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Welcome to MoneyPoolsCash

Updates:

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Licenses and Eligibility

Global coverage of 180+ countries and unprecedented 48 US states

Buy & sell cryptocurrencies no matter where you are

FinCEN Department of the Treasury, United States of America

Money Service Business Registration: 31000185271796


  • State of Wyoming: https://wyobiz.wyo.gov/Business/FilingDetails.aspx?eFNum=060223238161223147104178157196002190033034104020
  • US Treasury FinCen Licensed Money Service Business (MSB): MSB Registration Number: 31000185271796 – https://www.fincen.gov/msb-registrant-search

Company Name: MoneyPools Technology USA, Inc.
Address:30 N Gould Street, Suite 4000
City: Sheridan State: Wyoming, 82801 Country: United States

MoneyPools Technology UK Limited
Company #14520768 – 128 City Road
London, EC1V 2NX
UNITED KINGDOM

MoneyPools Technology RCA LIMITED – RCA BP 120 8ème arrondissement de Bangui rue Chicago. Bangui, Republic Central African Financial Services Numéro de licence: 17/MICSP/DIR.CAB/SGCICSFCCVJLH/SP22

 

Cryptocurrencies User Agreement

Last updated: January 3, 2023

This User Agreement (this “Agreement”) is among you, including MoneyPools Technology USA Inc. and MoneyPools Technology UK (“MPT”). MPT is registered in United States as a Money Business Service financial exchanger and a virtual currencies exchange operator. Unless otherwise stated herein, references to “MoneyPoolsCash”, “we”,

“us” or “our” in this Agreement will refer collectively to MoneyPoolsCash Inc., MPT, their respective direct and indirect subsidiaries and affiliates and any entities under common control with MoneyPoolsCash or MPT. In this Agreement, “you,” “your” or “User” means any person or entity using theMoneyPoolsCash Site (as defined below) or our Services (as defined below) and the person to whom MoneyPoolsCash Inc. and MPT enters into this Agreement.

This Agreement governs your use of the services provided by MoneyPoolsCash or MPT (the “Services”). By using any of the Services or signing up to use an account through www.MoneyPoolsCash.com

(the “Website”) or by accessing or using any of our associated websites (including, without limitation, the technology and the platform integrated therein), APIs and/or any and all related applications (collectively, the “Other Sites” together with the Website, the “MoneyPoolsCash Site”), you agree that you have read, understood and accept all of the terms and conditions contained in this Agreement, as well as all of the terms and conditions of our Privacy Policy which is hereby incorporated by reference and forms part of this Agreement. You should read this Agreement and the Privacy Policy carefully and in their entirety. This Agreement is effective as of the earliest date and time at which you use any of the Services or the MoneyPoolsCash Site.

If you do not agree to be bound by the terms and conditions of this Agreement or the Privacy Policy, you must not use or access the MoneyPoolsCash Site or use or access any of MoneyPoolsCash’ products or Services. Any use of or access to the MoneyPoolsCash Site or our Services means you consent to and agree to the terms and conditions of this Agreement and the Privacy Policy. If you do not read and accept this Agreement and our Privacy Policy in their entirety, you should not use or continue using the MoneyPoolsCash Site or our Services. No partnership, joint venture, employee-employer, joint associates for profit, agency or franchiser-franchisee relationship is intended or created by this Agreement. We do not endorse or recommend any particular virtual currency, digital asset or transaction. You acknowledge and agree that: (a) we are not acting as your bank, broker, intermediary, agent, or advisor or in any fiduciary capacity and nothing in this

Agreement shall be deemed or is intended to be deemed, nor shall it cause, any fiduciary or advisory relationship between you and us to exist; and (b) no communication or information provided to you by us including, without limitation, content on the MoneyPoolsCash Site shall be considered or construed as transaction, investment, tax, or any other form of advice. Independent advice should be sought where applicable and appropriate. You acknowledge and agree that the decision to use our Services and all transaction decisions are made solely by you and we bear no responsibility or liability for the outcome of your decisions.

CAUTION: The risk of loss in using and/or holding virtual currencies can be substantial. Therefore, you should carefully evaluate whether you can bear the risk of using and/or holding virtual currencies and whether it is suitable for you. You acknowledge and agree that you shall access and use the Services at your own risk.

You accept and understand that this Agreement may be modified or updated by us from time to time in our sole discretion. We will provide you with notice of such changes by posting the revised agreement on the Website and/or providing a copy to you. The amended Agreement will be deemed effective immediately upon posting on the Website. Your continued use of the Site and/or our Services constitutes your agreement to be bound by the revised agreement. If you do not agree with any such modification, your sole and exclusive remedy is to terminate your use of the Services and close your account.

2. Certain Services may be subject to additional terms and conditions specified by us from time to time, and your use of such Services is subject to those additional terms and conditions, which are hereby incorporated into this Agreement by reference.

If you have questions about this Agreement or our Services, please also consult the FAQ section of the

Website or contact us at support@MoneyPoolsCash.com.

1. Eligibility. You represent and warrant that you: (a) are of legal age to form a binding contract (at least 18 years old) and have full power, capacity and authority to enter into legally binding contracts;

(b) have not previously been suspended or removed from using our Services; (c) have full power, capacity and authority to enter into this Agreement and in doing so will not violate any other agreement to which you are a party; (d) are not in non-compliance with this Agreement or the Privacy Policy; (e) are not located in, under the control of, or a national or resident of any of the Restricted Jurisdictions; (f) are not on any trade or economic sanctions list, such as the UN Security Council Sanctions list or the Office of Foreign Assets Control (OFAC) list or in breach of applicable law; (g) will not use our Services if any applicable laws in your country prohibit you from doing so; and (h) meet all eligibility requirements for the Services at the time of using any Services.

The MoneyPoolsCash Site and our Services are also not available to persons who, in our sole opinion, present an unacceptable level of credit, legal or reputational risk to us, our Services or to others. Any use of the MoneyPoolsCash Site or our Services by anyone who does not meet our eligibility requirements is strictly prohibited and in violation of this Agreement. MoneyPoolsCash may require, on an ongoing basis, that you demonstrate to us that you continue to meet our eligibility requirements. Our decisions with respect to eligibility are final.

In order to use the MoneyPoolsCash Site and our Services, you must register for a personal or merchant account (an “Account”) and accept the terms of this Agreement and our Privacy Policy. We may, in our sole discretion, refuse to open an Account for you or limit the number of Accounts that you may hold. When creating your Account, you must provide accurate and complete information, and you must keep this information up to date. You may never use another User’s account or take virtual currency or funds from another User’s account without permission. If you open an Account on behalf of an organization, or other entity, then (i) “you” includes you and that entity, and (ii) you represent and warrant that you are an authorized representative of the organization or entity with the authority to bind the organization or entity to this Agreement, and that you agree to this Agreement on the entity’s or organization’s behalf.

2. Our Services.

2.1 Virtual Currency Services. MPT is registered as a deposit virtual currencies wallet operator and a virtual currencies exchange operator and its virtual currency Services or the services of its partners enable you to store, track, transfer, manage and convert your balances (collectively,

“Virtual Currency Transactions”) of certain supported virtual currencies in virtual currency wallets hosted by MPT. We will process Virtual Currency Transactions in accordance with the instructions we receive from you. When you request that MPT receive or deposit virtual currency into your Account from another one of your accounts or wallets or request that MPT transfer virtual currency to another wallet or account from your Account, you authorize MPT to execute such transaction via the Services. Prior to submitting instructions to us, you should verify all transaction information. We do not guarantee the identity of any recipient, user, requestee or other party. You cannot reverse a Virtual Currency Transaction once it has been broadcast to the relevant virtual currency network. If a Virtual Currency Transaction has not yet been confirmed on the virtual currency network, virtual currency associated with such transaction will be designated as pending and will not be included in your virtual currency wallet balance or be

3. Available to conduct Virtual Currency Transactions. You cannot reverse or change any Virtual

Currency Transaction marked as complete or pending. You must comply with all applicable laws, regulations, licensing requirements and third party rights (including, without limitation, data privacy laws) in your use of the Services. We may refuse to process or cancel any pending Virtual Currency Transaction as required by law or any court or other authority to which we are subject in any jurisdiction. We further reserve the right to delay any Virtual Currency Transaction if we perceive a risk of fraud or illegal activity. We also have the right to refuse to process or cancel any Virtual Currency Transaction due to technological issues with the blockchain software, our own software, or for other technological reasons.

Our Services are available only in connection with those virtual currencies that we support which

may change from time to time. A full list of the virtual currencies we currently support can be found on the Website at Supported Coins. You will not use your Account or your virtual currency wallet to store, send, request, or receive virtual currencies in any form that we do not support (we will use reasonable efforts to help you move or sell virtual currency that we no longer support). We assume no responsibility or liability in connection with any attempt to use your Account or virtual currency wallet for virtual currencies that we do not support.

You agree that you will not receive interest or other earnings in your Account or virtual currency wallet from the use of our Services except through your own Virtual Currency Transactions and

MoneyPoolsCash has no responsibility or liability to you for Virtual Currency Transactions conducted by you or conducted by us in accordance with your instructions. You are prohibited from using our Services for any illegal or fraudulent purposes or for the purpose of consummating transactions for any other parties.

All virtual currency or digital assets received by MPT into your Account (“Received Assets”) are custodial assets held by MPT for your benefit, as described in further detail below:

(a) Ownership. Title to Received Assets shall at all times remain with you and shall not transfer to MPT, except as provided herein. As the owner of the Received Assets in your Account, you bear all risk of loss of such Received Assets and we have no responsibility or liability with respect to the value of the virtual currency or digital assets in your Account. We are under no obligation to issue any replacement virtual currency, digital assets or funds in the event that any virtual currency, digital assets, funds or password are lost, stolen, malfunctioning, destroyed or otherwise inaccessible. None of the Received Assets in your Account are the property of MPT. MPT does not represent or treat Received Assets in your Account as belonging to MPT. Except as required by a facially valid court order, or except as provided herein, MPT will not sell, transfer, loan, hypothecate or otherwise alienate Received Assets in your Account unless instructed by you or as otherwise authorized by this Agreement. For the avoidance of doubt, MPT makes no warranty that virtual currency or digital assets in your Account (including Received Assets) are held by you free and clear of any security interest or other lien or encumbrance.

(b) Control. You control the Received Assets. At any time, subject to outages, downtime, and other applicable policies or the other terms of this Agreement, you may withdraw your Received Assets by sending them to a different blockchain address controlled by you or a

third party.

(c) Wallets. Unless otherwise instructed and agreed to by MPT, your virtual currency

will be held in a general multi-client wallet managed and overseen by MPT and its accounting procedures or your virtual currency may be held in a separate individual wallet if instructed by you and when available as part of MPT’ Services in

MPT sole discretion.

2.2 Internet Provider. MoneyPoolsCash acts as a Service provider by creating, hosting, maintaining and providing our Services to you via the Internet. We cannot ensure that a buyer or a seller you are dealing with will actually complete the Virtual Currency Transaction and all risk of a Virtual Currency Transaction remains with you. We do not guarantee continuous, uninterrupted or secure access to our Services or the MoneyPoolsCash Site and we make no representations or warranties regarding the amount of time needed to complete Virtual Currency Transaction processing which is dependent upon many factors outside of our control. Access to Services may become degraded or unavailable during times of significant volatility or volume.

2.3 Underlying Protocols. We do not own, control, operate or maintain the underlying software protocols which govern the operation of the virtual currencies supported by us. In general, the underlying protocols are open source software and anyone can use, copy, modify, and distribute them. By using our Services, you acknowledge, agree and accept the risk (i) that we are not responsible for the operation of the underlying protocols and any changes to such protocols and we make no guarantee of their security, functionality or availability; and (ii) that the underlying protocols are subject to sudden changes in operating rules, which may, amongst other things, materially affect the value, function, name of the virtual currency and/or our ability to support certain virtual currencies and we are not liable for any loss of value you may experience as a result of such changes in operating rules. In the event of a fork in a virtual currency, you agree that we may temporarily suspend our Services (with or without advance notice to you) and that we may, in our sole discretion, decide whether or not to support (or cease supporting) either branch of the forked protocol entirely. You also agree that in the event you send a Virtual Currency Transaction at the time of a virtual currency fork, we will only honor the originally-intended Virtual Currency

Transaction that you sent. You acknowledge and agree that we assume absolutely no responsibility or liability whatsoever in respect of an unsupported branch of a forked protocol. 2.4 Identity Verification. During registration of your Account and at any other time you have an Account, you agree to provide us with the information we request for the purposes of ongoing due diligence, identity verification and the detection of money laundering, terrorist financing, fraud, or any other financial crime and permit us to keep a record of such information. You will maintain and promptly update your Account information. You agree and represent and warrant that all information you provide us at any time will not be false, inaccurate or misleading. You will need to complete certain verification procedures before you are permitted to use our Services. Your access to our Services and the limits that apply to your use of our Services, may be altered, suspended or terminated as a result of information collected about you on an ongoing basis and/or your failure to provide us with information we request on a timely basis. You authorize us to make inquiries, whether directly or through third parties, that we consider necessary to verify your identity or protect you and/or us against fraud or other financial crime, and to take action we reasonably deem necessary based on the results of such inquiries. When we carry out these inquiries, you acknowledge and agree that your personal information may be disclosed to fraud prevention or financial crime agencies and that these agencies may respond to our inquiries in full.

You are solely responsible and liable for the activity that occurs in relation to your Account and for maintaining the security of your Account by protecting your password and restricting access to your Account. You accept all risks of any authorized or unauthorized access to your Account, to the maximum extent permitted by law. You are required to keep your Account password secure. We recommend that you use “strong” passwords (passwords that use a combination of upper and lower case letters, numbers and symbols) with your Account. You must notify us immediately of any breach of security or unauthorized use of your Account by emailing us at

support@MoneyPoolsCash.com. We will not be responsible or liable for any damages, liability or losses caused by any unauthorized use of your Account.

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You may control your User profile and how you interact with our Services by changing the settings in your Account settings page. By providing us with your email address, you consent to our using such email address to send you Service-related notices, including any notices required by law, in lieu of communication by postal mail. We may also use your email address to send you other messages, such as changes to features of our Services. If you do not want to receive such email messages, you may opt out by clicking “unsubscribe”, or something similar in the email message. Opting out may prevent you from receiving email messages regarding updates, improvements, or

offers.

2.5 No Warranty. THE MONEYPOOLSCASH SITE, ALL INFORMATION PROVIDED THROUGH THE MONEYPOOLSCASH SITE AND OUR PRODUCTS AND SERVICES ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS. EACH OF US AND OUR RESPECTIVE PAST, PRESENT AND FUTURE EMPLOYEES, OFFICERS, DIRECTORS, ADVISORS, CONTRACTORS, CONSULTANTS, LICENSORS,

EQUITY HOLDERS, MEMBERS, PARTNERS, SHAREHOLDERS, SUPPLIERS, MANAGERS, VENDORS, SERVICE PROVIDERS, PARENT COMPANIES, SUBSIDIARIES, AFFILIATES, AGENTS, REPRESENTATIVES, PREDECESSORS, SUCCESSORS AND ASSIGNS (INDIVIDUALLY, A “MONEYPOOLSCASH PARTY” AND COLLECTIVELY, THE “MONEYPOOLSCASH PARTIES”) EXPRESSLY DISCLAIM, AND YOU WAIVE, ALL WARRANTIES, WHETHER EXPRESS, IMPLIED OR STATUTORY, INCLUDING, WITHOUT LIMITATION, IMPLIED WARRANTIES OF TITLE, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. No information, whether oral or written, obtained by you from us or through use of the MoneyPoolsCash Site or our Services will create any warranty not expressly stated herein. Without limiting the foregoing, the MoneyPoolsCash Parties do not warrant that our Services will meet your requirements; the content on the MoneyPoolsCash Site is accurate, reliable or correct; that our Services will be available at any particular time or location, uninterrupted, error-free or secure; that any defects or errors will be corrected; or that the MoneyPoolsCash Site is free of viruses or other harmful components. Use of the MoneyPoolsCash Site and our Services are at entirely your own risk and any content downloaded or otherwise obtained through the use of the MoneyPoolsCash

Site or our Services is downloaded at your own risk.

