Privacy Policy
Last update: April 06, 2024
This Privacy Policy describes our policies and procedures regarding collecting, using, and disclosing your information when you use the Service. It also informs you of your privacy rights and how the law protects you.
We use your personal information to provide and improve the Service. By using the Service, you consent to this Privacy Policy’s collection and use of information.
Interpretation and definitions
Interpretation
Words whose initial capital letters are capitalized have the meanings defined below. The following definitions will have the same meaning regardless of whether they appear singular or plural.
Definitions
For this Privacy Policy:
In providing the Services, the Company acts in the name and on behalf of the electronic money institution Sefide, EDE, S.L.U. («Sefide«), as Sefide’s authorized agent. Sefide is a company incorporated and existing under the laws of the Kingdom of Spain, with a registered office at Avenida de la Ciencia 2-3º, 18006, Granada, Spain, and Spanish Tax Identification Number B-93205474, which is registered in the Mercantile Registry of Granada, volume 1559, folio 143, page GR-46879. E-mail address: info@sefide.es.
More information about Sefide can be found at: https://sefide.com/.
Sefide is licensed by the Bank of Spain (Entity Code No. 6705) and operates under the supervision of the Bank of Spain, with an address at Calle de Alcalá, 48, 28014, Madrid, Spain.
In addition, in providing the Money Transfer Service, the Company acts for and on behalf of MoneyGram International, S.A. («MoneyGram«) as MoneyGram’s authorized agent. MoneyGram is a company incorporated and existing under the laws of Belgium, with a registered office at Rue Joseph Stevens 7, 1100, Brussels, Belgium.
More information about MoneyGram can be found at https://www.moneygram.com.
MoneyGram is licensed by the National Bank of Belgium (Entity Code No. 0671.690.653) and operates under the supervision of the National Bank of Belgium.
For the GDPR, Personal Data means any information relating to You, such as a name, an identification number, location data, online identifier, or one or more factors specific to physical, physiological, genetic, mental, economic, cultural, or social identity.
For purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes, or can be associated with You or can reasonably be linked, directly or indirectly, to You.
Under the GDPR, You may be referred to as the Data Subject or the User, as You are the individual using the Service.
The Application allows the User to access the services described in the Terms and Conditions (the «Services«). The Terms and Conditions governing the Services (the «Terms and Conditions»), of which this Policy forms a part, can be found at https://www.topii.es/terms_and_conditions.
Likewise, the creation and operation of the Electronic Money Account is governed by Sefide’s Electronic Money Account Opening Agreement, applying the personal data processing policy contained in the Electronic Money Agreement, which the User can consult here: https://sefide.com/politica-de-privacidad/.
The MoneyGram Money Transfer Terms of Service govern the Money Transfer Services and apply to the personal data processing policy contained in the Terms of Service, which the User can consult here: https://www.moneygram.com/intl/privacy-notice.
Collection and use of your personal data
Types of data collected
Personal data
When using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:
Usage Data
Usage Data is collected automatically when you use the Service.
Usage Data may include information such as the Internet Protocol address (e.g., IP address) of your device, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, the unique identifier of your mobile device, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.
Information collected during the use of the application
In order to register and create the User’s account (the «Account«) in the Application (a necessary requirement to access the Services), the Company will collect, through the corresponding form, specific personal data of the User (identification data, biometric data, contact data, passwords, cell phone number), the provision of which will be mandatory, as indicated in the different registration screens of the Application.
In order to Use the Services, the User must also provide the financial data related to the valid means of payment (the «Means of Payment«) associated with their Account, as well as, if applicable, other passwords or codes required for each specific transaction, or biometric data (facial recognition) to authorize transactions, as indicated on the different screens of the Application.
If the User fails to provide all mandatory data by this Privacy Policy (or if the User fails to pass the identity verification checks of the Application, or those that the Company may perform by the Terms and Conditions), the User will not be able to register on the Application and use the Services, as indicated above.
The Company will collect information on the data of transactions made using the Services, such as where they are made, when they are made, the amounts of the transactions, the Means of Payment used, the description of the transaction, the amount of the Incentive, etc.
