Customer Privacy Policy.

In the European Economic Area (EEA), Global Simple Solutions Sp. z o.o. is the primary controller of your personal data.

We collect your personal data when you use our website at global-simple.com or any of the services available to you through our apps or website. We may also collect your personal data from other people or companies, as explained in the data collection section below.

When we say 'personal data', we mean information which we know about you (for example, we know when you use your GSS card to pay for things), or which can be used to personally identify you (for example, a combination of your name and postal address).

This notice explains what information we collect, how we use it, and your rights over your personal data.

Sometimes, we may also provide you with 'just in time' privacy explanations in our apps. When you use a new GSS product or service for the first time, these explanations will help you understand what specific personal data GSS collects, uses or shares for that product or service, and where relevant, you will be prompted to review your in-app privacy preferences.

We may provide privacy notices and explanations in languages other than Polish. If there are any discrepancies between other language versions and the Polish language versions, the Polish language version is authoritative.

If you have concerns about how we use your personal data, you can contact [email protected].

We collect information you provide when you:

Whenever you use our website or apps, we collect the following information:

We create new data about you by analysing the information we already have. This includes:

We collect personal data from third parties or other people, such as:

Credit reference agencies e-KYC providers Financial or credit institutions Price comparison websites Official registers and databases Joint account holders Fraud prevention agencies Partners assisting with crypto compliance (including for Travel Rule checks) Merchants in higher risk sectors (like gambling or crypto) Other third parties providing fraud prevention services Partners who help us to provide our services This includes your confirmation of ownership, tax identification numbers, information about late payments, information to help us check your identity or eligibility to receive selected GSS products or services, information about your spouse and family (if applicable in the context of an application for credit that you make), fraud risk scores and information relating to your transactions.

When you ask us to, we'll also collect personal data from accounts you hold with third party financial institutions (for example, when you create a linked account by activating Gemba account). If you apply for our credit products, when you allow us, we may use this information for credit checks.

Sometimes other GSS customers may give us information about you. For example, a GSS customer may tell us that you have behaved inappropriately and provide us with evidence to support their claim.

Occasionally, we'll use publicly available information about you from selected social media websites or apps to:

We collect information and contact details from publicly available sources, such as media stories, online registers or directories, and websites for enhanced due diligence checks, security searches, and KYC purposes.

We must have a legal basis (a valid legal reason) for using your personal data. Our legal basis will be one of the following:

We need certain personal data to provide our services and cannot provide them without this personal data.

In some cases, we have a legal responsibility to collect and store your personal data (for example, under anti-money laundering laws we must hold certain information about our customers).

We sometimes collect and use your personal data because we have a legitimate reason to use it and this is reasonable when balanced against your human rights and freedoms.

Where we process your personal data, or your sensitive personal data, to adhere to government regulations or guidance, such as our obligation to prevent fraud or support you if you are, or become, a vulnerable customer.

We may need to use your personal data to protect your life or the life of another person (for example, in a medical emergency or where we have concerns about potential self-harm).

Where you've agreed to us collecting and using your personal data, including sensitive personal data, for example when you tick a box to indicate you're happy for us to use your personal data in a certain way.

The specific legal basis for processing your personal data, including sensitive personal data, depends on local regulations and the context of data collection. Whenever possible, we will provide a brief privacy explanation at the time of data collection to clarify the specific lawful basis.

Below are the ways in which we may use your personal data, and our legal basis for doing so.

Whenever you sign up with GSS, we'll use your personal data to check your identity or the identity of joint account holders (as part of our KYC process). This may include facial scan data (biometric data), or voice data, extracted from any photo or video you submit. We do this to:

confirm you are who you say you are; prevent fraudsters getting access to your GSS account;

and make sure you're not somebody we've previously told we cannot provide services to. We will also check your identity at other times (for example, if your identification documents expire). If you register a new device or try to chat with customer support while not logged in, we'll also need to verify that it's really you.

Whenever you apply for or use a GSS product or service, we'll use your personal data to: decide whether or not to approve your application; meet our contractual and legal obligations; enable any Payment Links relating to your account; carry out confirmation of payee checks; help you understand your spending behaviour; and provide you with customer support services. We may record and monitor communications between you and us, including phone calls, to maintain appropriate records, check your instructions, and improve our services.

We use your personal data to check your address and identity, protect against fraud, keep to financial crime laws, and confirm that you're eligible to use our services. We also use it to help us better understand your financial circumstances and manage fraud risks related to your GSS account. To keep our anti-fraud measures effective, we can't always share all the details about how we prevent fraud. However, we will always give you general information about our efforts to keep you safe.

We use your personal data to personalise your in-app experience and marketing messages about our products and services so they're more relevant to you (where allowed by law). This may include analysing how you use our products and your transactions. Where you agree, we'll share information about our partners' promotions or offers, allow our partners to provide you with information about their products or services, and ask your opinion about our products or services. You can ask us to stop sending you marketing information by adjusting your marketing preferences in-app.

We use your personal data to manage our website and apps, including troubleshooting, data analysis, testing, research, statistical and survey purposes, and to make sure content is presented in the most effective way for you and your device. We also use it to: authenticate you as an authorised user when necessary; allow you to take part in interactive features; tell you about changes to our services; and help keep our website and apps safe and secure.

We use your personal data to help with social interactions through our services or to add extra functions for a better experience. For example, if you give us permission, we'll use the contacts list on your phone so you can easily make payments to, or message, your contacts using the relevant GSS app. We also use this data to identify if your contacts are users of third party payment schemes that GSS participates in, so you can make peer-to-peer transfers to them.