The materials and related graphics on the MoneyPoolsCash Site could include technical inaccuracies or typographical errors. Accordingly, you should verify all information before relying on it, and all decisions based on information contained on the MoneyPoolsCash Site are your sole responsibility and we shall have no liability for such decisions. Changes are periodically added to the information contained on the MoneyPoolsCash Site. The MoneyPoolsCash Parties may make improvements and/or changes to the MoneyPoolsCash Site, our products and Services and/or the materials described on the MoneyPoolsCash Site at any time. We do or may offer features or services through third parties. We have no control over and do not warrant, endorse, guarantee, or assume responsibility or liability for any product or service advertised or offered by a third party through the MoneyPoolsCash Site or any hyperlinked website or service, and we will not in any way monitor or be a party to any transaction between you and any third-party. We are not responsible or liable for ensuring that a third party you transact with will complete the transaction or is authorized to do so. You use third party services at your own risk and you are solely responsible for reviewing and understanding the implications of using the services of such third parties.

2.6 Limitation of Liability. To the maximum extent permitted by applicable law, in no event shall any of the MoneyPoolsCash Parties be liable for any indirect, punitive, incidental, special, consequential or exemplary damages, including, without limitation, damages for loss of business revenues, loss of profits, goodwill, use, data or other intangible losses, arising out of or relating to: (a) the use of, or inability to use, the MoneyPoolsCash Site or our Services; (b) any information provided by us or available from the MoneyPoolsCash Site; (c) any conduct or content of any other User of our Services

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or third party; or (d) the failure to receive in any way the transmission of any data, content, virtual currency, funds or property from you. Furthermore and without limiting the generality of the foregoing, under no circumstances will any MoneyPoolsCash Party be responsible for any liability, claim, proceeding, damage, loss, expense or injury resulting from hacking, tampering or other unauthorized access or use of our Services or your Account or the information, virtual currency or funds contained therein. To the maximum extent permitted by applicable law, none of the MoneyPoolsCash Parties shall be responsible or liable for any: (a) errors, mistakes, omissions or inaccuracies of information or content provided by us or on the MoneyPoolsCash Site; (b) loss, liability, cost, expense or damage of any nature whatsoever suffered or incurred arising out of or in connection with your access to or use of the MoneyPoolsCash Site, any of its content or our products or Services; (c) unauthorized access to or use of our secure servers and/or any and all personal information stored therein; (d) fault, delays, interruptions or lack of availability of the MoneyPoolsCash Site or any of our Services or products provided through the MoneyPoolsCash Site; (e) bugs, viruses, trojan horses, or the like that may be transmitted to or through our Services by any User or any third party; (f) errors or omissions in any content or for any loss or damage incurred as a result of the use of any content posted, emailed, transmitted, or otherwise made available through the MoneyPoolsCash Site or our Services; and/or (g) action of other Users, User Content (as defined below) or the defamatory, offensive, or illegal conduct of any third party. To the maximum extent permitted by applicable law, in no event shall the MoneyPoolsCash Parties be liable to you for any claims, proceedings, liabilities, obligations, expenses, damages, losses or costs in an amount exceeding the amount of fees paid by you to MoneyPoolsCash for the applicable Services for the 12 months preceding the date of any claim giving rise to such liability or one hundred U.S. dollars (USD $100.00), whichever is greater. This limitation of liability section applies whether the alleged liability is based on contract, tort, negligence, strict liability, or any other basis, even if a MoneyPoolsCash Party has been advised of the possibility of such damage. The foregoing limitation of liability shall apply to the fullest extent permitted by law in the applicable jurisdiction. Some jurisdictions do not allow the exclusion of certain warranties or the limitation or exclusion of liability for incidental or consequential damages. Accordingly, some of the limitations of this section may not apply to you.

2.7 Indemnification. You agree to defend, indemnify and hold harmless each MoneyPoolsCash Party from and against any and all claims, proceedings, damages, obligations, losses, liabilities, costs or debt, and expenses (including but not limited to attorney’s fees) arising from: (a) your use of and access to the MoneyPoolsCash Site and our Services, including, without limitation, any data, virtual currency or content transmitted or received by you; (b) your violation of any term or condition of this Agreement, including without limitation, your breach of any of the representations and warranties contained herein; (c) your violation of any third-party right, including, without limitation, any right of privacy or Intellectual Property Rights (as defined below); (d) your violation of any applicable law, rule or regulation; (e) your User Content or any content that is submitted via your Account including, without limitation, misleading, false, or inaccurate information; (f) your fraudulent behaviour, willful misconduct or gross negligence; or (g) any other party’s access and use of your Account or our Services with your unique username, password or other appropriate security code. If you are obligated to indemnify us, we will have the right, in our sole discretion, to control any action or proceeding and determine whether we wish to settle it. In such case, you will share the costs of our expenses.

 

3.0 Fees and Referrals.

3.1 Fees. A full list of our fees for traditional payment processing and virtual currency wallet services can be found at Fees/Pricing on the Website, in this Agreement or in a separate fee schedule provided by us, which we may change from time to time and which shall form part of this Agreement.

Consumers

End User Privacy Policy

Effective Date: February 20, 2023

Privacy and security are very important to us at MPT. This End User Privacy Policy (“Policy”) is meant to help you (the “end user”) understand how we at MPT collect, use, and share your data when you use MPT products or services - for example, when you use MPT Portal, or when you use MPT to connect and share your data to power the applications (“apps”) you use. These apps, which offer many consumer services and products such as helping you save for retirement, manage your spending, streamline credit applications, or transfer money, are built and provided by our business customers (we’ll call them “developers” here), and powered by MPT.

This Policy applies to MPT Inc. and its affiliates and subsidiaries, including MoneyPools Technology USA  and MoneyPools Technology UK  (collectively, “MPT,” “we,” “our,” and “us”). (Please see the “Contacting MPT” section below for which of these entities is responsible for processing your data.) You should read this Policy carefully, it contains important information about your privacy rights and choices.

First, Some Background

A quick note about MPT

Our mission at MPT is to unlock financial freedom for everyone. By delivering access to high-quality, usable financial account data that we’ve translated and standardized, we enable developers to focus on building experiences that benefit you.

About this Policy

Our goal with this Policy is to provide a simple and straightforward explanation of what data MPT collects from and about you and how we use and share that information. We value transparency and want to provide you with a clear and concise description of how we treat your data.

This Policy does not cover what developers of the apps you use do with your data. You should review the privacy policies or terms of service for those apps for information about their practices. This Policy also does not cover data we collect through our websites or when you interact with MPT outside of using our product or services, such as emailing MPT directly. Please see our All Audience Privacy Statement and Cookie Policy for more information.

MPT’s services are not directed to individuals under 18 and we do not knowingly collect data relating to children.

Our Data Practices

MPT is committed to providing end users with meaningful control over their data. This section describes MPT’s data practices relating to our processing of information about you. We also provide summaries of our practices organized by category of information collected and by product at the end of this Policy in the Summaries of Processing Activities section.

Data We Collect and Categories of Sources

As explained in greater detail below, the data we collect, use, and share depends on the MPT products and services that you, and or the app you have connected to, use. Depending on which of MPT’s products or services you or the developer you are connecting to use, MPT may collect the following:

  • Data you provide to us;
  • Data from financial partners when you connect your financial account;
  • Data from the electronic device you use to connect;
  • Data from the developer of the app you have connected to; and
  • Data from other sources, including service providers and identity verification services.

Data you provide to us. When you use MPT’s products or services, like when you connect your financial accounts (like your bank accounts) to a developer’s app through MPT, we may collect the following data from you:

  • identifiers like name, email address, and phone number;
  • login data when required by the provider of your account, like your username and password, account and routing number, or a security token.
  • when needed, data to help verify your identity and connect your accounts, including your Social Security number, date of birth, security questions and answers, and one-time password (OTP).

When you provide this data, you also give MPT permission and authority to act on your behalf to access and transmit your data to and from the relevant bank or financial service provider that holds your financial account (we’ll call them “financial partners” in this Policy).

Data we collect from financial partners when you connect your financial account. Depending on which MPT products you or the developer of your app use, as well as what and how information is made available by your financial product and service providers, we may collect the following data from financial partners when you connect your financial accounts with or through MPT:

  • Account data, including financial institution name, account name, account type, account ownership, branch number, IBAN, BIC, account number, routing number, and sort code;
  • Data about an account balance, including current and available balance;
  • Data about credit accounts, including due dates, balances owed, payment amounts and dates, transaction history, credit limit, repayment status, and interest rate;
  • Data about loan accounts, including due dates, repayment status, balances, payment amounts and dates, interest rate, guarantor, loan type, payment plan, and terms;
  • Data about investment accounts, including transaction information, type of asset, identifying details about the asset, quantity, price, fees, and cost basis;
  • Identifiers and data about the account owner(s), including name, email address, phone number, date of birth, and address information;
  • Data about account transactions, including amount, date, payee, type, quantity, price, location, involved securities, and a description of the transaction; and/or
  • Professional data, including data about your employer, in cases where you’ve connected your payroll accounts or provided us with your pay stub or tax form information.

Depending on the MPT service you or the developer of your app use, and the manner in which the data is made available, the data collected from your financial accounts may include data from all accounts (e.g., checking, savings, credit card, and joint accounts) accessible through a single set of account credentials. For more specifics about data collected in connection with different products and services, see Summary of Processing Activities by Product.

Data we receive from your devices. When you use a device, like your smartphone, tablet, or computer, to connect to our services through a developer’s application, we receive data about that device, including:

  • internet protocol (IP) address;
  • timezone setting and location, device location;
  • hardware model and operating system;
  • which features within our services you access, browser data, and other technical data about the device.

Data we receive about you from the developers of apps powered by MPT. When needed for MPT to provide a service, the developers of the apps you use may provide us with identifiers and commercial information about you, like your name, Social Security number, email address, phone number, or information about your financial accounts and account transactions. One example of this kind of service are MPT Identity Verification and Monitor services, which are used so the developer you are connecting to can verify your identity, detect fraud, and screen their users against watchlists.

Data we receive about you from other sources. When needed to provide a service or to help prevent fraud, abuse, or security threats, we may also receive data about you directly from third parties, including our service providers or identity verification services.

Information we derive from the data we collect. We may derive additional information about you from the data we collect. For example, we may infer your geolocation, your annual income, or the type of account or subaccount you’ve chosen to connect―such as when you connect your loan accounts, so we can let the developer know whether the account is for a mortgage, student loan, or credit card.

How We Use Your Data

We use your data for the following business and commercial purposes:

  • Provide Services: To operate, provide, and maintain our services.
  • Develop Existing Services: To improve, enhance, modify, add to, and further develop our services.
  • Help Prevent Fraud or Protect Privacy: To help protect you, developers, our partners, MPT, and others from fraud, malicious activity, and other privacy and security-related concerns.
  • Develop New Services: To develop new products and services.
  • Develop Insights: To develop insights based on the data we’ve collected about you. This includes your transaction data and data from other sources, to help developers of your connected apps provide services and/or a better user experience to you, like providing you with faster access to your funds or to help detect and prevent potentially fraudulent activity.
  • Provide Support: To provide support to you or to developers, including to help respond to your inquiries related to our services or developers’ apps.
  • Investigate Misuse and Misconduct: To investigate any misuse of our service or developers’ apps, including violations of our Developer Policy, criminal activity, or other unauthorized access to our services.
  • For Legal Purposes: To comply with contractual and legal obligations under applicable law and for other legal purposes such as to establish and defend against claims.
  • With Your Consent: For other notified purposes with your consent or at your direction.

Our Lawful Bases for Processing (EEA and UK End Users)

For individuals in the European Economic Area (“EEA”) or the United Kingdom (“UK”), MPT only processes your personal data when we have a valid legal basis to do so. Our legal basis for processing the data we collect will depend on what information we collected and the context for processing it. Generally, we will only collect and process your data where:

  • we need to fulfill our responsibilities and obligations in any contract or agreement with you (for example, to comply with our end user services agreements);
  • to comply with our legal obligations under applicable law;
  • the processing is necessary for our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example, to safeguard our services; to communicate with you; or to update our services); or
  • you have given your consent to do so.

To the extent we rely on consent to collect and process your data, you have the right to withdraw your consent at any time per the instructions provided in this Policy.

How We Share Your Data

We share your data for the following reasons:

  • With the developer of the app you are using and as directed by that developer;
  • To enforce any contract with you;
  • With our data processors and other service providers, partners, or contractors in connection with the the services they perform for us or developers;
  • With financial partners to help establish, maintain, or manage a connection you’ve chosen to make between your financial institution accounts and an app;
  • If we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (like a court order or subpoena);
  • In connection with a change in ownership or control of all or a part of our business (like a merger, acquisition, reorganization, or bankruptcy);
  • Between and among MPT and our current and future parents, affiliates, subsidiaries and other companies under common control or ownership;
  • As we believe reasonably appropriate to prevent malicious or fraudulent activities, or otherwise protect the rights, privacy, safety, or property of you, developers, our partners, MPT, and others; or
  • For any other notified purpose with your consent or at your direction.

(For US users) We do not share your data with non-affiliated third parties except as permitted by law (as authorized by 12 C.F.R. s 1016.14 and 1016.15).

We may collect, use, and share data that has been aggregated or anonymized in a manner that does not identify you personally for any purpose permitted under applicable law. This includes creating or using aggregated or anonymized data to develop new services or to facilitate research, to the extent permitted under applicable law.

When you link your financial accounts through MPT, we typically use Google’s reCaptcha service to help detect fraud and abuse. When reCaptcha is used, Google’s Privacy Policy and Terms of Use apply to reCaptcha and information Google collects through reCaptcha.

We do not sell or rent personal data that we collect under this policy.

We may collect and share cookie data with third parties when you visit our website, or we may allow third parties to collect this cookie data from our sites. Please see our Cookie Policy and All Audience Privacy Statement for more details.

Our Retention and Deletion Practices

We retain your data only as long as it is needed. To determine whether the data is needed, we consider the reason your data was collected and used and any legal requirements to hold onto your data. We review your data periodically to ensure it is still needed to fulfill the purpose for which it was collected or any other legal requirements. If a developer removes your connection from their app to your data, MPT’s systems are designed to automatically delete your personal data, subject to certain exceptions where we may still retain your information which we talk about below.

The exceptions to this may be if: (a) you’ve established a connection with another developer’s app through MPT that is still active; (b) MPT needs your data to continue providing you with a MPT service you requested; (c) MPT is required by law to keep your data; (d) MPT needs your data to help prevent fraud or protect privacy, provide support, or investigate misuse and misconduct; or (e) we request - and you specifically agree - to allow us to retain your data longer.