The Company will also collect information about the User’s general use of the Application and the User’s activity within the Application, such as:
In general, the information collected referred to in this clause remains anonymous. It does not personally identify the User, nor is it stored in association with any other information that links it to the User. You can consult more details by accessing our Cookies Policy, which is included below.
However, if the User voluntarily enters additional information, or if the User checks the corresponding boxes allowing geolocation or the sending of own or third-party commercial communications, the corresponding information on the use of the Application will be associated with the rest of the personal data provided by the User and will be treated as personal data, for the processing that the Company will carry out by the purposes and legitimacy of the processing in question, as detailed below.
Once the Application is installed on a Device, the Company will automatically collect technical information about it, including the Device’s unique device identifier and IP address, as well as, if permitted by the User, the device’s geolocation data.
The information collected referred to in this clause remains anonymous, i.e., it does not personally identify the User, nor is it stored in association with any other information that links it to the User. You can consult more details by accessing our Cookies Policy, which is included below.
Notwithstanding the foregoing, if the User voluntarily enters additional information, the Device information will be associated with the other personal data provided by the User and treated as personal data for the processing that the Company will carry out by virtue of the purposes and legitimacy of the processing in question as detailed below (for example, in relation to geolocation data).
The User must take into account that, in case they do not allow the technical data of the Device to be treated as personal data (such as geolocation data), they may not be able to enjoy the Services with all their functionalities (for example, they will not be able to consult nearby Establishments available according to their location).
Use of your personal data
The Company may use Personal Data for the following purposes:
We may share your personal information in the following situations:
Messages and Communications
Topii is committed to maintaining the privacy and security of your communication. All messages sent through our application are protected to ensure that only you and the intended recipient can access the shared content. We have no ability to read or access the content of your messages.
To ensure reliable delivery of messages, including those containing attachments or communications regarding services such as remittance requests or transfers, we store messages securely on our servers. These are kept as long as necessary to ensure effective delivery, especially in cases where the receiving device may be temporarily offline.
In addition, we collect and store the minimum technical information necessary for the efficient operation of our services. This includes authentication identifiers, session tokens, and other data essential for message and service management. We strive to limit this information to the minimum that is strictly necessary to provide our services securely and efficiently.
Service Communications
As part of our services, Topii sends communications through messages that may include details about transactions performed, such as remittances or transfers. These communications are intended to keep you informed about the status of your requests and provide relevant information about the services you use.
Contact list
To make it easier for you to find your contacts on Topii and improve your user experience, our application may request access to your device’s address book. We use secure methods to process this information, ensuring the privacy of your contacts. This process is entirely optional and is carried out only with your explicit consent.
Retention of your personal data
The Company will retain Your Personal Data only for as long as necessary for the purposes set forth in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain Your Data to comply with applicable law), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except where this data is used to enhance the security or improve the functionality of Our Service or where We are legally required to retain this data for longer periods of time.
Transfer of your personal data
Your information, including Personal Data, is processed at the Company’s operating offices and at any other location where the parties involved in the processing are located. This means that this information may be transferred to and maintained on computers located outside your state, province, country, or other governmental jurisdiction where data protection laws may differ from those in your jurisdiction.
Your consent to this Privacy Policy, followed by your submission of such information, represents your agreement to such transfer.
The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data to an organization or country will take place unless there are adequate controls in place that include the security of your data and other personal information.
Delete your personal data.
You have the right to delete or request that we assist you in deleting the Personal Data we have collected about you.
Our Service may offer you the ability to delete certain information about yourself within the Service.
You may update, modify, or delete your information at any time by logging into your account if you have one and visiting the account settings section that allows you to manage your personal information. You may also contact us to request access to, correct, or delete any personal information you have provided to us.
Please note, however, that we may need to retain certain information when we have a legal obligation or a legal basis to do so.
Disclosure of your personal data
Commercial operations
If the company is involved in a merger, acquisition, or asset sale, your Personal Data may be transferred. We will notify you before your Personal Data is transferred and becomes subject to a different Privacy Policy.
Compliance with the law
In certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
Other legal requirements
The Company may disclose your Personal Data in the good faith belief that such action is necessary to:
Security of your personal data
The security of your Personal Data is important to us, but please remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Detailed information on the processing of your personal data
Service Providers that We use may have access to Your Personal Data. These third-party providers collect, store, use, process, and transfer information about Your activity on Our Service in accordance with their Privacy Policies.
