the purpose of protecting against fraud, securing our network and the payment
transactions that we process.
. We, or a third party, have a legitimate interest in using your Personal Information for
such purpose (e.g., detecting fraud risks or resolving disputes).
In some cases, we provide our Open Banking solutions as a processor on behalf of your
service provider, merchants and other partners which act as data controllers. When we
act as a processor, controllers are responsible for ensuring a legal basis for the
processing of your Personal Information. Please refer to their respective privacy policies
for more information regarding the processing of your Personal Information in these
contexts.
How We Share Your Personal Information
We May Share Personal Information with:
Amber Fundme affiliates and other entities within the Amber group of companies..
Service providers acting on our behalf..
Other participants in the payment ecosystem, including financial institutions, and
merchants..
Other participants in the Open Banking ecosystem, including financial institutions,
merchants and third parties..
Third parties for fraud monitoring and prevention purposes, or other purposes required
by law..
Third parties whose feature you use in connection with our products and services or
with your consent..
Other entities as required under applicable law or in the event of a sale or transfer of
our business or assets.
We do not disclose Personal Information we collect about you, except as described in this Data Protection
and Privacy Policy, as disclosed to you at the time of data collection or as described in our program
specific privacy notice. Please see the “Data Transfers” section below to understand how we comply with
applicable cross-border data transfer rules.
We may also share your Personal Information:
With financial institutions and other entities that issue payment cards or merchants to
process payment transactions and perform other activities that you request.
With entities that partner with Amber Fundme or assist Amber Fundme in providing its
products and services, for fraud prevention and monitoring and third party identification
services, to ensure the security of transactions and our payment processing system.
With other participants in the Open Banking ecosystem, including financial institutions,
merchants and other entities of your choice (e.g., your investment advisors).
When we act as a service provider for third parties and provide them with Personal
Information that we process on their behalf.
With our service providers who perform services on our behalf for the purposes
described in this Data Protection and Privacy Policy (or in the applicable program
specific privacy notice). We require these service providers by contract to only process
Personal Information in accordance with our instructions and as necessary to perform
services on our behalf or in compliance with applicable law. We also require them to
safeguard the security and confidentiality of the Personal Information they process on
our behalf by implementing appropriate technical and organizational security
measures and confidentiality obligations binding employees accessing Personal
Information.
With third parties whose features (e.g., third-party cookies, widgets, plug-ins) are
integrated in our products and services.
With social media networks when you directly engage with those platforms
With other third parties with your consent.
As required under applicable law or legal process, or to respond to requests from law
enforcement or governmental agencies.
When we believe disclosure is necessary to protect individuals’ vital interests, to enforce
our Terms of Use, prevent Amber Fundme against harm or financial loss, or in
connection with an investigation of suspected or actual fraudulent or illegal activity.
In the event we sell or transfer all or a portion of our business or assets. Should such a sale or
transfer occur, we will use reasonable efforts to direct the transferee to use Personal Information
you have provided to us in a manner that is consistent with our Data Protection and Privacy Policy.
Following such a sale or transfer, you may contact the entity to which we transferred your Personal
Information with any inquiries concerning the processing of that information.
Your Rights and Choices
Depending on your country, you may have the right or choice to:
Opt out of some collection or uses of your Personal Information, including the use of
cookies and similar technologies, the use of your Personal Information for marketing
purposes, and the anonymization of your Personal Information for data analyses.
Access your Personal Information, obtain a copy of it, rectify it, restrict or object to its
processing, or request its deletion, destruction or anonymization.
Receive the Personal Information you provided to us to transmit it to another company.
Withdraw any consent provided.
Where applicable, lodge a complaint with your relevant supervisory authority or
regulator.
You, or a party authorized to act on your behalf, can exercise your rights by sending an
email to Us as provided in the “How to Contact Us” section below.
You have certain rights regarding the Personal Information we maintain about you and
certain choices about what Personal Information we collect from you, how we use it,
and how we communicate with you.
Please note that in order to use the Amber Fundme product and services you agree to supply the required
personal information that we request from you.
You can choose:
Not to provide Personal Information to Amber Fundme by refraining from conducting payment
transactions or from submitting Personal Information directly to us. When we collect Personal
Information from you, we indicate whether and why it is necessary to provide it to us, as well as
the consequences of failing to do so. If you do not provide Personal Information, you may not be
able to benefit from the full range of Amber Fundme products and services, and we may not be able to
provide you with the Amber Fundme products or services if that information is necessary to provide
you with them, or if we are legally required to collect it in relation to the provision of such
product or service.
To opt out of the collection and use of certain information, which we collect about you by
automated means, when you visit our websites or use our apps you can exercise your choice regarding
the use of cookies and similar technologies by clicking on the ‘Manage cookies’ banner displayed in
the bottom right corner of Amber Fundme websites. Your browser may tell you how to be notified of
and opt out of having certain types of cookies placed on your device. Note that without certain
cookies you may not be able to use all of the features of our websites, apps or online services. The
aforementioned options may be restricted in certain jurisdictions.