Your data will only be processed as required by law or in accordance with this Policy.

Please refer to the “Your Data Protection Rights” section of this Policy for options that may be available to you, including how to request deletion of your data. The “Your Privacy Controls” section of this Policy also provides details about tools available to you to help you view and manage the connections you’ve made using MPT. You can also contact us about our data retention practices using the contact information in the “Contacting MPT” section below.

Protection of Data

MPT’s security policies and practices are designed to protect the confidentiality and integrity of your data (such as Social Security number and other identifying data), as well as any other data we collect about you. MPT implements controls designed to limit access to this data to personnel who have a business reason to know it and prohibits its personnel from unlawfully disclosing this data.

Some Final Details

International Data Transfers

We operate internationally, and so we may transfer the data we collect about you across international borders for processing and storage (for example, we may transfer data from the EEA or UK to the United States). When we transfer data to a different country or territory, we follow applicable data protection laws in doing so. In particular, when we transfer data from the EEA or UK across other international borders, we rely on adequacy decisions, data transfer agreements, or other EU Commission- or UK Secretary of State-approved (as applicable) mechanisms for such transfers, including standard contractual clauses. You can ask for a copy of these standard contractual clauses by contacting us as set out below. Prior to transferring data from the EEA or UK, we carry out transfer impact assessments and implement any supplementary measures to ensure any data transferred will be maintained in accordance with EEA and UK requirements.

Your Data Protection Rights

Regardless of where you live, we will honor the following rights related to your personal data, subject to some limitations and exceptions provided by law, and you will not be discriminated against for exercising them:

  • Access data collected about you;
  • Request access to more details about the categories and specific pieces of personal information we may have collected about you in the last 12 months (including personal information disclosed for business purposes);
  • Request, under certain circumstances, that we rectify or update your data that is inaccurate or incomplete;
  • Request, under certain circumstances, that we erase or restrict the processing of your data;
  • Object to our processing of your data under certain conditions provided by law;
  • Where processing of your data is based on consent, withdraw that consent;
  • Request that we provide data collected about you in a structured, commonly used and machine-readable format so that you can transfer it to another company, where technically feasible.

For both MoneyPools Technology USA. and MoneyPools Technology UK. we have appointed a data protection officer (DPO) who is also responsible for overseeing questions in relation to this Policy and can be contacted via email at support@moneypoolscash.com.

We welcome and appreciate the chance to address any concerns you may have and encourage you to contact us. In addition, and depending on your jurisdiction, you may have the right to make a complaint at any time to your (data protection) supervisory authority. For end users in the EEA, you can find contact information for the European Data Protection Board (EDPB) on the EDPB’s website here. For end users in the UK, you can find contact information for the Information Commissioner’s Office (ICO) on the ICO’s website here.

To exercise any rights you have, you can submit a request using our online form. You can also contact us as described in the “Contacting MPT” section below to exercise any of your data protection rights. You may be required to provide additional information necessary to confirm your identity before we can respond to your request.

If we receive your request from an authorized agent, we may ask for evidence that the agent has valid written authority, like a power of attorney, to submit requests on your behalf.

We will consider requests and provide our response within a reasonable period of time (and within any time period required by applicable law). Please note, however, that certain data may be exempt from such requests, for example if we need to keep the data to comply with our own legal obligations or to establish, exercise, or defend legal claims.

Your Additional Privacy Controls

MPT developed the MPT Portal to provide you with a convenient, centralized way to view and manage the connections you’ve made using MPT.

If you’re located in the U.S., you can create a MPT Portal account by visiting moneypoolscash.com verifying your phone number and email address, and creating a password. Once you’ve created a MPT Portal account, you’ll be directed to a dashboard that can show you financial accounts you’ve connected to your chosen apps using MPT, and the types of data shared with those apps. Additionally, the MPT Portal provides you with controls to terminate the connection between apps and your financial accounts and delete associated data stored in MPT’s systems.

Changes To This Policy

We may update or change this Policy from time to time. If we make any updates or changes, we will post the new policy on MPT’s website at https://moneypoolscash.com/ and update the effective date at the top of this Policy. We will also notify developers of any material changes in accordance with our developer agreements, as they may be better positioned to notify you about changes to this Policy. If you have an active MPT Portal account, we will also send you an email notifying you of the update.

Contacting MPT

If you have any questions or complaints about this Policy, or about our privacy practices generally, you can contact us at support@moneypoolscash.com or by mail at:

If you reside outside the EEA or UK:

MoneyPools Technology USA Inc.

Attn: Legal

30 N Gould Street, Suite 4000

Sheridan, Wyoming, 82801 United States

For both MoneyPools technology USA. and MoneyPools Technology UK. we have appointed a data protection officer (DPO) who is also responsible for overseeing questions in relation to this Policy and can be contacted via email at support@moneypoolscash.com.


If you reside in the UK:

MoneyPools Technology UK Limited

Attn: Legal

 128 City Road
London, EC1V 2NX
UNITED KINGDOM


If you reside in the EEA:

MoneyPools Technology UK Limited

Attn: Legal

 128 City Road
London, EC1V 2NX
UNITED KINGDOM

 

 

Summaries of Processing Activities

Summary of Processing Activities by Category of Information

To help provide even greater transparency around our practices, we consolidated the information provided in our Policy above into a table that matches the categories of data MPT collects about you with the sources of the data, uses of the data, and the categories of recipients with whom MPT shares the data. For more detailed descriptions of our data collection, use, and sharing practices, please refer back to the sections of the Policy above.

Category of Personal Information & Examples

Source of Personal Information

Uses of Personal Information

Categories of Parties with Whom Personal Information May Be Shared

Identifiers

for example: name, email address, phone number, and username

  • Data you provide
  • Data we collect from your financial accounts
  • Data we receive from your devices
  • Data we receive about you from other sources
  • Provide Services
  • Develop Existing Services
  • Help Prevent Fraud or Protect Privacy and Security
  • Develop New Services
  • Develop Insights
  • Provide Support
  • Investigate Misuse and Violations
  • For Legal Purposes
  • With Your Consent
  • Developer(s) of app(s) you use, and as directed by the developer(s)
  • Financial institutions
  • Providers of payments services 
  • Partners and contractors in connection with the services they perform for us or developers
  • Professional advisors
  • Service providers who help MPT analyze data for MPT's business purposes
  • Cloud storage services providers
  • Software development services providers
  • Fraud prevention services providers
  • Identity verification services providers
  • MPT group entities
  • Third parties when compelled by law, such as to law enforcement or other governmental authorities

Financial Data

for example: financial account name and number, balance, and transaction history

  • Data you provide
  • Data we collect from your financial accounts
  • Data we receive about you from other sources
  • Data we derive from data we collect from you or other sources
  • Provide Services
  • Develop Existing Services
  • Help Prevent Fraud or Protect Privacy and Security
  • Develop New Services
  • Develop Insights
  • Provide Support
  • Investigate Misuse and Violations
  • For Legal Purposes
  • With Your Consent
  • Developer(s) of application(s) you use, and as directed by the developer
  • Financial institutions
  • Providers of payments services
  • Partners and contractors in connection with the services they perform for us or developers
  • Professional advisors
  • Service providers who help MPT analyze data for MPT's business purposes 
  • Cloud storage services providers
  • Software development services providers
  • Fraud prevention services providers
  • Identity verification services providers
  • MPT group entities
  • Third parties when compelled by law, such as to law enforcement or other governmental authorities

Commercial Data

for example: data relating to which of our services you use through developer apps and the dates and times of your use

  • Data we collect from your financial accounts
  • Data we receive about you from other sources
  • Data we derive from data we collect from you or other sources
  • Provide Services
  • Develop Existing Services
  • Help Prevent Fraud or Protect Privacy and Security
  • Develop New Services
  • Develop Insights
  • Provide Support
  • Investigate Misuse and Violations
  • For Legal Purposes
  • With Your Consent
  • Developer(s) of application(s) you use, and as directed by the developer
  • Financial institutions
  • Providers of payments services
  • Partners and contractors in connection with the services they perform for us or developers
  • Professional advisors
  • Service providers who help MPT analyze data for MPT's business purposes
  • Cloud storage services providers
  • Software development services providers
  • Fraud prevention services providers
  • Identity verification services providers
  • MPT group entities
  • Third parties when compelled by law, such as to law enforcement or other governmental authorities

Location Data

for example: timezone setting and device location

  • Data we receive from your devices
  • Data we derive from data we collect from you or other sources
  • Provide Services
  • Develop Existing Services
  • Help Prevent Fraud or Protect Privacy and Security
  • Develop New Services
  • Develop Insights
  • Provide Support
  • Investigate Misuse and Violations
  • For Legal Purposes
  • With Your Consent
  • Developer(s) of application(s) you use, and as directed by the developer
  • Financial institutions
  • Partners and contractors in connection with the services they perform for us or developers
  • Professional advisors
  • Service providers who help MPT analyze data for MPT's business purposes
  • Cloud storage services providers
  • Software development services providers
  • Fraud prevention services providers
  • MPT group entities
  • Third parties when compelled by law, such as to law enforcement or other governmental authorities

Professional Data

for example: information about your employer and payroll information

  • Data you provide
  • Data we collect from your financial accounts
  • Data we receive about you from other sources
  • Data we derive from data we collect from you or other sources
  • Provide Services
  • Develop Existing Services
  • Help Prevent Fraud or Protect Privacy and Security
  • Develop New Services
  • Develop Insights
  • Provide Support
  • Investigate Misuse and Violations
  • For Legal Purposes
  • With Your Consent
  • Developer(s) of application(s) you use, and as directed by the developer
  • Financial institutions
  • Partners and contractors in connection with the services they perform for us or developers
  • Professional advisors
  • Service providers who help MPT analyze data for MPT's business purposes
  • Cloud storage services providers
  • Software development services providers
  • Fraud prevention services providers
  • Identity verification services providers
  • MPT group entities

Electronic Network Activity Data

for example: your device hardware model and operating system, and browser data

  • Data we receive from your devices
  • Provide Services
  • Develop Existing Services
  • Help Prevent Fraud or Protect Privacy and Security
  • Develop New Services
  • Develop Insights
  • Provide Support
  • Investigate Misuse and Violations
  • For Legal Purposes
  • With Your Consent
  • Developer(s) of application(s) you use, and as directed by the developer
  • Financial institutions
  • Partners and contractors in connection with the services they perform for us or developers
  • Professional advisors
  • Service providers who help MPT analyze data for MPT's business purposes
  • Cloud storage services providers
  • Software development services providers
  • MPT group entities

Information We Derive

for example: we may derive location from IP address or your annual income from your pay stubs

  • Information we derive from data we collect from you or other sources
  • Provide Services
  • Develop Existing Services
  • Help Prevent Fraud or Protect Privacy and Security
  • Develop New Services
  • Develop Insights
  • Provide Support
  • Investigate Misuse and Violations
  • For Legal Purposes
  • With Your Consent
  • Developer(s) of application(s) you use, and as directed by the developer
  • Financial institutions
  • Providers of payments services
  • Partners and contractors in connection with the services they perform for us or developers
  • Professional advisors
  • Service providers who help MPT analyze data for MPT's business purposes
  • Cloud storage services providers
  • Software development services providers
  • Fraud prevention services providers
  • MPT group entities

 

Summary of Processing Activities by Product

As noted above, the data we collect and use depends on the MPT products and services that you and the developer use. To make it easier to understand what data is collected and used for which product and service, we put together the below summaries of our data collection and use by product. Some of these products are only available to US based users, and others are only available to EEA and UK based users. If you are not sure which MPT products or services your connected applications use, please contact the developer of the application. (Note that this list reflects MPT’s product suite as of the effective date of this Policy and may not include products or services in development as of that date.)

Assets

Assets enables you to provide access to a point-in-time consolidated summary of your financial account data—like account balances, transaction histories, and account holder identity information—to MPT and the apps and services you choose. We collect identifiers, financial information, commercial data, location data, electronic network activity data, and we derive inferences from this data. We use this data as described in the How We Use Your Data section of this Policy.

Auth

Auth helps to enable you to authenticate your financial account data and provide access to your account and routing numbers to MPT and the apps and services you choose. We collect identifiers, financial data, commercial data, location data, and electronic network activity data. We use this information as described in the How We Use Your Data section of this Policy.

Balance

Balance enables you to provide access to your real-time financial account balances to MPT and the apps and services you choose so they can help you do things like avoid overdrawing your account before you make a money transfer. We collect identifiers, financial data, commercial data, location data, and electronic network activity data. We use this data as described in the How We Use Your Data section of this Policy.

Identity

Identity enables you to provide access to the account holder data held by your financial institution—such as your name, email address, phone number, and mailing address—to MPT and the apps and services you choose to help them do things like verify your identity or prefill your account data within the app. We collect identifiers, financial data, commercial data, location data, and electronic network activity data. We use this data as described above in the How We Use Your Data section of this Policy.

Identity Verification and Monitor

Identity Verification and Monitor facilitate identity verification, fraud detection, and watchlist screening services globally for developers. When we provide Identity Verification and Monitor services to developers, we only collect and process your data as a service provider to that developer, and so the developers determine the purpose and means by which your data is processed. For more details on how we process end user data for developers and on the developer’s instruction to provide Identity Verification and Monitor services, see our affiliate’s End User Privacy Statement.

Income

Income enables you to provide access to data pertaining to your income and employment to MPT and the apps and services you choose. We collect identifiers, financial data, commercial data, location data, professional data, electronic network activity data, and we derive inferences from this data. We use this data as described in the How We Use Your Data section of this Policy.

Investments

Investments enables you to provide access to data from your retirement, brokerage, education savings, and health savings accounts to MPT and the apps or services you choose so they can do things like provide you with personal financial and wealth management tools. We collect identifiers, financial data, commercial data, location data, professional data, electronic network activity data, and we derive inferences from this data. We use this data as described in the How We Use Your Data section of this Policy.

Liabilities

Liabilities enables you to provide access to financial data from your credit card, mortgage, and student loan accounts to MPT and the apps and services you choose. We collect identifiers, financial data, commercial data, location data, electronic network activity data, and we derive inferences from this data. We use this data as described in the How We Use Your Data section of this Policy.

Payment Initiation and Variable Recurring Payments

Payment Initiation enables you to make one time, recurring, or variable recurring payments into accounts. This is for services like bank transfers, standing orders, and variable recurring payments and one-off or recurring payments out of accounts, like withdrawals and refunds. Variable Recurring Payments enables our EU and UK users to authenticate a bank account one time, and then make future payments without the need for additional authentication. We collect identifiers, financial data, commercial data, location data, electronic network activity data, and we derive inferences from this data. We use this data as described in the How We Use Your Data section of this Policy.

Payouts

Payouts enables you to seamlessly and instantly make withdrawals and refunds from an app or service that you are using, by opening and pre-funding an e-money account from which funds can be sent to users that are requesting a payout. We collect identifiers, financial data, commercial data, location data, electronic network activity data, and we derive inferences from this data. We use this data as described in the How We Use Your Data section of this Policy.

MPT Portal

MPT Portal is a privacy tool that US end users can use as a way to control the connections to apps that they’ve made through MPT. End users can use MPT Portal to view connections to apps in a single dashboard, disconnect financial accounts from apps, or delete data from MPT’s systems. We collect identifiers, financial data, commercial data, location data, and electronic network activity data. We use this data as described in the How We Use Your Data section of this Policy.