Analytics
We may use third-party service providers to monitor and analyze the use of our Service.
Google Analytics is a web analytics service provided by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the data collected to contextualize and personalize the advertisements of its own advertising network.
You can turn off certain Google Analytics features through your mobile device settings, such as your device’s advertising settings, or by following the instructions provided by Google in its Privacy Policy: https://policies.google.com/privacy.
For more information about Google’s privacy practices, please visit Google’s privacy and terms webpage: https://policies.google.com/privacy.
Firebase is an analytics service provided by Google Inc.
You can opt out of certain Firebase features through your mobile device settings, such as your device’s advertising settings, or by following the instructions provided by Google in its Privacy Policy: https://policies.google.com/privacy.
We also recommend that you consult Google’s policy for the protection of your data: https://support.google.com/analytics/answer/6004245.
For more information about the type of information Firebase collects, please visit the How Google uses data when you use our partners’ sites or apps web page: https://policies.google.com/technologies/partner-sites.
Its privacy policy is available at https://emma.io/politica-de-privacidad/.
E-mail marketing
We may use your personal data to contact you and send you newsletters, promotional or marketing materials, and other information that may be of interest to you. You may opt out of receiving any or all of these communications from us by following the unsubscribe link or instructions contained in any email we send you or by contacting us.
We may use email marketing service providers to manage and send emails to you.
Mailchimp is an email marketing service provided by The Rocket Science Group LLC.
For more information about Mailchimp’s privacy practices, please visit their privacy policy: https://mailchimp.com/legal/privacy/.
Its privacy policy is available at https://emma.io/politica-de-privacidad/.
Usage, performance, and miscellaneous
We may use third-party service providers to maintain and improve our Service.
FreshDesk is a customer service software. The service is operated by Freshworks, Inc.
The FreshDesk service may collect information from your device.
The information collected by FreshDesk is maintained in accordance with its Privacy Policy: https://www.freshworks.com/privacy/.
GDPR Privacy
Legal basis for the processing of personal data under the GDPR
We may process Personal Data under the following conditions:
In any case, the Company will be happy to assist in clarifying the specific legal basis that applies to the processing, and in particular, whether the provision of Personal Data is a legal or contractual requirement or a necessary requirement to enter into a contract.
Your rights under the GDPR
The Company undertakes to respect the confidentiality of your Personal Data and to guarantee you the exercise of your rights.
You have the right, under this Privacy Policy, and by law if you are located within the EU, to:
Exercising your GDPR data protection rights
You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will do our best to respond to you as soon as possible.
You have the right to lodge a complaint with a data protection authority about our collection and use of your personal data. For more information, if you are located in the European Economic Area (EEA), please get in touch with your local data protection authority in the EEA.
CCPA/CPRA Confidentiality Notice
This privacy notice section for California residents supplements the information contained in Our Privacy Policy and applies exclusively to all visitors, users, and other persons residing in the State of California.
Categories of personal data collected
We collect information that identifies, relates to, describes, references, can be associated with, or could reasonably be linked, directly or indirectly, to a particular Consumer or Device. The following is a list of categories of personal information that we may collect or may have collected from California residents in the past twelve (12) months.
Please note that the categories and examples listed below are as defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information have, in fact, been collected by Us, but it reflects Our good faith belief, to the best of Our knowledge, that some of that applicable category information can be and may have been collected. For example, specific categories of personal information would only be collected if You provided such personal information directly to Us.
Examples: A real name, alias, mailing address, unique personal identifier, online identifier, Internet protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
Picked up: Yes.
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, work history, bank account number, credit card number, debit card number or any other financial information, medical information or health insurance information. Some personal information in this category may overlap with other categories.
Picked up: Yes.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including family genetic information).
Collections: No.
Examples: Records and history of products or services purchased or considered.
Collections: No.
Examples: Genetic, physiological, behavioral and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, for example, fingerprints, facial and voice prints, iris or retinal scans, keystroke, gait or other physical patterns, and sleep, health or exercise data.
Collections: No.
Examples: Interaction with our Service or advertising.
Picked up: Yes.
