Introduction

EdenMoney® is committed to respecting the privacy of its clients and partners and as such, is committed to ensuring the protection of all the Personal Data it collects and processes. EdenMoney® has both a legal and a moral responsibility to ensure that as an organisation, we handle Personal Data in line with all legal and regulatory requirements.

Although every effort has been made to ensure that this Privacy Policy is as easy to understand and as ‘jargon’ free as possible, there are times that we must use data protection specific wording and if at any point you feel you do not fully understand the contents of this Privacy Policy, please refer to refer to guidance issued at: www.knowyourprivacyrights.org

We know that data protection can often be quite a specialist subject and we have tried to make this Privacy Policy as simple as possible, to assist you in understanding exactly how and why we process your Personal Data.

Who we are

EdenMoney®® is a trading name of Eden Charge Limited, a company incorporated in the Isle of Man with register number 133351C, hereinafter referred to as “EdenMoney®”, “we, “us” “our” and the “Company”.

Eden Charge’s Registered Office is: Suit 1, First Floor, 4 Athol Street, Douglas, Isle of Man, IM1 1LD.

Eden Charge is registered with the Isle of Man Informational Commissioner as a Data Controller, Registration No: R003086, details of our registration can be found here

Relevant legislation

In 2016, the European Union approved the General Data Protection Regulation 2016/679 (GDPR), which came into operation with the E.U. on the 25th May 2018.

In response, the Isle of Man Government implemented the Data Protection (Application of GDPR) Order 2018, which came into operation on the 01st May 2018 – effectively adopting GDPR into Isle of Man law.

EdenMoney®, as an Isle of Man based company, is required to follow the requirements of the Data Protection (Application of GDPR) Order 2018.

This Privacy Policy

This Privacy Policy, together with the Terms and Conditions, has been designed to provide details on the following:

Where we collect Personal Data from
Why we collect this Personal Data
Scope and limitation
What Personal Data is collected
The legal basis we use for processing your Personal Data
Who we share your Personal Data, and why
Where your Personal Data is stored
How long we retain your Personal Data for
Your rights to access your Personal Data and how to exercise them
Our contact details
The contact details of the relevant Supervisory Authority

You indicate your understanding and acceptance of the terms of this Privacy Policy by continued use of the services of EdenMoney®, including the Platform and website.

Players – Personal Data

Where we collect Personal Data from

EdenMoney® collects Personal Data from you when you:

Use the EdenMoney® Platform and/or website
Contact the Company by email or in-app messenger service
Contact the Company by telephone or video call
Communicate with the Company via EdenMoney®’s social media accounts

Why we collect Personal Data

We collect and process Personal Data for the following purposes:

To enable you to use the Platform
To perform regulatory compliance checks
To prevent fraud
To deal with enquiries, complaints, and feedback from you and our service providers
To manage and administer the Platform
To improve your browsing experience by personalising the Platform
To analyse and improve the services offered on the Platform
To provide third parties with statistical, anonymised, information about our users
To publish generic transactional information

Scope and limitation of Personal Data collection

EdenMoney®’s policy is to only process the Personal Data necessary for the purposes detailed above and as required under the relevant Anti-money laundering regulations.

Throughout the data collection process and the course of the business relationship we will only ask you to provide Personal Data to us where it is strictly needed for these purposes and will only process your Personal Data when and how the law allows us to.

What Personal Data is collected

The types of Personal Data processed by us in relation to the services we provide are usually limited to:

Full name (including prior or aliases if applicable)
Date and place of birth
Nationality
Sex
Residential address
Contact details such as email address, and telephone number(s)
Financial details such as bank account and debit / credit card details
Languages spoken for contact purposes
Your IP address and corresponding geographical location

Lawful basis for processing

Your Personal Data is processed in accordance with the following lawful basis:

Contractual – for the provision of services to you
Legal obligation – in accordance with relevant Anti-money laundering regulations

What other information is collected

Technical information

EdenMoney® may also process information obtained from computer, mobile device, or other hardware through which you access the Platform, including, without limitation:

Browser/platform type and version
Internet Service Provider
Operating system
Referral source/exit pages
Length of visit
Page views
Platform navigation
Search terms that you use

This information is collected and anonymised.