Signal

Signal helps the apps and services you use provide a better user experience to you, like providing you with faster access to your funds and reducing the risk of fraud or a payment not being completed. We collect identifiers, financial data, commercial data, location data, electronic network activity data, and we derive inferences from this data. We use this data as described in the How We Use Your Data section of this Policy.

Transactions

Transactions enable you to provide access to transaction histories from your financial accounts to MPT and apps and services you choose so they can provide you with things like personal finance management tools, expense reporting, cash flow modeling, and more. We collect identifiers, financial data, commercial data, location data, electronic network activity data, and we derive inferences from this data. We use this data as specified above in the How We Use Your Data section of this Policy.

Transfer

Transfer enables you to authorize a developer to send payments to you, or collect payments from you, through bank transfers, on either a one time or recurring basis. This includes verifying you own the account to or from which the payment will be sent, assessing the risk that the payment may not be completed or is fraudulent, electronically moving the money, and confirmation that the money was moved. We may collect identifiers, financial data, location data, and electronic network activity data. We use this data as described in the How We Use Your Data section of this Policy.

Wallet Onboard

Wallet Onboard lets you connect your crypto wallet with the apps and services you choose. We only collect IP address and data associated with the device you use to connect. When you make this connection, you might choose to pass your wallet address on to the third party app or service you are connecting to - in that instance, MPT does not collect or store that wallet address. We use this data as described in the How We Use Your Data section of this Policy.

Consumer Privacy Notice

Last Updated: February 28, 2023


WHAT DOES MPT DO WITH YOUR PERSONAL INFORMATION?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you, or the app developer you are connecting to, use. This information can include:

  • Social Security number and account balances
  • Account transactions and transaction history
  • Income and employment information

For more information on the types of personal information we collect, please see the Data We Collect or Derive section of our End User Privacy Policy.

When you are no longer our consumer, we continue to use and share your information as described in this notice.

How?

All financial companies need to share consumers’ personal information to provide their products and services. In the section below, we list the reasons financial companies can share their consumers’ personal information; the reasons MPT chooses to share; and whether you can limit this sharing.

 

Reasons we can share your personal information

Does MPT share?

Can you limit this sharing?

For our everyday business purposes –
such as to connect and share data from your financial accounts to power the apps you use, as well as to protect against fraud or misuse, respond to court orders and legal investigations, or report to credit bureaus.

Yes

No

For our marketing purposes

No

We don’t share

For joint marketing with other financial companies

No

We don’t share

For our affiliates' everyday business purposes - information about transactions and experiences

No

We don’t share

For our affiliates' everyday business purposes - information about creditworthiness

No

We don’t share

For nonaffiliates to market to you

No

We don’t share

 

Questions

Contact us support@moneypoolscash.com

 

Who we are

Who is providing this notice?

MPT Inc.

 

What we do

How does MPT protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does MPT collect my personal information?

As explained in more detail in the Data We Collect or Derive section of our End User Privacy Policy, we collect personal information you provide to us and collect your personal information from other companies when you use our products or services. This includes, for example, when you use MPT Portal or when you use MPT to connect and share your data to power the applications (“apps”) you use.

Why can’t I limit all sharing?

Federal law gives you the right to limit only:

  • sharing for affiliates’ everyday business purposes – information about your creditworthiness;
  • affiliates from using your information to market to you;
  • sharing for nonaffiliates to market to you.

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

 

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

  • Our affiliates include MoneyPools technology USA. and MoneyPools Technology UK.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

  • MPT does not share with nonaffiliates so they can market to you.

Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

  • MPT does not joint market.

Other Important Information

California: If you are a resident of California, we will not share personal information we collect about you except to the extent permitted under California law.

Vermont: If you are a resident of Vermont, we will not share personal information we collect about you with non-affiliates unless the law allows or you provide authorization.

End User Services Agreement (US)

Effective Date: January 1, 2023

Thanks for using MPT! MPT provides a platform (“Platform”) that allows you and other end users to connect your bank accounts and other financial accounts (“Accounts”) with applications that can help you do things like save for retirement, manage your spending, streamline credit applications or transfer money (“Apps”).

This End User Services Agreement (US) (“Agreement”) is an agreement between you and MPT Inc. (“MPT”, “we” or “us”). By accepting this Agreement or accessing Moneypoolscash.com or your MPT profile, you agree to this Agreement and certify that you have all necessary rights to do so. If you are accepting on behalf of your employer or another entity, you represent and warrant that: (i) you have full legal authority to bind your employer or such entity to this Agreement; (ii) you have read and understand this Agreement; and (iii) you agree to this Agreement on behalf of the party that you represent. If you do not have the legal authority to bind your employer or the applicable entity, please do not accept this Agreement or access the features covered by this Agreement.

Please note that this Agreement does not apply to the services we provide to the developers of Apps. Those services are covered by our Developer Terms of Use and other terms.

MoneyPoolscash.com

You can use Moneypoolscash.com to manage connections between your Accounts and Apps. Moneypoolscash.com is designed to empower you with greater control over your financial data, but the decision to use any App remains yours. Your use of any App and Account, and the App and Account providers’ use of your data, is governed by separate terms between you and the applicable providers. MPT is not responsible for any Apps or Accounts provided by third parties or the acts or omissions of any third-party providers, and does not guarantee that any Apps or Accounts will remain available or compatible with the Platform.

MPT Profile Creation.

You need to create an profile with MPT in order to use certain features of the Platform, including certain features of Moneypoolscash.com. You also need to ensure that your information is accurate, complete and up-to-date. You must notify us if you learn of any unauthorized access to or use of your MPT Profile.

Control and Responsibilities.

You represent and warrant that you have all necessary rights to use your Accounts and Apps with the Platform, and you agree to comply with all laws and regulations applicable to your use, as well as any rules and guidelines that we post. You must not (1) use or access anyone else’s Accounts or related data, (2) submit information about anyone else’s identity or Accounts or that violates any third-party rights or (3) use the Platform for any fraudulent, illegal or misleading purpose. You also agree not to (a) modify, reverse engineer or seek to gain unauthorized access to the Platform or related systems, data or source code, (b) bypass or circumvent measures designed to prevent or limit access to any part of the Platform, (c) rent, lease, provide access to or sublicense any elements of the Platform to a third party or use the Platform on behalf of or to provide services to third parties, (d) copy, modify or create derivative works of the Platform or remove any of MPT’s proprietary notices, (e) access the Platform for competitive purposes or publish any benchmark or performance information about the Platform, or (f) use the Platform in any manner that could damage, disable, overburden, or impair the functioning of the Platform or interfere with, disrupt or negatively affect other users.

How MPT Uses Your Data.

Please review our End User Privacy Policy to learn how MPT uses data related to your Accounts (e.g., your Account login information and balance information). You should also refer to our Privacy Statement and Cookie Policy for information about what we collect from the use of our websites. If you have questions, contact us at support@moneypoolscash.com.

Rights to the Platform.

Note that MPT owns all right, title and interest (including intellectual property rights) in and to the Platform (including Moneypoolscash.com and MPT Profile features) and our related websites and technology. If you choose to give us feedback, suggestions or other inputs about the Platform, we may use them without restriction.

Our Disclaimers.

TO THE EXTENT PERMITTED BY LAW, THE PLATFORM (INCLUDING MONEYPOOLSCASH.COM AND MPT PROFILES) IS PROVIDED “AS IS” AND “AS AVAILABLE,” AND ANY USE IS AT YOUR DISCRETION AND RISK. MPT, ITS AFFILIATES AND ITS AND THEIR SUPPLIERS MAKE NO WARRANTIES, EXPRESS OR IMPLIED, STATUTORY OR OTHERWISE, INCLUDING WARRANTIES OF MERCHANTABILITY, TITLE, FITNESS FOR A PARTICULAR PURPOSE OR NONINFRINGEMENT. MPT DOES NOT WARRANT THAT USE WILL BE UNINTERRUPTED OR ERROR-FREE, THAT ANY OF YOUR DATA WILL BE ACCURATE OR COMPLETE OR THAT MPT WILL MAINTAIN ANY DATA WITHOUT LOSS.

Liabilities for our Platform. TO THE EXTENT PERMITTED BY LAW, MPT, ITS AFFILIATES AND ITS AND THEIR SUPPLIERS WILL NOT BE RESPONSIBLE FOR: (A) ANY LOST PROFITS, LOSS OF USE, LOST OR INACCURATE DATA, FAILURE OF SECURITY MECHANISMS, FINANCIAL LOSSES, OR ANY INDIRECT, SPECIAL, INCIDENTAL, RELIANCE OR CONSEQUENTIAL DAMAGES OF ANY KIND OR (B) ANY DAMAGES OR AMOUNTS EXCEEDING, IN THE AGGREGATE, THE GREATER OF (1) THE AMOUNT YOU PAID US TO USE THE PLATFORM AND (2) ONE HUNDRED U.S. DOLLARS (US $100).

Dispute Resolution.

We hope you will have a positive experience using our Platform, but should a dispute between us arise out of or relating to these Terms, we agree to resolve the dispute by following these steps:

  1. Send us a notice, according to the Notices section below, describing the dispute and including all relevant facts so we know how to help you.
  2. Within 5 business days after our receipt of your notice, we will reach out to discuss your dispute with you.
  3. If we’re not able to resolve your dispute during our discussion, you will send us a written proposal for resolving your dispute.
  4. Within 15 business days after our receipt of your written proposal, we will let you know whether we agree to your proposal, or we will provide you with a counter-proposal.

After Step 4, it’s up to you to decide whether you’d like to continue to negotiate with us to resolve your dispute, or whether you’d like to pursue a resolution through some other means.

Throughout this process, both you and MPT agree to negotiate in good faith and according to the terms of this section to resolve the dispute before resorting to litigation or some other form of dispute resolution procedure. All negotiations (including your notice, our discussions, and your and our proposals) pursuant to this section are confidential and treated as compromise and settlement negotiations for the purposes of federal and state rules of evidence and procedure.

Notices.

MPT may provide notices or communications to you through the email associated with your MPT profile, through Moneypoolscash.com or through other reasonable methods. All notices, requests and other communications to MPT under this Agreement must be in writing to MPT Inc., Attention: 30 N Gould Street, Suite 4000 Sheridan, Wyoming, 82801 United States (with a courtesy copy to support@moneypoolscash.com ) and will be deemed given when delivered.

Ending This Agreement.

At any time in its discretion, MPT may terminate or suspend this Agreement (or your use of the Platform) with or without notice and for any or no reason, including if MPT suspects that you have violated this Agreement. MPT will have no liability to you for any termination or suspension, nor will such action limit any other rights or remedies MPT may have. Except for your right to use the Platform, this Agreement will survive any termination.

About This Agreement.

This Agreement may not be transferred or assigned by you without MPT’s prior written consent. MPT may assign or transfer this Agreement to its affiliates or in connection with a merger, sale, reorganization or other change of control. In addition, MPT’s affiliates, contractors and service providers may exercise MPT’s rights or fulfill its obligations under this Agreement. Waivers must be in writing and no waivers will be implied. If any provision of this Agreement is held by a court of competent jurisdiction to be unenforceable for any reason, the remaining provisions will remain unaffected and in full force and effect. This Agreement is the final, complete and exclusive agreement between you and us relating the subject matter of this Agreement and supersedes all prior or contemporaneous understandings and agreements relating to such subject matter, whether oral or written. In this Agreement, headings are for convenience only and the term “including” (and similar terms) will be construed without limitation.

MPT may modify this Agreement from time to time. Unless we specify otherwise, modifications take effect (and govern future use of the Platform, including Moneypoolscash.com and your MPT Profile) when we post the modified version. MPT will use reasonable efforts to notify you of the modifications, and you may be required to agree to the modified version. If you do not agree to the modifications, your sole remedy is to cease using the Platform.

End User Services Agreement (UK)

Last Updated: 04 August 2022

Thank you for using MPT!

This End User Services Agreement ("Agreement") is a legal agreement between MPT Financial Ltd. ("MPT", "we" or "us") and the end user of our Services ("you", "your"). This Agreement only applies when we provide account information services and payment initiation services to you with respect to a UK payment account, and when we transmit retrieved data and/or the payment status related to such services to third parties on your behalf ("Services"). Such third parties include the owner or provider of the website, desktop and/or mobile application through which you have accessed our Services ("Application").

This Agreement describes the terms and conditions that apply to your use of the Services. You may not access or use the Services unless you agree to comply with all of the terms and conditions in this Agreement. You should therefore read this Agreement carefully and make sure you understand it. If you do not understand any of the terms and conditions of this Agreement, please contact us before using the Services by emailing us at support@moneypoolscash.com.

You may view an up-to-date copy of this Agreement at any time.

1. MPT

1.1. MoneyPools Technology UK. (company registration #14520768) is regulated by the Financial Conduct Authority under the Payment Services Regulations 2017 for the provision of payment initiation and account information  services

1.2. MPT's registered office address is 128 City Road London, EC1V 2NX UNITED KINGDOM.

2. MPT Services

2.1. You have accessed our Services through an Application or within the MPT dashboard (available at https://Moneypoolscash.com/ ). The products and services provided to you by the Application are governed by a separate agreement between you and the provider of the Application ("Application Terms"). We have no responsibility for the products and services provided to you by or through the Application and will not be liable to you for any harm, damage or loss arising from your use of the products and services provided by or through the Application.

2.2. Our Services will allow you to obtain financial information from your online bank or payment account ("Payment Account") (account information services) and to make online payments directly from your Payment Account (payment initiation services).

2.3. The terms and conditions that apply to the Payment Accounts that you access through our Services (the "Account Terms") will remain in effect and this Agreement does not change your Account Terms.

2.4. We will not charge you for the use of our Services. Applications or other third parties may, however, charge you for products and services provided to you that make use of the Services provided by MPT under this Agreement. Application providers and other third parties may pay us fees and other amounts in connection with the services we provide to them.

Account information services

2.5. MPT's account information services allow you to access and view information relating to your selected Payment Account within the MPT dashboard (available at https://Moneypoolscash.com/ ) and the Application through which you have accessed our Services.

2.6. To access the MPT dashboard, you need to create an account with MPT. You also need to ensure that your information is accurate, complete and up-to-date. You must follow best practices to help secure your MPT account and notify us if you learn of any unauthorised access to or use of your MPT account.

2.7. With your explicit consent, we access and display information relating to your selected Payment Account(s) ("Account Information") within the MPT dashboard and transmit such information to the Application through which you have accessed our Services. Such information may include: a. financial transaction history, for example, transaction amount, data, description and currency; b. financial account details, for example, account number, type, currency and balance; and c. financial account holder information, for example, name, address, phone number, and email address.

2.8. Before receiving MPT's account information service, you will have instructed the Application through which you have accessed our Services to retrieve your Account Information using MPT. Upon such an instruction, you will generally be redirected to us.

2.9. Once you are redirected to us, we will ask you to select which Payment Account provider ("Account Provider") you would like us to access Account Information from. You will give your explicit consent to us: (i) accessing your Account Information from the Account Provider you have selected; and (ii) taking the steps outlined in clause paragraph 2.12. once we have accessed your Account Information. MPT will request your Account Information from your Account Provider on a periodic basis in accordance with your consent until the consent expires or is withdrawn.