Examples: Approximate physical location.
Picked up: Yes.
Examples: Sound, electronic, visual, visual, thermal, olfactory, or similar information.
Collections: No.
Examples: Current or past work history or performance evaluations.
Collections: No.
Examples: Educational records directly related to a student maintained by an educational institution or a party acting on its behalf, such as grades, transcripts, class rosters, student schedules, student identification codes, student financial information, or student disciplinary records.
Collections: No.
Examples: A profile that reflects a person’s preferences, characteristics, psychological tendencies, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collections: No.
For example, Account login and password information and geolocation data.
Picked up: Yes.
Under the CCPA/CPRA, personal information does not include:
Sources of personal information
We obtain the categories of personal information listed above from the following categories of sources:
Use of personal information
We may use or disclose the personal information we collect for «business purposes» or «commercial purposes» (as defined in the CCPA/CPRA), which may include the following examples:
Please note that the above examples are illustrative and are not intended to be exhaustive. For more details on how we use this information, please refer to the section «Use of your personal data.»
If we decide to collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes, we will update this Privacy Policy.
Disclosure of personal information
We may use or disclose, and may have used or disclosed in the last twelve (12) months, the following categories of personal information for business or marketing purposes:
Please note that the categories listed above are as defined in the CCPA/CPRA. This does not mean that all instances of that category of personal information have, in fact, been disclosed, but it reflects our good faith belief, to the best of our knowledge, that some of that information in the applicable category can be and may have been disclosed.
When we disclose personal information for business or commercial purposes, we enter into a contract describing the purpose and requiring the recipient to maintain the confidentiality of the personal information and not to use it for any purpose other than the performance of the contract.
Sharing personal information
We may share, and have shared in the last twelve (12) months, Your personal information identified in the categories above with the following categories of third parties:
Sale of personal information
As defined in the CCPA/CPRA, «sell» and «sale» mean to sell, rent, lease, assign, disclose, divulge, disclose, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means, a Consumer’s personal information by the Company to a third party for monetary consideration. This means that we may have received some benefit in exchange for sharing personal information, but not necessarily an economic benefit.
We do not sell personal information as the term «sell» is commonly understood. We do allow service providers to use your personal information for the business purposes described in our Privacy Policy for activities such as advertising, marketing, and analytics, and these may be considered a sale under the CCPA/CPRA.
We may sell and have sold in the last twelve (12) months the following categories of personal information:
Please note that the categories listed above are as defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were, in fact, sold, but it reflects our good faith belief, to the best of our knowledge, that some of that information in the applicable category can be and may have been shared in exchange for value.
Sale of personal data of children under 16 years of age
We do not knowingly collect personal information from children under the age of 16 through our Service, although some third-party websites to which we link may do so. These third-party websites have their own terms of use and privacy policies, so we encourage parents and legal guardians to monitor their children’s use of the Internet and instruct them never to provide information on other websites without your permission.
We do not sell the personal information of consumers we know are under the age of 16 unless we receive affirmative authorization (the «right to opt-out») from the consumer who is between the ages of 13 and 16 or from the parent or guardian of a consumer under the age of 13. Consumers who agree to the sale of personal information may object to future sales at any time. To exercise the right to opt out, you (or your authorized representative) may send us a request by contacting us.
If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please get in touch with us with sufficient details to enable us to delete such information.
Your rights under CCPA/CPRA
The CCPA/CPRA gives California residents specific rights regarding their personal information. If you are a California resident, you have the following rights:
Exercising your CCPA/CPRA Data Protection Rights
See the «Do Not Sell My Personal Information» section and the «Limit the Use or Disclosure of My Sensitive Personal Information» section for more information on how to opt-out and limit the use of the sensitive information collected.
In addition, to exercise any of your rights under the CCPA/CPRA, and if you reside in California, you may contact us:
Only you or a person registered with the California Secretary of State whom you authorize to act on your behalf may make a verifiable request regarding your personal information.
Your application must:
We cannot respond to your request or provide you with the requested information if we cannot:
We will disclose and provide the requested information free of charge within 45 days of receipt of your verifiable request. The time period for providing the requested information may be extended once for an additional 45 days when reasonably necessary and upon notice.