Cookies

For more information on the Company’s use of Cookies, please see our Cookies Notice.

Transactional data

EdenMoney® processes information regarding the dates, times, currency, and amounts of:

Deposits
Withdrawals
Currency conversions
Transactions, including amounts and details of the Providers and item(s) purchased

… performed within the Platform.

Lawful basis for processing

This technical and transaction information is processed in accordance with the following lawful basis:

Legitimate interest – to enable EdenMoney® to analyse and improve our service offering and Platform.

What Personal Data is not collected

Special Category Personal Data

EdenMoney® does not collect, use, hold, or process any Special Category Personal Data.

Personal Data relating to criminal convictions and offences

EdenMoney® does not collect, use, hold, or process any Personal Data relating to criminal convictions or offences.

Parent / Child accounts – Personal Data of minors (Children under 16)

As part of the Parent / Child account feature, EdenMoney® is required to process certain Personal Data in respect of minors, for them to use this feature and the Platform itself. EdenMoney® ensures that we minimise the amount of Personal Data processed in accordance with principle 3 of GDPR – Data minimisation.

What Personal Data is collected

The types of Personal Data processed by us in relation to the services we provide are limited to:

Full name
Date of birth
Contact details such as email address, and telephone number(s)

Lawful basis for processing

Your Personal Data is processed in accordance with the following lawful basis:

Explicit consent provided by the parent / legal guardian

As part of the Terms and Conditions of use in respect of the Parent / Child account features, you are required to provide explicit, opt-in, consent to EdenMoney® for the processing of the Personal Data of minor(s) whose sub-account(s) are connected to your account.

By providing consent, you are confirming that you have the right to do so, as the parent or legal guardian of the minor(s) who will be using the Parent / Child account feature.

Withdrawal of this consent will result in the removal of the Parent / Child account feature.

What Personal Data is not collected

Special Category Personal Data

EdenMoney® does not collect, use, hold, or process any Special Category Personal Data on minors.

Personal Data relating to criminal convictions and offences

EdenMoney® does not collect, use, hold, or process any Personal Data relating to criminal convictions or offences on minors.

How EdenMoney® uses your Personal Data

Who we share Personal Data with

Except to the extent required by any applicable law or governmental, regulatory, or judicial body, EdenMoney® will not disclose your Personal Data to any third party other than to selected service providers to whom we are engaged with for their products and services to us.

However, EdenMoney® has a legal obligation to share information (at times statistical and anonymised) with competent authorities, such as:

Regulatory authorities
Law enforcement agencies

In some cases, your Personal Data may be accessed by service providers of EdenMoney® as part of the Company’s own legal, regulatory, and risk management requirements. These include:

Professional legal advisers
Auditors and quality assurance firms
Banking and payment institutions
Due diligence screening agencies
IT and cyber security partners

All external organisations listed above have their own legal obligation to comply with privacy and data protection legislation and may also operate under a professional duty of confidentiality due to the type of service they provide. They have their own privacy policies that provide information about how they use your information.

In all cases, EdenMoney® will hold legal engagements with suitable and appropriate data protection clauses and safeguards in place and will always take the appropriate steps to protect the Personal Data it is responsible for.

If you wish to find out more about the organisations your Personal Data is shared with, you can do so by submitting a request to the EdenMoney® Data Protection Officer – details outlined below.

EdenMoney® will never sell or provide access to your Personal Data to unauthorised 3rd parties.

Anti-money laundering checks

EdenMoney® utilises an independent third party to perform anti-money laundering checks called: Trulioo

As a part of this process, we provide Personal Data and due diligence documentation to Trulioo who undertake regulatory required compliance checks. Details of Trulioo’s Privacy Policy can be found here

Trulioo stores a copy of your Personal Data for 1 week after it has performed the Anti-money laundering checks, after which time your Personal Data is automatically deleted.