If you turn location services on in the relevant GSS app, we use your personal data to: provide you with products and services; provide relevant advertising to you (for example, information about nearby merchants); and protect against fraud.

We prepare anonymous statistical datasets about our customers' spending patterns for forecasting purposes, to understand how customers use GSS, and to comply with governmental requirements. These datasets may be shared internally or externally. The information is never personal data and you will never be identifiable from it. For example, some countries require us to report spending statistics — we provide anonymised data about broad categories of merchants, account top-ups, and money transfers, but never customer-level information.

We use your personal data to understand how customers use our products and services, help us develop and improve them, develop and train our internal models (to ensure decisions are accurate, fair and effective), and show you only the products you are eligible for. For example, we might check how you use our apps to see if your salary is paid into your GSS account, or include you in a focus group to test new products we think you'll find relevant.

Legitimate interests (product development, responsible use, improving current products)

We use your personal data to help us identify if you may need extra assistance. You can let us know if you need help, or we may analyse your behaviour in the GSS app, customer support chats, and transactions. We try to spot signs of vulnerability so we can offer better support. In some countries it is a legal requirement to proactively identify and assist vulnerable customers.

Depending on the GSS products or services you use, we may make automated decisions about you. Some of these decisions are made using artificial intelligence without any initial human input.

We may also use technology to evaluate your personal circumstances and other factors to predict risks or outcomes. This is sometimes known as profiling. We do this for the efficient running of our services and to ensure decisions are fair, consistent, and based on the right information.

If we make an automated decision or create a profile about you that significantly affects you, you have the right to request a manual review of that decision by a person. You can also share your perspective and challenge the outcome. For more information, please see the What are my rights? section below.

Where we use automated decision-making:

Opening accounts KYC, anti-money laundering and sanctions checks Identity and address checks Detecting fraud Monitoring your GSS account to detect fraud and financial crime Restricting or closing accounts Deciding, or helping to decide, whether to lock, restrict, or close your GSS account if we detect fraud, financial crime or a breach of our Personal Terms (or other relevant terms and conditions) Our legal basis is one or more of the following:

If you sign up to our services, and where national laws allow, we'll assume you want to be contacted by post, push notification, email, phone call and text message with information about GSS products, services, offers and promotions. Where national laws require us to get your consent to send marketing communications, we'll do so in advance.

We use your personal data to personalise marketing messages about our products and services so they are more relevant and interesting to you (where allowed by law). This may include analysing how you use our services and your transactions. We may use generative artificial intelligence technology to help us select and personalise the most relevant content for you.

You can object to profiling for direct marketing purposes. You can also adjust your preferences or tell us you don't want to receive direct marketing at any time — just use the privacy settings in the relevant GSS app or tap the unsubscribe links in any marketing message we send you or, if we call you, ask us not to contact you again.

If you do not want to receive personalised marketing messages and opt out, you will not receive any marketing communications. However, you may still receive generic information about our products and services in our apps.

Our legal basis is:

Your ability to exercise these rights will depend on a number of factors. Sometimes, we won't be able to agree to your request (for example, if we have a legitimate reason for not doing so or the right does not apply to the particular information we hold about you).

We explain how we use your personal data in: this privacy notice; standalone notices we provide for specific products and processes; and through 'just in time' in-app notifications.

If you ask, we'll provide a copy of the personal data we hold about you. We can't give you personal data about other people, data linked to an ongoing criminal or fraud investigation, data linked to settlement negotiations with you, or communications with our legal advisers.

You can have incomplete or inaccurate personal data corrected. Before we update your file, we may need to check the accuracy of the new personal data you have provided.

You can ask us to delete your personal data if: there's no good reason for us to continue using it;

you gave consent and have now withdrawn it; you have objected to our use; we have used it unlawfully; or the law requires deletion. As a regulated financial services provider, we must keep certain data even after you ask us to delete it. We'll always let you know if we can't delete it.

You can tell us to stop using your personal data, including profiling you, for marketing purposes.

If our legal basis for using your personal data is 'legitimate interests' and you disagree with us using it, you can object. However, if there is an overriding reason why we need to use your personal data, we will not accept your request. If you object to data we need to provide our services, we may need to close your account.

You can ask us to suspend using your personal data if: you want us to investigate whether it's accurate; our use is unlawful but you don't want deletion; we no longer need it but you want us to hold it for a legal claim; or you have objected and we are checking whether we have an overriding reason to continue.

If we can, and are allowed to do so under regulatory requirements, we'll provide your personal data in a structured, commonly used, machine-readable format.

If you've given us consent to use your personal data, you can withdraw it at any time by changing your privacy settings in the relevant GSS app or sending an email to [email protected]. Please note, it will have been lawful for us to use the personal data up to the point you withdraw your permission.

If we make an automated decision about you that significantly affects you, you can ask us to carry out a manual review of this decision.

To exercise any of your rights set out in the previous section, you can send us an email at [email protected].

For security reasons, we can't deal with your request if we're not sure of your identity, so we may ask you for proof of ID.

If a third party exercises one of these rights on your behalf, we may need to ask for proof that they've been authorised to act on your behalf.

When you exercise one of your rights, or update your privacy settings in the GSS app, it may take us up to one month to respond or implement your changes.

GSS will usually not charge you a fee when you exercise your rights. However, we're allowed by law to charge a reasonable fee or refuse to act on your request if it is manifestly unfounded or excessive.

The table below explains which suppliers we normally share your personal data with:

We may share your personal data with our partners to:

[email protected]