2.10. Please note, you may be redirected to your Account Provider's website or mobile application in order to authenticate yourself so that your Account Provider knows that you consent to us accessing your Account Information.

2.11. Alternatively, in some circumstances, we may ask you to provide us with the login details for your Payment Account. By providing us with your Payment Account login details, you confirm that you have all the necessary rights, permissions and authority to share your login details and Account Information with us, and you grant us explicit consent to use your login details to access your Payment Account to obtain the necessary Account Information on your behalf and at your direction in order to provide you with the Services.

2.12. Once we have accessed your Account Information we may: a. share your Account Information with the Application through which you have accessed our Services; b. share your Account Information with third parties as directed by the Application through which you have accessed our Services provided, however, that you have explicitly consent to such sharing; or c. display your Account Information on the MPT dashboard.

2.13. You agree to us sharing the Account Information we have accessed from your Account Provider with the Application through which you have accessed our Services, and with third parties as directed by that Application provided that in both cases you have explicitly consented to such sharing. Such sharing allows the Application to provide you with products and services in accordance with the Application Terms.

2.14. We do not check the accuracy of the Account Information retrieved from your Account Provider and we rely on your Account Provider to ensure that your Account Information is up to date and accurate.

2.15. We may standardize, categorize, merge, aggregate, and otherwise process your Account Information before displaying your Account Information on the MPT dashboard, sharing it with the Application through which you have accessed our Services, or sharing it with third parties as directed by that Application with your explicit consent.

2.16. You may withdraw or vary your consent for MPT to provide account information services at any time.

Payment initiation services

2.17. MPT's payment initiation service allows you to make online payments from your Payment Account(s). MPT can initiate the following types of online payments from your Payment Account(s): (i) single payments; (ii) standing orders; and (iii) variable recurring payments.

Single Payments

2.18. Before receiving our payment initiation service in respect of a single online payment order, you will have instructed the Application through which you have accessed our Services to make a single online payment using MPT. You will be asked to review and confirm your payment order details for the single online payment, including: (i) the payment amount and (ii) the recipient details. It is your responsibility to ensure that all of the payment order details are correct before you confirm the payment order. You may not be able to recover a payment to an incorrect account or recipient.

2.19. These details will be pre-populated for you to review and confirm. For example, where you use MPT payment initiation services to purchase goods or services online you must ensure that the merchant recipient details are correct.

2.20. You will confirm the payment order and provide explicit consent for MPT to send the payment order to your Account Provider for execution, to receive information from your Account Provider on the initiation and execution of the payment order and to pass this information on to the Application through which you accessed our Services.

2.21. When you use MPT's payment initiation service you will be asked to select the Payment Account from which you will fund the payment and you may be redirected to your Account Provider's website or mobile application in order to authenticate yourself so that your Account Provider knows that you consent to the transaction.

2.22. If the payment order relates to a transaction that is to be executed by your Account Provider immediately, you will not be able to cancel the payment order once you have provided your confirmation and explicit consent in accordance with paragraph 2.20.

2.23. If the Application through which you accessed our Services supports refunds, the following provisions apply: At the time we submit the payment order to your Account Provider for execution, we shall ask the Account Provider to share your name, Payment Account sort code and account number or IBAN ("Account Details") with us. If you require a refund for the payment made using MPT's payment initiation services, you must request the refund from the Application through which you accessed our Services. The Application will in turn notify us that you have requested a refund and we will share your Account Details with the Application in order for them to make the refund to your Payment Account (i.e. the Payment Account used to fund the original payment). The Application (and not MPT) is responsible for making the refund. MPT accepts no liability for the accuracy of your Account Details provided to us by your Account Provider.

Standing Orders

2.24. You can use MPT's payment initiation service to submit a standing order to your Account Provider. A standing order is an instruction to your Account Provider to make regular, recurring payments of the same amount to the same recipient over a specified or indefinite period of time.

2.25. If you use MPT's payment initiation service to submit a standing order you will be asked to confirm: (i) the amount of the periodic payment, (ii) the recipient of the payments, (iii) the payment start date, (iv) the interval of the payment (e.g. every week or every month) (v) the day on which the payment should be made (e.g. the day of the week or month) and (vi) the end date or that the payments will continue unless cancelled.

2.26. Once you have confirmed the standing order details, you will be redirected to your bank to authenticate yourself and MPT will submit the standing order instruction to your Account Provider.

2.27. Once the standing order has been confirmed as received by your Account Provider, MPT no longer has control over the execution of the standing order payments; this is the responsibility of your Account Provider.

2.28. You will be able to view your standing order via your Account Provider's online banking facility (where supported). If you wish to change or cancel a standing order, you must do so directly with your Account Provider before the deadline provided by your Account Provider and before the next payment is due. If you miss the deadline for cancelling or amending your standing order, your Account Provider may not be able to stop the next payment in time.

2.29. For further information on how you can cancel and amend standing orders you should refer to your Account Provider terms and conditions.

Variable Recurring Payments

2.30. Before receiving our payment initiation service to make variable recurring payments, you will have instructed the Application through which you have accessed our Services to make a payment order for a series of payment transactions to the same payee using MPT (Variable Recurring Payments).

2.31. You will be asked to set up a mandate for the Variable Recurring Payments. This is your consent to MPT to initiate a series of payments which fall within agreed consent parameters which are set by you, which may include: (i) the maximum amount per payment (ii) the frequency of the payments (iii) the maximum amount per frequency (e.g. no more than $50 per day/week/month/year) and (iv) the expiry date of the payment order (VRP Mandate). These details will either be pre-populated for you to review and confirm or you will be able to manually select your limits within the consent parameters. It is your responsibility to ensure that all of the details in the VRP Mandate are correct. You may not be able to recover a payment made pursuant to a VRP Mandate if any details are not correct to an incorrect account or recipient.

2.32. You will confirm any details required in setting up the VRP Mandate and provide explicit consent for MPT to: (i) send those details to your Account Provider; (ii) access your Payment Account; (iii) initiate payment transactions in accordance with the VRP Mandate; (iv) receive information from your Account Provider on the initiation and execution of your instructions; and (v) to pass this information on to the Application through which you accessed our Services.

2.33. When you set up a VRP Mandate you will be asked to select the Payment Account from which you will fund the Variable Recurring Payments and you will be redirected to your Account Provider's website or mobile application in order to authenticate yourself so that your Account Provider knows that you consent to the VRP Mandate and to Variable Recurring Payments being made under the VRP Mandate.

2.34. Once your Account Provider has confirmed authentication, either MPT or the Application through which you accessed our Services will confirm to you that the VRP Mandate has been successfully set up. MPT will then initiate payments under the VRP Mandate in accordance with payment requests made by the Application through which you have accessed our Services. MPT will only initiate a payment under a VRP Mandate where the payment is within the parameters set by you in the VRP Mandate.

2.35. You will be able to view and manage your VRP Mandate through your Account Provider, the Application and MPT. If you wish to withdraw your VRP Mandate then you can do so with your Account Provider, the Application or MPT directly. For further information on how you can withdraw your VRP Mandate through your Account Provider, you should refer to your Account Provider terms and conditions.

3. Eligibility and Availability

3.1. You can only use the Services if:

  • (a) you are 18 or over;
  • (b) your Payment Account and Account Provider are located in a non-US OFAC sanction territory;
  • (c) you provide us with accurate, complete, and up-to-date information, and do not misrepresent your identity or any other information about you;
  • (d) you agree to this Agreement, and to using our Services in accordance with this Agreement; and
  • (e) you agree to comply with all laws and regulations applicable to your use of the Services.

3.2. The Services that are available and the manner in which the Services are delivered may vary depending on the type of device you are using, the type of Payment Account(s) you have, the Account Terms and the Application Terms.

4. Communication

4.1. Where relevant, MPT may send you information and notifications to your email address or mobile number via SMS where MPT considers this appropriate.

4.2. If your contact details (including your mobile phone number or email address) change, you should tell us as soon as you can. You are responsible for maintaining and regularly checking your device or email inbox for information and notifications from MPT.

4.3. You can contact MPT by emailing us at support@moneypoolscash.com.

5. Incorrect or Unauthorised Payments

5.1. If you suspect that an incorrect or unauthorised payment has been made using MPT's payment initiation services you must contact us as soon as possible by emailing support@moneypoolscash.com.

5.2. You should be aware that your Account Provider may contact you directly (and  not through MPT or the Application through which you have accessed our Services) if there is an issue with a payment order submitted through MPT for whatever reason (for example, if there are insufficient funds or an issue with your authorisation). You may need to resolve such matters directly with your Account Provider.

6. Data

6.1. We use your information in line with our End User Privacy Policy (“Privacy Policy”) which can be found on our website at https://moneypoolscash.com. If you are not comfortable with how we handle your information as explained in the Privacy Policy, you should not use our Service.

7. Liability

7.1. MPT will not be liable to refund you for any losses caused by circumstances beyond our control, for example, due to extreme weather, terrorist activity or industrial action.

7.2. MPT is not liable for any contravention of a requirement imposed on it by or under Part 7 of the Payment Services Regulations 2017 where the contravention is due to: a. abnormal or unforeseeable circumstances beyond MPT's control, the consequences of which would have been unavoidable despite all efforts to the contrary; or b. the obligations of MPT under other provisions of EU or national law.

7.3. Nothing excludes or limits our liability for: a. death or personal injury caused by our negligence; b. our fraud or fraudulent misrepresentation; or c. a deliberate breach of this Agreement in a major way that is designed to harm you.

7.4. We are not liable to you for any harm, damage or loss to you arising from the acts or omissions of any third parties, in particular your Account Provider(s) and the Application through which you have accessed our Services.

8. Complaints

8.1. If you have a complaint about our Services, please email us at support@moneypoolscash.com so that MPT can investigate the circumstances for you. We will aim to deal quickly and fairly with any complaints you have about our Services in accordance with our obligations under applicable law. MPT may, however, direct you to: a. your Account Provider, if your complaint relates to the services provided under the Account Terms or involves an incorrect or unauthorised payment in accordance with paragraph 5 above; or b. the Application through which you accessed our Services, if your complaint relates to the products and/or services provided by the Application under the Application Terms.

8.2. If your complaint relates to our Services and we do not resolve it, you may be able to refer it to the UK Financial Ombudsman Service. You can contact the UK Financial Ombudsman by telephone on: from inside the UK: 0300 123 9123 or 0800 023 4567; from other countries: +44 20 7964 0500 on Monday to Friday, 8am to 8pm and on Saturday 9am to 1pm; by post at The Financial Ombudsman Service, Exchange Tower, London E14 9SR; or by email: complaint.info@financial-ombudsman.org.uk. The UK Financial Ombudsman Service is also available in a number of different languages and if you need it you will be put in touch with a translator when you contact the UK Financial Ombudsman Service.

8.3. MPT is not responsible for any complaints or disputes about purchases made using our payment initiation services. You should settle these with the person from whom you bought the goods or services. We are not responsible for the quality, safety, legality or any other aspect of any goods or services purchased using our payment initiation services. Remember that once you have used our payment initiation service to make a purchase, MPT cannot cancel or stop that payment transaction.

8.4. MPT is also not responsible for any complaints or disputes about products and/or services provided by the Application through which you accessed our Services, other third parties, or your Account Provider. You should settle these with the Application, third party, or Account Provider directly.

9. Changes to this Agreement

9.1. The contract between you and MPT which is set out in this Agreement and which governs your use of the Services will continue until cancelled in accordance with this paragraph 9.

9.2. We will give you at least two months' prior written notice via, at a minimum, the contact details you have supplied to us of any intended material change to this Agreement along with the new version of the Agreement.

9.3. If you do not agree with the proposed change(s) you must tell us using the MPT contact details set out in paragraph 4.3. before that change takes effect and you will have the right to terminate this Agreement at any time before the proposed date of their entry into force. If you do not contact us in order to tell us that you do not accept the changes and request to terminate this Agreement you will be deemed to have accepted the change(s) to the Agreement.

10. Termination

10.1. You have the right to cancel the contract between us, which is set out in this Agreement, at any time without notice by contacting MPT using the MPT contact details set out at paragraph 4.3.

10.2. We may cancel the contract with you, with immediate effect, by giving written notice: a. if you repeatedly break this Agreement and fail to resolve the matter to MPT's satisfaction in a timely manner; or b. in the event of your death or incapacity.

10.3. We may cancel this Agreement with you for any reason by giving you at least 2 months' written notice.

11. Governing law and language

11.1. This Agreement is governed by English law and is subject to the non-exclusive jurisdiction of the English Courts.

11.2. This Agreement is in English and all communications with you will be in English.

End User Services Agreement (EEA)

Last Updated: 04 April 2022

Thank you for using MPT!

This End User Services Agreement ("Agreement") is a legal agreement between MoneyPoolsCash UK  ("MPT", "we" or "us") and the end user of our Services ("you", "your"). This Agreement only applies when we provide account information services and payment initiation services (within the meaning of the European revised payment service directive (EU) 2015/2366) to you with respect to a European Economic Area (EEA) payment account, and when we transmit retrieved data and/or the payment status related to such services to third parties on your behalf ("Services"). Such third parties include the owner or provider of the website, desktop and/or mobile application through which you have accessed our Services ("Application").

This Agreement describes the terms and conditions that apply to your use of the Services. You may not access or use the Services unless you agree to comply with all of the terms and conditions in this Agreement. You should therefore read this Agreement carefully and make sure you understand it. If you do not understand any of the terms and conditions of this Agreement, please contact us before using the Services by emailing us at support@moneypoolscash.com

1. MPT

1.1.  If you reside in the EEA:

MoneyPools Technology UK Limited

Attn: Legal

 128 City Road
London, EC1V 2NX
UNITED KINGDOM

 

2. MPT Services

2.1 You have accessed our Services through an Application or within the MPT dashboard (available at https://Moneypoolscash.com/). The products and services provided to you by the Application are governed by a separate agreement between you and the provider of the Application ("Application Terms"). We have no responsibility for the products and services provided to you by or through the Application and will not be liable to you for any harm, damage or loss arising from your use of the products and services provided by or through the Application.

2.2. Our Services will allow you to obtain financial information from your online bank or payment account ("Payment Account") (account information services).

2.3. The terms and conditions that apply to the Payment Accounts that you access through our Services (the "Account Terms") will remain in effect and this Agreement does not change your Account Terms.

2.4. We will not charge you for the use of our Services. Applications or other third parties may, however, charge you for products and services provided to you that make use of the Services provided by MPT under this Agreement. Application providers and other third parties may pay us fees and other amounts in connection with the services we provide to them.

Account information services

2.5. MPT's account information services allow you to access and view information relating to your selected Payment Account within the MPT dashboard (available at https://Moneypoolscash.com/) and the Application through which you have accessed our Services.

2.6. To access the MPT dashboard, you need to create an account with MPT. You also need to ensure that your information is accurate, complete and up-to-date. You must follow best practices to help secure your MPT account and notify us if you learn of any unauthorised access to or use of your MPT account.

2.7. With your explicit consent, we access and display information relating to your selected Payment Account(s) ("Account Information") within the MPT dashboard and transmit such information to the Application through which you have accessed our Services. Such information may include:

(a) financial transaction history, for example, transaction amount, data, description and currency;

(b) financial account details, for example, account number, type, currency and balance; and

(c) financial account holder information, for example, name, address, phone number, and email address.

2.8. Before receiving MPT's account information service, you will have instructed the Application through which you have accessed our Services to retrieve your Account Information using MPT. Upon such an instruction, you will generally be redirected to us.

2.9. Once you are redirected to us, we will ask you to select which Payment Account provider ("Account Provider") you would like us to access Account Information from. You will give your explicit consent to us: (i) accessing your Account Information from the Account Provider you have selected; and (ii) taking the steps outlined in clause 2.12 of this Agreement once we have accessed your Account Information. MPT will request your Account Information from your Account Provider on a periodic basis in accordance with your consent until the consent expires or is withdrawn.

2.10. Please note, you may be redirected to your Account Provider's website or mobile application in order to authenticate yourself so that your Account Provider knows that you consent to us accessing your Account Information.

2.11. Alternatively, in some circumstances, we may ask you to provide us with the login details for your Payment Account. By providing us with your Payment Account login details, you confirm that you have all the necessary rights, permissions and authority to share your login details and Account Information with us, and you grant us explicit consent to use your login details to access your Payment Account to obtain the necessary Account Information on your behalf and at your direction in order to provide you with the Services.

2.12. Once we have accessed your Account Information we may:

(a) share your Account Information with the Application through which you have accessed our Services;

(b) share your Account Information with third parties as directed by the Application through which you have accessed our Services provided, however, that you have explicitly consent to such sharing; or

(c) display your Account Information on the MPT dashboard.

2.13. You agree to us sharing the Account Information we have accessed from your Account Provider with the Application through which you have accessed our Services, and with third parties as directed by that Application provided that in both cases you have explicitly consented to such sharing. Such sharing allows the Application to provide you with products and services in accordance with the Application Terms.

2.14. We do not check the accuracy of the Account Information retrieved from your Account Provider and we rely on your Account Provider to ensure that your Account Information is up to date and accurate.

2.15. We may standardize, categorize, merge, aggregate, and otherwise process your Account Information before displaying your Account Information on the MPT dashboard, sharing it with the Application through which you have accessed our Services, or sharing it with third parties as directed by that Application with your explicit consent.

2.16. You may withdraw or vary your consent for MPT to provide account information services at any time.

3. Eligibility and Availability

3.1. You can only use the Services if:

(a) you are 18 or over;

(b) your Payment Account and Account Provider are located in a country in the EEA;

(c) you provide us with accurate, complete, and up-to-date information, and do not misrepresent your identity or any other information about you;

(d) you agree to this Agreement, and to using our Services in accordance with this Agreement; and

(e) you agree to comply with all laws and regulations applicable to your use of the Services.

3.2. The Services that are available and the manner in which the Services are delivered may vary depending on the type of device you are using, the type of Payment Account(s) you have, the Account Terms and the Application Terms.

4. Communication

4.1. Where relevant, MPT may send you information and notifications to your email address or mobile number via SMS where MPT considers this appropriate.

4.2. If your contact details (including your mobile phone number or email address) change, you should tell us as soon as you can. You are responsible for maintaining and regularly checking your device or email inbox for information and notifications from MPT.

4.3. You can contact MPT by emailing us at support@moneypoolscash.com

5. Data

5.1. We use your information in line with our End User Privacy Policy ("Privacy Policy") which can be found on our website athttps://moneypoolscash.com. If you are not comfortable with how we handle your information as explained in the Privacy Policy, you should not use our Service.

6. Liability

6.1. MPT will not be liable to refund you for any losses caused by circumstances beyond our control, for example, due to extreme weather, terrorist activity or industrial action.

6.2. MPT is not liable for any contravention of a requirement imposed on it by or under any applicable Dutch financial laws and regulation, where the contravention is due to:

(a) abnormal or unforeseeable circumstances beyond MPT's control, the consequences of which would have been unavoidable despite all efforts to the contrary; or

(b) the obligations of MPT under other provisions of EU or national law.

6.3. Nothing excludes or limits our liability for:

(a) death or personal injury caused by our negligence;

(b) our fraud or fraudulent misrepresentation; or

(c) a deliberate breach of this Agreement in a major way that is designed to harm you.

6.4. We are not liable to you for any harm, damage or loss to you arising from the acts or omissions of any third parties, in particular your Account Provider(s) and the Application through which you have accessed our Services.

7. Complaints

7.1. If you have a complaint about our Services, please email us at support@moneypoolscash.com so that MPT can investigate the circumstances for you. We will aim to deal quickly and fairly with any complaints you have about our Services in accordance with our obligations under applicable law. MPT may, however, direct you to:

(a) your Account Provider, if your complaint relates to the services provided under the Account Terms; or

(b) the Application through which you accessed our Services, if your complaint relates to the products and/or services provided by the Application under the Application Terms.

7.2. If your complaint relates to our Services and we do not resolve it, you may be able to refer it to the Financial Services Complaints Board, within three months of receiving our final response regarding the complaint, or within one year after you have submitted your complaint with us.

7.3. MPT is also not responsible for any complaints or disputes about products and/or services provided by the Application through which you accessed our Services, other third parties, or your Account Provider. You should settle these with the Application, third party, or Account Provider directly.

8. Changes to this Agreement

8.1. MPT reserves the right to change this Agreement at any time. MPT will take into account your interests affected by the intended changes and will only make changes that we consider to be reasonable.

8.2. We will give you at least two months' prior written notice via, at a minimum, the contact details you have supplied to us of any intended material change to this Agreement along with the new version of the Agreement.

8.3. If you do not agree with the proposed change(s) you must tell us using the MPT contact details set out in clause 4.3 before that change takes effect and you will have the right to terminate this Agreement at any time before the proposed date of their entry into force. If you do not contact us in order to tell us that you do not accept the changes and request to terminate this Agreement you will be deemed to have accepted the change(s) to the Agreement.

9. Termination

9.1. The contract between you and MPT which is set out in this Agreement and which governs your use of the Services will continue until cancelled in accordance with this clause 9.

9.2. You have the right to cancel the contract between us, which is set out in this Agreement, at any time without notice by contacting MPT using the MPT contact details set out at clause 4.3.

9.3. We may cancel the contract with you, with immediate effect, by giving written notice:

(a) if you repeatedly break this Agreement and fail to resolve the matter to MPT's satisfaction in a timely manner; or

(b) in the event of your death or incapacity.

9.4. We may cancel this Agreement with you for any reason by giving you at least 2 months' written notice.

10. Governing law and language

10.1. This Agreement and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with it or its subject matter or formation shall be exclusively governed by and construed in accordance with the laws of the Netherlands.

10.2. This Agreement is available in the English language. All communications with you will be in English.

MPT Short Message Service (SMS) Terms

Effective Date: November 18, 2022

MPT Inc. (“MPT”) is a financial technology company that securely transfers your financial data from your bank to your apps. MPT may send you SMS messages in order to provide a service to you and/or to confirm your identity by way of two-factor authentication. By agreeing to these Short Message Service Terms (“SMS Terms”), you consent to receive automated SMS messages from MPT, and any of its SMS-related service providers (“service providers”), including through the use of an automatic telephone dialing system, at the telephone number you have provided. Message and data rates may apply. As a general matter, you will receive one message, per request. Carriers are not liable for delayed or undelivered messages.

By agreeing to these SMS Terms, you also authorize your wireless operator to disclose your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber and device details, if available, to MPT and service providers for the duration of the business relationship, solely for identity verification and fraud avoidance. See our Privacy Policy for how we treat your data.

If you do not wish to receive SMS messages from MPT or its service providers, or if you no longer want your wireless operator to share information about you with MPT or its service providers, you agree to reply STOP to any SMS message from MPT or sent on behalf of MPT in order to opt out of the SMS message notifications. You may receive an additional SMS message confirming your decision to opt out. After opting out of SMS messages, you will no longer receive messages from MPT or its service providers. If you wish to receive SMS messages again, you can sign up, similarly to the initial process you did to request the SMS messages.

If you are experiencing issues with the SMS messages from MPT or its service providers, you can reply with the keyword HELP for more assistance, or you can contact support@moneypoolscash.com

Developers

Developer Policy

Effective Date: January 31, 2022

Prior to January 31, 2022, the prior 2022  version of MPT’s Developer Policy will remain in effect.

This Developer Policy ("Policy") provides rules and guidelines that govern access to or use by our developers (“you” or “your”) of the MoneyPoolsCash  API, websites (“Site”), dashboards, related tools, and other products or services (collectively, the "Services") provided by MPT Inc. and its subsidiaries, including MoneyPools technology UK and MoneyPools technology USA  (“MPT”, “we”, “our”, and “us”). Any violation of this Policy may result in suspension or termination of your access to the Services and/or access to end users’ personal and financial information provided by MPT ("End User Data").

By accessing and using the Services, you agree to comply with all the terms of this Policy. This Policy will apply each time you access or use the Services. If you are agreeing to the terms of this Policy on behalf of an organization or entity, you represent and warrant that you are so authorized to agree on behalf of that organization or entity. This Policy is important; please read it carefully.

We may update or change this Policy at any time in our discretion. If we make any changes to this Policy that we deem to be material, we will make a reasonable effort to inform you of such change. If you object to a change, your exclusive remedy is to cease any and all access and use of the Services.

Registration

To sign up for the Services, you must create an account ("Account") by registering on our Site and providing true, accurate, and complete information about yourself and your use of the Services. You agree not to misrepresent your identity or any information that you provide for your Account, and to keep your Account information up to date at all times. It is your responsibility to maintain access to your Account; you may never share your Account information, including your MPT Dashboard password, as well as your API authentication credentials, including your Client Identification Number (“Client ID”) and secret, with a third party or allow any other application or service to act as you.

Compliance with Applicable Law

When using the Services, you agree to abide by all applicable local, state, national, and international laws. You also confirm that you, your business, your employees, your service providers, and any others acting on your behalf adhere to all applicable laws, especially those pertaining to financial data, data protection, privacy and data security.

In addition, you certify that you, your officers, directors, shareholders, direct and indirect parent entities, subsidiaries, and affiliates:

  • are and will remain in compliance with all applicable import, re-import, sanctions, anti-boycott, export, and re-export control laws and regulations (including all such laws and regulations that apply to a U.S. company, such as the Export Administration Regulations, the International Traffic in Arms Regulations, and economic sanctions programs implemented by the Office of Foreign Assets Control (OFAC));
  • are not subject to, or owned by parties that are subject to, sanctions or otherwise identified on any sanctions-related list, including but not limited to lists maintained by the United States government (such as the List of Specially Designated Nationals and Blocked Persons, maintained by OFAC, the Entity List maintained by the U.S. Commerce Department’s Bureau of Industry and Security, and the CAATSA section 231(d) list maintained by the U.S. State Department), the United Nations Security Council, the United Kingdom, the European Union or its Member States, or other applicable government authority; and
  • are not engaging, and will not engage, in activities which may require or permit any applicable government authority to pursue an enforcement action against, or impose economic sanctions on you or us.

The certifications immediately above are not sought, and are not provided, if and to the extent such request or certification would constitute a violation of the EU Blocking Statute, of laws or regulations implementing the EU Blocking Statute in the EU Member States or in the United Kingdom, or any similar anti-boycott, non-discrimination, or blocking provisions foreseen in applicable local laws.

You are solely responsible for ensuring that your use of the Services is in compliance with all laws applicable to you, including without limitation, the rules and guidelines of any system or network that facilitates payments and any security requirements, including under the Payment Card Industry Data Security Standards (PCI-DSS), as may be applicable to you.

Security

You are responsible for securely maintaining your MPT Dashboard username and password, as well as your API authentication credentials, including your Client ID and secret. You agree to notify us promptly at

support@moneypoolscash.com in the event of any breach of security or unauthorized use of your Account or any End User Data. You must never publish, distribute, or share your Client ID or secret, and must encrypt this information in storage and during transit.

Your systems and application(s) must handle End User Data securely. With respect to End User Data, you should follow industry best practices but, at a minimum, must perform the following:

  • Maintain administrative, technical, and physical safeguards that are designed to ensure the security, privacy, and confidentiality of End User Data.
  • Use modern and industry standard cryptography when storing or transmitting any End User Data.
  • Maintain reasonable access controls to ensure that only authorized individuals that have a business need have access to any End User Data.
  • Monitor your systems for any unauthorized access.
  • Patch vulnerabilities in a timely fashion.
  • Log and review any events suggesting unauthorized access.
  • Plan for and respond to security incidents.
  • Comply with relevant rules and regulations with regard to the type of data you are handling, such as the Safeguards Rule under the Graham-Leach-Bliley Act.

Data Storage and Usage

Any End User Data in your possession must be stored securely and in accordance with applicable laws. To the extent applicable, if you use End User Data in an anonymized form then your use of such anonymized data must be clearly and conspicuously disclosed to the End User including a description of how you use such anonymized End User Data.

Account Deactivation

Once you stop using the Services in accordance with any applicable agreement you may have with us, you may deactivate your Account by following the instructions on the Site. We may also deactivate your Account if you have ceased using the Services for three months; your applicable agreement with us terminates or expires; or as reasonably necessary under applicable law. After your Account deactivation, we will deprovision your access to all End User Data associated with your integration.

Even after your Account deactivation, and to the extent permitted under applicable law, we may still retain any information we collected about you for as long as necessary to fulfill the purposes outlined in our privacy policy/statement, or for a longer retention period if required or permitted under applicable law.

Prohibited Conduct

You agree not to, and agree not to assist or otherwise enable any third party to:

  • sell or rent End User Data to marketers or any other third party;
  • access or use the Services or End User Data for any unlawful, infringing, threatening, abusive, obscene, harassing, defamatory, deceptive, or fraudulent purpose;
  • collect and store end users’ bank credentials and/or End User Data other than as required to access or use the Services, as authorized by the end user, as permitted by MPT, and as permitted under applicable law;
  • use, disclose, or retain any “nonpublic personal information” (as defined under the Gramm-Leach-Bliley Act) or “personal information” (as defined under the California Consumer Privacy Act) other than in strict compliance with applicable law;
  • use, disclose, or otherwise process any “personal data” (as defined in Regulation (EU) 2016/679 (General Data Protection Regulation)) other than in strict compliance with applicable law;
  • access or use the Services or access, transmit, process, or store End User Data in violation of any applicable privacy laws or in any manner that would be a breach of contract or agreement with the applicable end user;
  • access or use the Services to infringe any patent, trademark, trade secret, copyright, right of publicity, or other right of any person or entity;
  • access or use the Services for any purpose other than for which it is provided by us, including for competitive evaluation, spying, creating a substitute or similar services to any of the Services, or other nefarious purpose;
  • scan or test (manually or in an automated fashion) the vulnerability of any MPT infrastructure without express prior written permission from MPT;
  • breach, disable, interfere with, or otherwise circumvent any security or authentication measures or any other aspect of the Service;
  • overload, flood, or spam any part of the Services;
  • create developer accounts for the Services by any means other than our publicly-supported interfaces (e.g., creating developer accounts in an automated fashion or otherwise in bulk);
  • transfer, syndicate, or otherwise distribute the Services or End User Data without express prior written permission from MPT;
  • decipher, decompile, disassemble, copy, reverse engineer, or attempt to derive any source code or underlying ideas or algorithms of any part of the Services, except as permitted by applicable law;
  • modify, translate, or otherwise create derivative works of any part of the Services;
  • access or use the Services or End User Data in a manner that violates any agreement between you or the end user and MPT; or
  • access or use the Services or End User Data in a manner that violates any applicable law, statute, ordinance, or regulation.