Any disclosures we provide will only cover the 12-month period prior to receipt of the verifiable request.
For data portability requests, we will select a format for providing your personal information that is readily usable and allows you to transmit the information from one entity to another without hindrance.
Please do not sell my personal data.
As defined in the CCPA/CPRA, «sell» and «sale» mean to sell, rent, lease, assign, disclose, divulge, disclose, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means, a Consumer’s personal information by the Company to a third party for monetary consideration. This means that we may have received some benefit in exchange for sharing personal information, but not necessarily an economic benefit.
We do not sell personal information as the term «sell» is commonly understood. We do allow service providers to use your personal information for the business purposes described in our Privacy Policy for activities such as advertising, marketing, and analytics, and these may be considered a sale under the CCPA/CPRA.
You have the right to opt out of the sale of your personal information. Once we receive and confirm a verifiable request from you, we will stop selling your personal information. To exercise this right, please get in touch with us.
Service Providers with whom we partner (e.g., our analytics or advertising partners) may use technology in the Service that sells personal information as defined in the CCPA/CPRA. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as described in the CCPA/CPRA, you may do so by following the instructions below.
Please note that any opt-out is specific to the browser you use. You may have to opt out of all browsers you use.
Website
If applicable, click on the «Privacy Preferences», «Update Privacy Preferences» or «Do Not Sell My Personal Data» buttons on the Service to review your privacy preferences and opt-out of cookies and other technologies that we may use. Please note that you will need to opt-out from each browser you use to access the Service.
In addition, you may opt out of receiving personalized advertisements served by our Service Providers by following our instructions presented in the Service:
Opting out will place a cookie on your computer that is unique to the browser you use to opt-out. If you change browsers or delete the cookies stored by your browser, you will have to opt out again.
Mobile devices
Your mobile device may offer you the ability to opt out of the use of information about the applications you use in order to provide you with advertisements tailored to your interests:
You can also stop the collection of location information from your mobile device by changing your mobile device preferences.
To limit the use or disclosure of my sensitive personal data
If you reside in California, you have the right to limit the use and disclosure of your sensitive personal information to the use necessary to provide the services or supply the goods reasonably expected by an average consumer requesting such services or goods.
We collect, use, and disclose sensitive personal information as necessary to provide the Service. For more information about how we use your personal information, please see the «Use of Your Personal Information» section or contact us.
Do Not Track» Policy required by the California Online Privacy Protection Act (CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third-party websites track your browsing activities. If you visit these websites, you can set your browser preferences to inform the websites that you do not want to be tracked. You can turn DNT on or off by visiting your browser’s preferences or settings page.
Your California Privacy Rights (California Shine the Light Act)
Pursuant to California Civil Code Section 1798 (California’s Shine the Light law), California residents who have an established business relationship with us may request information once a year about the disclosure of their Personal Information to third parties for their direct marketing purposes.
If you would like to request more information under California’s Shine the Light law, and if you are a California resident, you may contact us using the contact information provided below.
Privacy Rights of Minor Users in California (California Business and Professions Code Section 22581)
California Business and Professions Code section 22581 allows California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have posted.
To request deletion of such data, and if you are a California resident, you may contact us using the contact information provided below, and include the e-mail address associated with your account.
Please note that your request does not guarantee complete or comprehensive removal of content or information posted online and that removal may not be permitted or required by law in certain circumstances.
Children’s Privacy
Our Service is not directed to children under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13. If you are a parent or guardian and you know that your child has provided us with Personal Data, please get in touch with us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we will take steps to delete that information from our servers.
If we need to rely on consent as the legal basis for processing your information and your country requires parental consent, we may require parental consent before collecting and using that information.
Links to other websites
Our Service may contain links to other websites that we do not operate. If you click on a third-party link, you will be directed to that third-party’s site. We strongly encourage you to review the Privacy Policy of each site you visit.
We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Changes to this privacy policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will notify you by email and by a prominent notice on our Service before the change becomes effective, and we will update the «Last Updated» date at the top of this Privacy Policy.
We encourage you to review this Privacy Policy for changes periodically. Changes to this Privacy Policy will be effective when posted on this page.
Contact us
If you have any questions about this Privacy Policy, you may contact us: