September 2023

Privacy Notice for Professional Partners

This privacy notice (“Privacy Notice”) explains how we process your personal data (“Personal Data”) when you browse our website or mobile application (“Website/App”) and when you apply to become or act as a Ria agent and/or interact with us as a professional partner (“Professional Partner”).

We encourage you to review this Privacy Notice regularly and check the Website/App for any updates. Updates to this Privacy Notice will be published on our Website/App, and by continuing to engage with us, you agree to this Privacy Notice and any future amendments.

If local laws require additional details to be included in this Privacy Notice, such information has been included in the Regional Privacy Notice sections below.


Who are we?

We are RIA, part of the Euronet Group companies.

You can find all of our contact details here.


What types of Personal Data are collected?

We only collect Personal Data necessary to provide you with the Services and to comply with applicable laws.


Why do we collect Personal Data?

We collect Personal Data for specific contractual and legal purposes.

With your consent, we also collect data for additional purposes.


How long does RIA retain Personal Data?

We retain Personal Data only as long as necessary or as required by applicable law.


With whom do we share Personal Data?

We share Personal Data with other Euronet Group companies, legal authorities, and partners where necessary to fulfill regulatory requirements or contractual commitments.


Where does RIA store Personal Data?

We store Personal Data in secure locations with strict security measures.

If we need to transfer Personal Data to another location, we take all necessary steps to comply with legal obligations and ensure an appropriate level of security.


What are your Personal Data rights?

Depending on where you live, you may have rights regarding your Personal Data under applicable laws. A description of common Personal Data rights is set out in Section 15 below. To submit a request, you may contact us by email at dpo@euronetworldwide.com or by phone (local phone numbers are available here).

Internal Appeals Process

If you receive notice from us that your Personal Data rights request has been denied, you may appeal the denial within a reasonable period after receiving the notice by emailing dpo@euronetworldwide.com.


1. What Personal Data do we collect, how do we collect it, and why?

The categories, sources, and reasons for collecting Personal Data are listed below. Where the collection of Personal Data is based on your consent, you may withdraw your consent at any time. RIA does not and will not “sell” or “share” Personal Data, as those terms are defined under applicable law. We retain Personal Data for as long as reasonably necessary to provide the Services and fulfill our legal obligations.

If you have questions or concerns regarding the processing of your Personal Data, you may contact us at any time at dpo@euronetworldwide.com.


Identifiers or Identification Data

The Personal Data we collect from you may include your name, email address, phone and/or fax number, residential and/or business address, and other contact data (“Contact Details”), title, date of birth, gender, image, video, or signature.

Where necessary, identification data is used only for the purposes described.

Reason for processing your data

Legal basis

Provision of Services

Contractual obligation

Representing the company regarding legal requirements (contracts, negotiations)

Contractual obligation

Providing operational support

Legitimate interest

Your participation in events or giveaways organized by us

Consent

Compliance with our legal obligations related to record retention, including correspondence such as emails, faxes, electronic communications, customer account records, customer service letters, and communications between us, Euronet Group companies, partners, and suppliers

Legal obligation

Managing your account (registration, administration, maintenance, servicing)

Contractual obligation

Advertising and marketing

Consent / Contractual obligation

Criminal records

Legitimate interest


Financial Details and Professional or Employment-Related Information

We collect your personal financial data when you register to use our Services. We collect financial data such as bank account information, financial statements, transfer reasons, occupation (professional or employment-related information), or other documentation showing the source of funds you intend to transfer (similar to pay slips), in order to provide our Services.

Reason for processing your data

Legal basis

Provision/performance of Services

Contractual obligation

Anti-money laundering

Legal obligation

Prevention of terrorist financing and criminal activity

Legal obligation

Managing customer accounts

Contractual obligation

Provision/performance of Services

Contractual obligation


Behavioral and Technical Information

IP address, internet or similar network activity, browsing or search activity, behavioral information (to understand how you behave while using our products and services), browser type and version, time zone settings, screen resolution settings, browser plug-in types and versions, operating system, and platform.

See our Cookie Policy.

Processing Purpose

Legal Basis

Conducting analytics to measure Website/App and Service usage, including number of visits, average time spent, viewed pages, interaction data (scrolling, clicks, mouse hovers), and improving content offered

Legitimate interest

Verifying or maintaining Service quality, improving or upgrading Services, administering the Website/App, troubleshooting, data analysis, testing, research, statistics, and surveys

Consent / Legitimate interest

Helping ensure the security and safety of our Website/App

Consent / Legitimate interest

Advertising and marketing, including measuring the impact of emails

Consent


Audio and Video Monitoring

Images, videos, and audio/voice recordings.

Processing Purpose

Legal Basis

Maintaining the security of our Services through CCTV monitoring in our stores or offices

Legitimate interest

The Personal Data collected from you may vary depending on the country where our Services are offered. Not all categories described above may apply to you.


Non-Identifiable Data

Where possible, we use data that cannot directly identify you (such as anonymous demographic and usage data) instead of Personal Data (“non-identifiable data”). This non-identifiable data may be used to improve our internal processes or service delivery without further notice to you.

We may use aggregated data for various purposes, including analyzing, evaluating, and improving our Services.