Suspension and Termination

We reserve the right to withhold, refuse, or terminate access to the Services and/or End User Data in whole or in part where we believe the Services are being accessed or used in violation of this Policy or any other MPT agreement, including MPT’s agreements with any third party partners or data sources of MPT (each, a “Partner”), or where use would pose a risk of harm, including reputational harm, to MPT, its infrastructure, its data, the Services, an end user, or a Partner.

We will use reasonable efforts to notify you via email or other method when deciding to withhold, refuse, or terminate access to the Services and/or End User Data. We may immediately suspend or terminate access without notice if appropriate under the circumstances, such as when we become aware of activity that is a violation of any applicable law or when we determine, in our sole discretion, that harm is imminent.

MPT will not be liable for any damages of any nature suffered by you or any third party resulting from MPT’s exercise of its rights under this Policy or under applicable law.

Reporting Violations

If any person becomes aware of a violation of this Policy, we request that you immediately notify us via email to support@moneypoolscash.com We may take any appropriate action -- including reporting any activity or conduct that we suspect violates the law to appropriate law enforcement officials, regulators, or other appropriate third parties -- in our sole discretion in respect to such violations.

Universal Data Access

MPT promotes an Open Finance ecosystem in which end users own their data (e.g., financial data) and may grant access to such data to third parties. To the extent that you host any such end user data not already accessible by MPT, upon MPT’s reasonable request, the parties agree to cooperate in good faith to negotiate and initiate an arrangement for MPT to access such end user data on behalf of end users.

Miscellaneous

The failure by you or MPT to exercise in any respect any right provided for herein or in any other agreement you may have with us shall not be deemed a waiver of any further rights hereunder.

If any provision of this Policy is found to be unenforceable or invalid, that provision shall be limited or eliminated to the minimum extent necessary so that this Policy shall otherwise remain in full force and effect and enforceable.

Job Candidates

Candidate Privacy Notice (Global)

Effective Date: December 21, 2022

At MPT, we understand the importance of privacy and transparency. The purpose of this Candidate Privacy Notice (“Notice”) is to explain how MPT Inc. and its subsidiaries, including MoneyPools Technology USA Inc. and MoneyPools Technology UK  (collectively, “MPT”, “we”, “our”, or “us”), collect, use, and share personal data and information from and about potential candidates (“you” or “your”) for positions with MPT (“Candidate Information”).

Please note that if you submit your CV/resume or other Candidate Information through our website, we may also collect and process cookies. Additional information regarding the types of cookies we use, why we use them, and how you can control or limit the use of cookies can be found in our Cookie Policy.

Our Data Practices

Information We Collect

We collect Candidate Information provided by (1) you, including through MPT’s Careers page (available at https://MPT.com/careers/), (2) third parties, such as background check providers, recruitment consultants or professional recruitment agencies, or (3) MPT itself through candidate research. We may also derive Candidate Information by creating a profile reflecting your employment preferences, characteristics, behavior, intelligence, abilities, and aptitudes, such as through notes taken as part of the interview process.

We collect the following categories of Candidate Information about candidates we consider for jobs:

  • identifiers and contact information, including your full name, address, phone number, email address, or other contact information;
  • professional or employment-related information, including information in your resume or CV; your work history, certifications, professional licenses, and other experience; and contact details of your former/current employer (when such details contain your personal data);
  • education information, including information about your degrees and training; transcripts; and academic achievements;
  • social networking and similar information, such as social media and public profile information, including URLs related to your LinkedIn, Twitter, GitHub, and Portfolio profiles, and your personal website;
  • in certain regions (like the US) and as permitted by applicable law we may collect demographic and other sensitive information (e.g., race, gender, veteran status, ethnicity, sexual orientation, and disability status); and
  • other information you submit, including additional information provided in an application form, cover letter, or other work product.

If your application progresses, we will also collect the following Candidate Information:

  • information collected as part of the interview process, such as notes taken from your interview (when they contain your personal data); and personal data included in any take-home project;
  • information necessary to schedule your interview, including identifiers such as your address, your Known Traveler Number, and any frequent traveler details;
  • audio and visual information, including photographs for work profiles and security footage gathered on MPT premises.
  • electronic network activity information and usage data, including your use of MPT equipment, devices, software and other assets.
  • details about employment expectations, including, to the extent they contain your personal data, type of employment sought, compensation expectations, willingness to relocate, and other job preferences;
  • (if and to the extent relevant for a specific role) information necessary to run a background check, such as information obtained either from you or through reference and background checks, subject to any further permissions or notifications required and/or permitted by applicable law, usually by way of providing an official Certificate of Good Conduct; and
  • information required to initiate employment, including proof of eligibility to work in a specified country (such as a passport or visa); demographic information such as your date and place of birth, and citizenship; identifiers such as your social security number (where required and/or permitted by law), national insurance number, other government-issued identifier, tax identifiers and related tax information (where required and/or permitted by law), and bank account numbers and related information; benefits eligibility information; and other information you provide for the purposes of starting employment or executing an employment agreement.

How We Use Your Information

We use the Candidate Information collected about you to process your application for employment and to comply with statutory obligations we have in relation to your application, including confirming your eligibility to work in a given location.

We will also use your Candidate Information for the following purposes:

  • administering and processing your application, including verifying your identification, experience and other information you submit and, if your application progresses, any interview information and background check information;
  • communicating with you about your application, including contacting you via phone, email or social media platforms about your application and, if your application progresses, coordinating any interview and background check;
  • assessing and evaluating your suitability for the role for which you have applied, or for other vacancies, including verifying your identification, experience and other information you submit and, if your application progresses, any interview information and background check information;
  • conducting reference and background checks, including criminal records checks, as part of your application, subject to applicable law, including verifying your identification, experience and other information you submit and, if your application progresses, any interview information and background check information;
  • complying with applicable laws and employment-related requirements, including verifying identification information and information required to initiate employment, for purposes such as confirming ability to legally work in a specific location, setting up payroll, withholdings and benefits, and complying with statutory reporting requirements;
  • improving our recruitment process, as permitted by applicable law and only in certain regions (like the US), including by generating analytics using Candidate Information to ensure we recruit a diverse set of candidates;
  • informing you of career opportunities, including other vacancies for which you may be eligible; and
  • for other notified purposes with your consent.

Please note that if you accept employment with MPT, your Candidate Information will become part of your employment record and will be used for employment purposes in accordance with applicable law and any applicable Personnel Privacy Notice. If you are not accepted for a role, however, we may still keep your application, including relevant Candidate Information, to allow us to consider you for other career opportunities with MPT and provided that, if required by applicable laws, we obtained your prior consent for such longer retention of your personal data. If you do not want your information retained in the event you are not offered a position, as applicable, please refer to the following sections below for options that may be available to you: California Candidates Data Protection Rights and UK, EEA, and Canadian Candidates Data Protection Rights.

MPT does not use your personal data for automated individual decision making (including profiling).

How We Disclose Your Information

We disclose your personal data to others as follows, or as otherwise described in this Notice:

  • between and among MPT and our subsidiaries and affiliated entities, as the specific entity you're applying to work for is part of a wider group of companies with headquarters in the United States and offices in various jurisdictions that share human resources and IT systems for processing your application, assessing your suitability for the role, and initiating employment (if applicable);
  • with our data processors and other service providers, including data analytics service providers, background check service providers, and recruitment agencies, in connection with the services they perform for us or on our behalf. Where required, these service providers, partners, or vendors acting on our behalf will be subject to contractual obligations to implement appropriate technical and organizational measures to safeguard the Candidate Information, and to process it only as instructed.
  • to law enforcement, government authorities, regulators, and other third parties, such as courts and other authorities, independent external advisers and internal compliance and investigation teams, if we believe such disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
  • in connection with, or during the negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company, as permitted by applicable law;
  • as necessary to protect MPT, including to establish, exercise, or defend against potential, threatened or actual legal claims;
  • to enforce any contract with you or if we believe that your actions are inconsistent with our policies;
  • to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
  • for any other notified purpose, with your consent or at your direction.

We may also use or disclose aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you, to the extent permitted under applicable law.

Our Lawful Bases for Processing (UK and EEA Candidates Only)

For candidates in the United Kingdom (“UK”) and European Economic Area (“EEA”), our legal basis for collecting, using, and sharing Candidate Information will depend on the information concerned and the context in which we collected or processed it. In general, however, we will normally only collect and process Candidate Information where:

(a) we need to comply with legal obligations applicable to us (such as applicable immigration and/or employment laws and regulations);

(b) we need the information to fulfill our responsibilities in any actual or prospective agreement with you (such as an employment agreement or an offer of employment if you are considered for employment);

(c) the processing is necessary for our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (such as to ensure a safe working environment for all our team members, and to ensure the reliability of our candidates, and otherwise to administer and process your application, or to communicate with you about your application); and

(d) we have your consent to do so (in cases where your consent is truly freely given).

Where we are legally allowed or required to collect and process special categories of data (for example, race), then we will only process such information:

  • where we reasonably need to do so in order to comply with our legal obligations as a prospective employer;
  • where we need to do so in order to be informed of your working capacity;
  • where we need to do so to protect your or another person's vital interests (and we are unable to obtain your consent); or
  • where you have given us your consent (in cases where your consent is truly freely given).

To the extent we rely on consent to collect and process Candidate Information, you have the right to decline your consent or to withdraw your consent at any time by contacting us at support@moneypoolscash.com Withdrawing your consent will not, however, affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted for other purposes in reliance on lawful processing grounds other than consent.

Our Retention Practices

We retain Candidate Information for no longer than necessary to satisfy the purpose for which it was collected and used, as described in this Notice, unless a longer retention period is required or permitted under applicable law. As noted above, however, if you accept employment with MPT, your Candidate Information will become part of your employment record and will be used for employment purposes in accordance with applicable law and any applicable Employee Privacy Notice.

Other Details

International Data Transfers

We operate internationally, and as a result, will transfer Candidate Information across international borders, including from the UK, EEA, and/or Canada to the United States, for processing and storage. To the extent that Candidate Information is transferred from the UK or EEA to territories/countries for which the EU Commission and/or Secretary of State in the UK (as appropriate) has not made a finding that the legal framework in that territory/country provides adequate protection for individuals' rights and freedoms for their personal data, we will transfer such data consistent with applicable data protection laws, including through the use of the EU Commission-approved and/or Secretary of State in the UK approved (as appropriate) standard contractual clauses (as applicable). You can ask for a copy of these standard contractual clauses by contacting us as set out below.

In addition, we are committed to ensure that we comply with any additional requirements or guidelines from the European Court of Justice, data protection law and/or supervisory authorities in relation to the transfer of personal data.

California Candidates Data Protection Rights

The California Consumer Privacy Act or “CCPA”, as amended by the California Privacy Rights Act, affords candidates residing in California certain rights with respect to their Candidate Information. If you are a California resident, this section applies to you.

We collect, or have collected in the preceding 12 months, the categories of Candidate Information listed in the below table from the sources identified in the “Information We Collect” section. For details about the precise data points we collect, or have collected in the preceding 12 months, please see the “Information We Collect” section above. We use and disclose the Candidate Information for the business and commercial purposes listed in the following table, and we disclose the Candidate Information to the recipients also listed in the following table.

We retain the categories of Candidate Information in accordance with the retention practices described above in Our Retention Practices.

MPT does not (1) “sell” or “share” (as those terms are defined by the CCPA) Candidate Information or (2) use or disclose sensitive personal information for any purpose other than what is specified in CCPA section 1798.121(a).

Subject to certain limitations, you have the right to (a) request to know more about the sources of and the categories and specific pieces of Candidate Information we collect, use, and disclose and the categories of third parties to which we disclose such information, (b) request deletion of Candidate Information, (c) request correction of inaccurate Candidate Information, and (d) not be discriminated against for exercising these rights. You may make these requests by emailing us at support@moneypoolscash.com. We will verify your request by asking you to provide information related to your recent interactions with us, such as your phone number and email address. We will not discriminate against you if you exercise your rights under the CCPA.

If we receive your request from an authorized agent who does not provide a valid power of attorney, we may ask the authorized agent to provide proof that you gave the agent signed permission to submit the request to exercise rights on your behalf. In the absence of a valid power of attorney, we may also require you to verify your own identity directly with us or confirm to us that you otherwise provided the authorized agent permission to submit the request. If you are an authorized agent seeking to make a request, please email us at support@moneypoolscash.com

UK, EEA, and Canadian Candidates Data Protection Rights

Under applicable law, you have certain rights in relation to your Candidate Information. These rights can differ by country and province.

Subject to certain limitations and exceptions, those rights include the right to: (i) know whether we process personal data about you, (ii) request access to or rectification of the personal data we process about you; (iii) object to, or request that we restrict, the processing of your personal data; (iv) request that we delete personal data about you; (v) request that we provide the personal data you provided to us in a structured, commonly used and machine-readable format, for transmission to another controller; (vi) revoke consent at any time where our processing is based on your consent; and (vii) lodge a complaint with your local supervisory authority (if you are in the UK, please see this page for contact details for the UK Information Commissioner's Office and if you’re in the EEA, please see this page for contact details).

If you’d like to exercise any of your rights, where applicable, please contact us using the contact information provided below.

Additionally, we are happy to provide you with a more detailed overview of our relevant processing purposes (as well as the related categories of data, retention periods and legal processing grounds) upon your request.

Changes to this Notice

We may change this Candidate Privacy Notice from time to time. If we make any changes, we will update the effective date at the top of this Notice. In addition, if any of the changes are material and impact your Candidate Information, we will also send you a copy via email.

All Audiences

Privacy Statement

Effective Date: December 21, 2022

Thank you for using MPT! We hope you will take some time to read this Privacy Statement carefully.

This Privacy Statement explains the ways MPT Inc. and its subsidiaries, including MoneyPools Technology USA Inc. and MoneyPools Technology UK , (collectively, “MPT”, “we”, “our”, and “us”) collect, use, and share information about you in connection with your access to or use of MPT’s websites, use our products and services (collectively, “Services”), or otherwise interact with us (for example, when you make a customer service inquiry or attend a MPT event or webinar). This Privacy Statement does not apply to information we collect about end users when they connect their financial accounts to an app through MPT. If you’re looking for information as to how we handle data collected under those circumstances, please see our End User Privacy Policy.

Our Data Practices

Information We Collect and Categories of Sources

Information you provide to us. We collect the information you provide directly to MPT. For example, you provide personal information when you create a developer account, fill out our “contact us” form, sign up for our emails, request customer support, enroll in billing, or otherwise communicate with us. The types of information we collect include:

  • identifiers (like full name, email address, postal address, phone number, and date of birth),
  • sensitive information (like a driver’s license number, and taxpayer identification number, financial account information, and social security numbers as necessary to provide services),
  • professional information (like as a company name and title), and
  • any other personal information you choose to provide (including, for example, in developer support messages).

We may also collect certain documentation that contains your photograph or we may require you to verify your identity by providing a photograph or video of yourself. Data collected in this context may be considered biometric data in some states or countries, as noted below. See the special notice for Illinois and Texas residents, below.

Special Biometric Data Notice for Illinois and Texas Residents

For residents of Illinois or Texas, if we require you to provide us with any document that contains your photograph or if you need to verify your identity by providing a photograph or video of yourself, the data derived from your face that we and our service providers collect and process on our behalf may be considered biometric data in some places. Your data will be stored no longer than three years, unless required by law.