To opt out of certain uses of information, which we collect about you by automated means, when you
visit third-party websites and interact with our ads. We may use service providers to serve ads on
those third-party websites. These ads may be customized and served based on the use of data we and
our partners have collected on our websites and apps. In addition, some of our service providers and
partners may collect information about your online activities over time and across third-party
websites to customize and serve these ads. Amber Fundme ads are sometimes delivered with icons that
help consumers (i) learn more about how their data is being used and (ii) exercise choices they may
have regarding the use of their data. Please click, where applicable, on the icon in our targeted
ads to learn about your ability to opt out or limit the use of your browsing behavior for
advertising purposes. You may also exercise your choice regarding the use of cookies and similar
technologies by clicking on the ‘Manage cookies’ banner displayed in the bottom right corner of our
websites.
You can tell us not to send you marketing emails by clicking on the unsubscribe link within the
marketing emails you receive from us or by contacting us as indicated below. You also may opt out of
receiving marketing emails from Amber Fundme. You can also contact Us at the email below to opt out
of receiving marketing emails.
To update your preferences, ask us to remove your information from our mailing lists or submit a request to
exercise your rights under applicable law, contact us as specified in the "How To Contact Us" section below.
If we fall short of your expectations in processing your Personal Information or you wish to make a
complaint about our privacy practices, please tell us because it gives us an opportunity to fix the problem.
To assist us in responding to your request, please give full details of the issue. We attempt to review and
respond to all complaints within a reasonable time and as required under applicable law.
Data Transfers
Amber Fundme is a global business. We may transfer the Personal Information we collect about you to
recipients in countries other than Jamaica, including the United States. Some countries may not have the
same data protection laws as the country in which you initially provided the information. When we transfer
your Personal Information to other countries, we will protect that information.
We comply with applicable legal requirements when transferring Personal Information to countries other than
the country where you are located.
We comply with applicable legal requirements when transferring Personal Information to countries other than
the country where you are located.
Depending on your country, you may contact us as specified in the “How to Contact Us” section below to
obtain a copy of the safeguards we use to transfer Personal Information outside of your jurisdiction.
How We Protect Your Personal Information
We maintain appropriate security safeguards to protect your Personal Information and only retain it for a
limited period of time.
The security of your Personal Information is important to AmberFundme. We are committed to protecting the
information we collect. We maintain reasonable administrative, technical and physical safeguards designed to
protect the Personal Information you provide or we collect against accidental, unlawful or unauthorized
destruction, loss, alteration, access, disclosure or use. We use SSL encryption on a number of our websites
from which we transfer certain Personal Information.
We also take measures to delete your Personal Information or keep it in a form that does not permit
identifying you when this information is no longer necessary for the purposes for which we process it,
unless we are required by law to keep this information for a longer period. When determining the retention
period, we take into account various criteria, such as the type of products and services requested by or
provided to you, the nature and length of our relationship with you, possible re-enrolment with our products
or services, the impact on the services we provide to you if we delete some information from or about you,
mandatory retention periods provided by law and the statute of limitations.
Features and Links to Other Websites
Our websites may include links to other third-party websites, social media tools, widgets or plug-ins,
permitting sharing web content including IP address, with third parties and social media providers. These
social media providers may learn of your visit even if you are not logged in to your social media account or
if you do not have an account with them. To the extent any linked websites or features you visit or use are
not owned or controlled by AmberFundme, we suggest that you review their own privacy notices or policies.
Our websites may provide links to other websites for your convenience and information. Our website may also
contain certain features for which we partner with other entities. These entities may learn of your visit
regardless of whether you use these features. These websites and features, which may include social
networking and geo-location tools, operate independently from Amber Fundme, and are clearly identified as
such. To the extent any linked websites or features you visit or use are not owned or controlled by Amber
Fundme, we suggest that you review the privacy practices of the websites.
Amber Fundme offers you the possibility to share, link to, or mention things on social media about Amber
Fundme’s products and services. For example, you may “like” an offer via your Facebook account, or “tweet”
an offer using Twitter. When you visit a website with a social media button, your browser establishes a
direct connection to that social media provider, and data concerning your visit, including IP address, is
transferred to the social media provider. If you have an account with the social media provider, the
provider may link your visit to your account, even if you are not logged into this account.
You may also choose to use certain features on our websites that can be accessed through, or for which we
partner with, other entities that are not otherwise affiliated with Amber Fundme. These features, including
geo-location tools, are operated by third parties and are clearly identified as such. Social media providers
such as Facebook and Twitter, and these other third parties, are independent from Amber Fundme and do not
necessarily share the same policy as Amber Fundme regarding the protection of privacy. Please review their
privacy notices if you decide to use their services and consult your social media account settings if you
want to deactivate certain features.
Children’s Privacy
Amber Fundme’s products and services are not directed to, or intended for, children under the age of 18.
Updates to This Data Protection and Privacy Policy
This Data Protection and Privacy Policy may be updated periodically to reflect changes in our privacy
practices.
This Data Protection and Privacy Policy may be updated periodically to reflect changes in our Personal
Information practices. We will post a prominent notice on relevant websites to notify you of any significant
or material changes to our Data Protection and Privacy Policy and indicate at the top of the Notice when it
was most recently updated. If we update our Data Protection and Privacy Policy, in certain circumstances, we
may seek your consent.
How to Contact Us
You can e-mail our Privacy Office at info@amberfundme.com. You may also submit a request to exercise your
rights to your Personal Information.
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