Device Features

When using the app, we may require access to additional information and certain features of your device, such as your contact list. Before accessing such information, we will request your permission. Any data obtained through these device features will only be stored on your device, never on our servers or elsewhere.


2. Accuracy of Personal Data

We are committed to ensuring your Personal Data is accurate and up to date. We take reasonable steps to ensure accuracy by properly recording the latest Personal Data we receive and, where necessary, conducting periodic reviews and requesting updates from you.

From time to time, we may send emails asking you to confirm and/or update your Personal Data. These communications are based on our legitimate interests and legal obligations to maintain accurate and current information.

If you find that your Personal Data is inaccurate, you may request correction or update your information by emailing dpo@euronetworldwide.com.


3. Legitimate Interests

Where we use your Personal Data to pursue our legitimate interests, we will make every effort to align our interests with yours so that your Personal Data is only used as permitted by applicable law or where it does not adversely affect your rights.

Upon request, customers may request information regarding any processing based on legitimate interests.


4. How long does Ria retain Personal Data?

Personal Data is retained for as long as necessary to provide the requested Services and to comply with applicable legal, accounting, or reporting obligations.

Retention periods are determined based on applicable requirements and obligations, which may include:

  • Legal and Regulatory Requirements

  • Customer Service and Contractual Relationships

  • Marketing purposes until you opt out or until we determine you are no longer interested or the data is inaccurate


5. Does Ria share my Personal Data with third parties?

Euronet Group

We disclose your Personal Data to Euronet affiliates and Euronet Group companies for the daily business purposes of our affiliates and compliance with group obligations.

As a result of any sale, acquisition, merger, or reorganization involving Euronet or any Euronet Group company, customer Personal Data may be transferred to third parties. In doing so, reasonable measures will be taken to ensure adequate protection.

Your Personal Data may also be disclosed to provide customer support services, including 24/7 customer service access.

Legal Basis

Legal obligation

Contractual obligation


Third-Party Service Providers

We may share Personal Data with:

  • Data analytics and identity verification providers for compliance verification (e-KYC) and fraud prevention services

  • Advertisers, advertising networks, and social media companies for personalized advertising and adaptation to user preferences

Legal Basis

Legal obligation

Consent

Contractual obligation

The legal meaning and list of “third-party service providers” may vary depending on your country of residence.


Legal and Regulatory Authorities

We may disclose your Personal Data if requested by authorized authorities or as necessary to enforce our Terms and Conditions or other agreements with you.

Legal Basis

Legal obligation

Contractual obligation


Strategic Partners

We may share your Personal Data with strategic partners where necessary to provide our Services.

Legal Basis

Legal obligation


Professional Partners

We may share your Personal Data with advisors, lawyers, consultants, auditors, or accountants to comply with legal obligations and provide our Services.

Legal Basis

Legitimate interest


6. Minors

We do not directly provide Services to children under 18 years of age or knowingly collect their personal information. If you are under 18, please do not use the Website/App or share Personal Data with us.

If you become aware that anyone under 18 has unlawfully provided us with Personal Data, please contact dpo@euronetworldwide.com.


7. Data Security

We are committed to protecting your Personal Data and have implemented commercially reasonable safeguards to prevent loss, misuse, or alteration of information entrusted to us.

All Personal Data is stored in secure locations protected by firewalls and advanced security mechanisms with restricted administrative access.

Personnel with access to your Personal Data are contractually bound to maintain confidentiality and comply with our internal privacy policies.

We aim to achieve the highest standards of data protection using industry-standard measures to protect your privacy.


8. Marketing and Advertising

Third-party advertisers provide advertisements displayed on our Website/App or elsewhere in our Services. Third-party advertisers do not have access to information directly provided by our customers.

If you have consented to Targeting Cookies or enabled targeting features, we may use third parties for remarketing and similar audience features.

You may opt out of advertising by modifying your cookie settings.

We may contact you periodically for marketing purposes where permitted and where you have provided consent or where otherwise permitted under applicable law.

You may withdraw your consent at any time by:

  • Updating your marketing preferences in your profile

  • Using the unsubscribe link in our communications

  • Emailing dpo@euronetworldwide.com


9. Description of Personal Data Rights

Depending on applicable law, your rights may include:

  • Right to Know

  • Right of Access

  • Right to Correct Inaccuracies

  • Right to Deletion

  • Right to Opt Out

  • Right to Restrict Processing

  • Right to Data Portability

  • Right to Object

  • Rights related to Automated Decision-Making

  • Right Against Retaliation

We will respond to requests within the periods required by applicable law.

Some rights may be limited due to legal, contractual, anti-money laundering, or compliance obligations.


10. Privacy Complaint Procedures

Data Subjects may file complaints with relevant data protection authorities or courts if they believe we have failed to comply with applicable law or this Privacy Notice.

Relevant authorities include:

  • European Data Protection Board (EEA)

  • UK Information Commissioner’s Office (ICO)

  • Federal Data Protection and Information Commissioner (Switzerland)

  • National Privacy Commission (Philippines)

  • Personal Data Protection Department (Malaysia)

  • Office of the Australian Information Commissioner

  • Federal Trade Commission (US)

  • Office of the Privacy Commissioner of Canada

  • Consejo para la Transparencia (Chile)

  • and others listed in the original notice.

RIA reserves the right to amend this Privacy Notice at any time.