Where is your Personal Data held

EdenMoney® stores your Personal Data, electronically, on our servers based in the Isle of Man

Data retention

To determine the appropriate retention period for personal data, EdenMoney® considers both legal requirement and the nature of the Personal Data we process when determining the most appropriate retention timeframes.

In all cases, your Personal Data will be maintained on our system for the lifetime of your relationship with EdenMoney®.

Personal Data will be retained for 6 years after the closure of your EdenMoney® account; although we reserve the right to hold Personal Data for longer periods as required by law or regulation and to establish, exercise, or defend our legal rights. Your Personal Data will be automatically deleted at the end of the retention period.

Communications

Legal and technical

From time to time, the Company may need to contact you to advise of system related matters such as scheduled maintenance, updates, or changes to functionality or to advise of updated Terms and Conditions. Such communication will only be sent to email address registered to your EdenMoney® account.

Marketing, promotions, and surveys

If you wish to subscribe to any EdenMoney® marketing materials published by the Company or wish to receive focused and relevant promotional communications from the Company or carefully selected affiliates or partners, the Company can offer you the option to ‘opt-in’ to this service.

If you ‘opt-in’, EdenMoney® will:

Send you newsletters and other relevant and targeted promotional communications
Send you emails offering you to take part in surveys and/or to give feedback

If you change your mind and wish to stop receiving any such communications, please click the ‘unsubscribe’ link in any email from the Company.

The Company will never send unsolicited marketing communication.

Your individual rights and how to exercise them

GDPR enshrines the rights of all individuals whose Personal Data is processed by an organisation covered by the legislation, as such, you have the following rights in respect of your Personal Data and privacy:

Your right to access personal data

You have the right to request access to your personal data, commonly known as a “Data Subject Access Request“. This enables you to submit a request to us for details on all the Personal Data we hold about you

To submit a Data Subject Access Request, please contact the Data Protection Officer here who can assist and kindly see the Data Subject Access Request section below for more information.

Your right to correction / amendment of personal data

You have the right to request correction of any Personal Data we hold if you believe this Personal Data is inaccurate or outdated. In those instances, we will need to verify the accuracy of the new data you provide to us.

If you wish to correct any data, Please submit a request here

Your right to erasure / right to be forgotten

You have the right to request erase of the Personal Data that we hold about you, commonly referred to as “the right to be forgotten”. Examples of why you may wish to exercise this right include, but are not limited to:

the Personal Data is no longer necessary in relation to the purposes for which it was originally collected and processed by us
where the legal grounds for EdenMoney® processing your Personal Data is consent, please note that if you withdraw consent then we may not other lawful basis for processing
where the legal grounds for EdenMoney® processing your Personal Data legitimate interests pursued by us or a third party, but you object to our processing and we do not have overriding legitimate grounds
you object to EdenMoney® processing for direct marketing purposes
you believe that your Personal Data have been unlawfully processed
your Personal Data must be erased to comply with a legal obligation to which EdenMoney® is subject

If you wish us to exercise your right to be forgotten, please submit a request here

However, we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request although the most common reasons for this include complying with local or international regulations and requirements in relation to:

preventing financial crime, money laundering and the funding of terrorism
identifying politically or commercially exposed persons, or those with a significant exposure to the media
identifying designated persons, or those with significant exposure to individuals and entities subject to Financial Sanctions

If you are unsure whether we can erase your Personal Data, please submit a request here

Your right to object to processing of Personal Data

You have the right to object to the processing of your Personal Data 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.

Please submit a request here

Your right to restrict processing of Personal Data

You have the right to restrict processing of your Personal Data which means you are entitled to request suspension of the processing of your Personal Data in the following scenarios:

if you want EdenMoney® to establish the data’s accuracy
where EdenMoney®’s use of the data is unlawful, but you do not want us to erase it
where you need EdenMoney® to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims
you have objected to EdenMoney®’s use of your data, but we need to verify whether we have overriding legitimate grounds to use it

Please submit a request here

Your right to data portability

Given the nature of the services that EdenMoney® provides, we currently do not believe that this applies to how we process Personal Data however, we are happy to discuss this with you should you feel differently.

Please submit a request here

Your right to withdraw consent

You have the right to withdraw your consent at any time where EdenMoney® is relying on consent to process your Personal Data.

If you do withdraw consent, please note that this will not affect the lawfulness of any processing carried out before you withdrew your consent.

Please submit a request here

Data Subject Access Request

How to make a Data Subject Access Request

To submit a Data Subject Access Request, please submit a request here

Fees

You will not have to pay a fee to access your Personal Data (or to exercise any of your other rights). However, EdenMoney® can charge a reasonable fee if we believe your request is unfounded, repetitive, or excessive.

If EdenMoney® believes that your request(s) are unfounded, repetitive, or excessive, we may refuse to comply with said request in such circumstances and will report our reasoning, as well as the details of your request(s), to you and our relevant Supervisory Authority – details can be found below.

Information we need from you

EdenMoney® may request specific information from you to help us confirm 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 inadvertently 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.

Our response

EdenMoney® is required to respond to your request within 30 calendar days of receiving it. We will provide confirmation to you that we have received your request as well as the date we must have to respond by. Occasionally, it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and provide you with a reasonable time frame for our response.

Follow up

If you are not happy with our response to your Data Subject Access Request, you have the right to make a complaint to either the Isle of Man Information Commissioner or the relevant supervisory authority of your relevant jurisdiction.

The contact details for the Isle of Man Information Commissioner are detailed below.

Data Security – How we protection your Personal Data

Data Security is of the upmost importance to EdenMoney® and to that end, we have put in place appropriate security measures to protect your Personal Data from being accessed by any unauthorised parties. As part of this, we use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

As the transmission of information via the internet may not be completely secure, we are therefore unable to guarantee the security of the Personal Data transmitted through the Company’s website or through mobile communications.

Any transmission is at your own risk. Personal Data that is received by the Company is subject to strict procedures and security features designed to prevent unauthorised access.

Access to your Personal Data is limited to authorised employees, banking and payment institutions, insurers, service providers and other third parties who require access for the fulfilment of a contract or agreement linked to the provision of services to you or us.

These third parties will only process your Personal Data on our explicit and documented instructions, with all processing relationships managed by an appropriate legal agreement and terms of business and if relevant, GDPR’s Standard Contractual Clauses (SCC).

Changes to this privacy policy

This Policy will be reviewed from time to time and may be changed without notice. Any Personal Data processed will be in accordance with the most current Privacy Policy of the Company, which will always be available on both the EdenMoney® Platform and website.

This Privacy Policy was updated: 14 February 2022

Data Controller contact information

The contact details for EdenMoney®’s Data Protection Officer are: dataprotection@edenmoney.com

Complaints to our relevant Supervisory Authority

If you are unhappy with our treatment of your Personal Data, you have the right to make a complaint at any time to the Information Commissioner’s Office in the jurisdiction in which you live or in the jurisdiction in which the Data Controller operates (if different). As EdenMoney® operates in the Isle of Man, details of the Isle of Man Information Commissioner are outlined below:

Information Commissioner’s Office (ICO)
First Floor
Prospect House
Prospect Hill
Douglas
Isle of Man
IM1 1ET

Telephone number: +44 1624 693260
Email address: ask@inforights.im
Website: https://www.inforights.im/

Disclaimer

Whilst every effort has been taken to ensure the accuracy of the information on this Website, all liability which might arise from your use or reliance on the information or links contained on the Website are excluded.

The content of this Privacy Policy is provided for general information purposes only, to inform you about EdenMoney®’s data protection activities. It does not constitute legal advice (or any other type of advice) and should not be relied on for this purpose.

This Website contains links to other websites. EdenMoney® does not endorse, and accepts no responsibility or liability for, any material supplied by or contained on any third-party website which is linked from or to this Website or any use of personal data by any third party.

This privacy policy is set out primarily in accordance with Isle of Man law in conjunction with the E.U. General Data Protection Regulation.

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