Information we receive when you test our technology. Sometimes people who build applications using our Services will use their own login information for their bank account or other financial account to test and evaluate how our technology will appear and operate in their application. If you do this, you should read our End User Privacy Policy for details on how we collect and handle that information.

Information we collect when you use our Services. When you use our Services, we collect the following information about you:

  • Log Information: We collect log files when you use our Services. This includes identifiers and electronic network activity information, like the type of browser you use, when you accessed our Services, the pages viewed, and your IP address.
  • Approximate Location: We determine the approximate location of the device you use to access our Services from your IP address or timezone setting on your device.
  • Information Collected by Cookies and Other Tracking Technologies: We use various technologies like cookies and web beacons in our services to collect personal information. Cookies are small data files stored by your web browser, on your hard drive, or in device memory that help us improve our Services and your experience, determine usage of our Services, and monitor for and detect potential harmful conduct. Web beacons are electronic images that are used in our Services or emails and help deliver cookies. Web beacons count how many times a webpage is visited, and help us understand how our Service is being used and improve it.
    • Please note that we may use third-party cookies for our advertising purposes, as permitted by law and as further described in our Cookie Policy. To change your cookie settings and preferences, including those for targeting and advertising cookies, click the Cookie Preferences link in the footer of the page.

Information we collect from other sources. We also collect information about you from other sources. For example, we may collect information from other members of your company and from vendors that help us identify new customers, including your name, email address, and social media profile URL.

How We Use Your Information

We use the information we collect for the following business and commercial purposes:

  • To operate, improve, and develop our Services;
  • To verify your identity;
  • To bill developers for our Services and to pay them;
  • To comply with law, like for tax reporting purposes;
  • To send you thing like technical notices, updates, security alerts, and messages about your account;
  • To respond to your comments, questions, and customer service requests;
  • To help personalize the Services experience for you;
  • To communicate with you about products, services, offers, and MPT events we offer or sponsor;
  • To monitor and analyze trends, use, and activities in connection with our Services;
  • To detect and prevent fraud, malicious activity, and other illegal activities;
  • To protect the rights, privacy, safety, or property of MPT and others; and
  • For other purposes that we notify you about before or at the time we collect the information.

Our Lawful Bases for Processing in the EEA and UK

MPT only processes your personal information when we have a valid legal basis to do so. Our legal basis for processing the information we collect will depend on what information we collected and the context for processing it. Generally, we only collect and process information where:

  • we need to fulfill our responsibilities and obligations in any contract or agreement with you;
  • to comply with our legal obligations under applicable law;
  • the processing is necessary for our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example, to provide or update our services); and
  • you have given your consent to do so.

How We Share Your Information

We share information about you as follows:

  • With other companies or individuals as service providers, contractors, or business partners to provide services for us and help support our business. We also share information with collection agencies in the event of delinquent payments from our developers.
  • If we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena). This includes disclosure in connection with requests from law enforcement or other governmental authorities;
  • If we believe your actions are inconsistent with our agreements or policies, or to protect the rights, privacy, safety, or property of MPT or others;
  • In the event of a change in ownership or control of all or part of our business (such as a merger, acquisition, reorganization, or bankruptcy);
  • Between MPT and our current and future parents, affiliates, subsidiaries and other companies under common control or ownership; and
  • With your consent or at your direction.

We also collect, use, and share information that has been aggregated, and de-identified in a way so it cannot be used to identify you, for any purpose permitted under applicable law.

We may share Personal Data with third parties or allow them to collect Personal Data from our sites or services, as described above.

This table explains how we have collected and shared personal information in the last 12 months:

CATEGORIES OF PERSONAL INFORMATION

Other Details

Advertising and Analytics Services Provided by Others

We allow third parties, inculding Google Analytics, to provide analytics services and advertisements on our websites. These third parties use cookies, web beacons, and other technologies to collect information about you.

You can find more information about how we use cookies and your related choices in our Cookie Policy.

International Data Transfers

We may transfer the information we collect about you to countries other than the one in which you live, for processing and storage. If we transfer information to a country or territory that has not been deemed to have equivalent privacy and data protection laws of your country we will transfer such data consistent with applicable data protection laws. In particular we may use EU Commission-approved or UK Secretary of State-approved (as applicable) standard contractual clauses, if necessary in combination with additional safeguards. You can ask for a copy of these standard contractual clauses by contacting us as set out below.

Data Retention

We retain your personal data for no longer than necessary to achieve the purposes for which it was collected, unless a longer retention period is required under applicable law.

Your Choices

  • Developer Account Information. You may update information you provide to us as part of your online developer account by logging into your account or by contacting us.
  • Cookies. You can find more information about how we use cookies and your related choices in our Cookie Policy.
  • Marketing Communications. You may opt in and opt out of receiving marketing emails from MPT by following the instructions in those emails. If you opt out, we may still send you other types of emails, such as support, service, and other emails about your account or our ongoing business relationship.

Your Data Protection Rights

You may have rights related to your personal information, including the right to know how we collect, use, or share your information. Additionally, you may have the right to request access to your personal information, as well as to seek to update, delete, or correct that information. We will honor your request to exercise these rights regardless of your location. You will not be discriminated against for exercising these rights.

In certain regions, including the EEA and UK, you may have additonal rights available to you. These rights include the right to: object to, or request that we restrict, the processing of your personal data; revoke consent at any time where our processing is based on your consent; and lodge a complaint with your local supervisory authority (if you’re in the EEA, please see https://edpb.europa.eu/about-edpb/board/members_en, and if you’re in the UK, please see www.ico.org.uk for contact details).

If you are a California resident, subject to limitations and exceptions provided by law, some additional rights may be available to you under the California Consumer Protection Act (“CCPA”). You may also request access to the categories and specific pieces of personal information collected about you in the last twelve months (including personal information disclosed for business purposes); know if any of your personal information has been "sold" or "shared" and to whom; opt-out of any "sales" or "sharing" of your personal information if a business is engaged in "selling" or "sharing" your information; and request a business correct inaccurate personal information. Please note that while we do not sell your personal information we may share it with third parties for advertising purposes as described in our cookie policy.

As described above in “Your Choices,” if you are one of our developers, you can conveniently access your online account information by logging into your account or by contacting us. To otherwise exercise your data protection rights, where applicable, please contact us as described in the “Contacting MPT” section below. You may be required to provide additional information to confirm your identity before we can respond to your request.

If we receive your request from an authorized agent, we may ask for evidence that you have provided the agent with valid written authority to submit requests on your behalf. If you are an authorized agent seeking to make a request, please contact us as described in the “Contacting MPT” section below.

Changes to this Statement

We may update or change this Privacy Statement periodically. If we make any updates or changes, we will notify you by updating the effective date at the top of this Statement. We may also provide notice of any changes through other means, such as placing a notice on our homepage at https://moneypoolscash.com or sending you an email. We encourage you to review the Privacy Statement whenever you access the Services or otherwise interact with us to stay informed about our data practices and the choices available to you.

Contacting MPT

If you have any questions about this Privacy Statement, or our privacy practices generally, please contact us at support@moneypoolscash.com or by mail at:

Cookie Policy

Effective Date: December 30, 2019

This Cookie Policy (“Policy”) explains howMoneyPools technology USA Inc. and its subsidiaries, including MoneyPools Technology UK and MoneyPools Technology RCA., (collectively, “we”, “our”, or “us”), and trusted third parties, use cookies on our websites and other online services (collectively the “Services”), as well as your choices related to those cookies. Please review this Policy to learn more about the types of cookies we use, why we use them, and how you can control or limit the use of cookies.

To find out more about our privacy practices, please refer to our End User Privacy Policy and our Privacy Statement.

What Are Cookies

Cookies are small data files stored on your browser or device, which can be in the form of session cookies (which expire once you close your web browser) or persistent cookies (which stay on your browser for a set period of time or until you delete them). They generally contain information such as website preferences, user settings, and browsing history. This information helps us recognize you as you interact with or revisit our Services.

Cookies may be served by the entity that operates the website you are visiting (“first-party cookies”) or by other companies (“third-party cookies”). For example, we use first-party cookies to remember your settings and preferences, such as language and location. We also integrate third-party analytics cookies, like Google Analytics, onto our websites to help us understand how you are using our websites so that we can improve them.

We also use other technologies that function similarly to cookies. For instance, we use web beacons (also called pixels), which are small images on a web page or in an email. Web beacons collect information about your browser or device and can set cookies. In addition, we use local storage, which allows data to be stored locally on your browser or device.

How We Use Cookies

We use cookies for a number of reasons, like helping us determine the popularity of certain content, improving our Services and your experience, and to better understand your online activity. The cookies we use generally fall into one or more of the following categories:

Category of Cookies

How We Use These Cookies

Essential

These cookies are strictly necessary for our Services to function properly. Some of our Services depend on these cookies and may not work properly, or at all, if they are disabled.

Security

We use these cookies to help identify and mitigate potential security risks.

Preferences

We use these cookies to remember your settings and preferences, such as language and location, when you use our Services.

Analytics

We use these cookies to better understand how you interact with our Services so that we can improve them.

For example, we may use these cookies to determine if you have interacted with certain content or features. We can also use these cookies to learn more about which features are the most popular with our users and where we may need to make improvements.

Advertising

We and our trusted advertising partners use these cookies to display advertisements, to make advertisements more relevant to visitors to our websites, and to track the efficiency of any advertising campaigns, both on our Services and on other websites.

Your Choices

You have the right to choose whether or not to accept cookies. However, since cookies can be an important part of how our Services work, if you remove or reject cookies, this could affect the availability and functionality of our Services.

Below are some options to control or limit how cookies are used on our Services:

Changes to This Policy

We may update or change the cookies (or similar technologies) we use from time to time. The most up-to-date version of this Policy will be posted on our website at https://moneypoolscash.com/, and if we make any changes, we will update the effective date at the top of the Policy. We recommend that you check back periodically for any changes.

Contacting Us

If you have any questions about our use of cookies or this Policy, you can contact us at support@moneypoolscash.com

Modern Slavery Act Transparency Statement

Introduction

At MPT, we are committed to a set of core principles: Impact; Grow together; Embrace openness and positivity; Think rigorously, act with urgency; Make it better; Consumer outcomes via customer love; and Invent tomorrow. In accordance with our core principles, MPT is committed to ensuring there is no modern slavery or human trafficking in our businesses and supply chains.

In compliance with its obligation under s.54 of the Modern Slavery Act 2015 (the "2015 Act"), this statement sets out the steps MPT Inc. has taken in the last financial year to ensure modern slavery and human trafficking is not taking place in any parts of its business or in any of its supply chains. This statement covers the steps taken by MPT Inc. and all of its group subsidiaries, including MoneyPools Technology USA. and MoneyPools Technology UK. (collectively, "MPT" and “our”). Although covered by this statement, we note that MPT Inc.’s wholly-owned subsidiary, MoneyPools Technology USA., does not have an obligation itself to make a transparency in supply statement pursuant to s.54 of the 2015 Act.

Our business

MPT provides technical infrastructure application programming interfaces ("APIs") to companies that develop digital financial applications ("apps") and services to enable consumers and businesses (together, “end users”) to share data from their financial accounts with the apps and services. These apps and services help end users do things like save for retirement, manage their spending, streamline loan applications, or transfer money.

MPT is a leading provider in the UK, Europe and North America, connecting apps and services to consumers and financial services.

MPT is headquartered in Sheridan, Wyoming and has over 20 team members across 6 offices in the US, Europe, UK, Africa, Latin America, Asia.

In the US, MPT is authorised by the Department of the Treasury, United States of America Money Service Business Registration: 31000224635628

Our supply chains

As a technology company, MPT's substantive supply chains are relatively short, and mostly comprised of organisations MPT uses on an on-going basis for services such as Software as a Service ("SaaS") or client installable software. In accordance with our Vendor Management Policy introduced in 24 January 2023 and most recently updated 29 January 2023, during last financial year, we have continued to undertake an on-boarding review of new vendors as well as ongoing monitoring of critical vendors to ensure they are complying with their contractual commitments and not otherwise breaching applicable law. MPT’s relationship with a vendor may be adjusted or terminated in the event that the monitoring reveals deficiencies or material risks that are unacceptable to MPT. This would include any identified risk of modern slavery or human trafficking. We have not identified any potential modern slavery or human trafficking issues to date in our supply chains.

Our policies and contractual controls

MPT strictly complies with applicable laws and regulations, as well as our internal policies and procedures, including our Code of Business Conduct ("the Code"), to ensure we act professionally, transparently and with integrity at all times.

The Code exists to help make clear what we expect of our team members, and to make sure that MPT continues to be a company that others want to do business with and that our team members are proud to be part of. All team members, as well as those doing business with MPT, must abide by and follow this Code, which covers the laws we must obey and offers guidance for navigating the complexities of doing business on a global scale.

In relation to human trafficking the Code states "The United States Government has a zero-tolerance policy regarding trafficking in persons. It goes without saying that MPT strictly prohibits team members from soliciting or engaging in: (a) prostitution, (b) trafficking in persons, and (c) forced labor. MPT will take appropriate disciplinary action — including, but not limited to, termination — against anyone who violates this prohibition. Team members are also under an affirmative obligation to timely report any information received from any source potentially constituting a violation of this policy."

MPT staff are required to read and sign an 'Acknowledgement of Receipt and Review' to confirm they received a copy of the Code and understand and will act in accordance with the rules, policies and procedures in the Code. The Code has continued to apply during the last financial year. It is reviewed and updated (as needed) on an annual basis and was last reviewed and updated on 8 January 2023. Compliance with the Code should, amongst other things, help reduce the risks of modern slavery and human trafficking in the MPT business and its supply chains.

Risk assessment and due diligence

MPT is not aware of any slavery or human trafficking issues within its group businesses or supply chains. In the last financial year, no potential issues of this type have been  identified or reported through internal reporting channels (such as MPT's procedures for reporting suspected violations, illegal or unethical behavior outlined in the Code), audit processes, other whistleblowing channels or otherwise. MPT Inc. has not received any information from any of the entities in the MPT group indicating that there may be any such issues with any of its intra-group suppliers or their supply chains.

Reflecting upon the position as set out above, we consider the risk of slavery or human trafficking in MPT, and its supply chain continues to be low. However, should any potential issue be identified, MPT will act swiftly to investigate and, where necessary, act to ensure there is no modern slavery or human trafficking occurring in its business or supply chains.

Next steps

MPT is committed to continuing to prevent slavery or human trafficking in its business and supply chain.

Approval of this statement

This statement is made in compliance with MPT Inc.'s obligations under s.54 of the Modern Slavery Act 2015 for the financial year ending December 31, 2020. This statement was approved by MPT Inc. on 30 January 2023.

Legal Changelog

Changes to our legal policies

Our mission at MPT is to enable innovation in financial services. As a result, we’re constantly working to improve our existing services, and to develop new services that give developers the ability to create amazing products, and for end users to connect their financial data to their favorite apps.

As we make changes to our services, we review and update our legal policies to reflect those changes. Additionally, we may periodically revise and reorganize the language in our policies to make them easier to follow and understand.

Stay up to date by reviewing highlights from the most recent changes to our policies below. And if you have any questions about the changes, please reach out to us at support@moneypoolscash.com.

 

 

Restricted Jurisdictions For Using MoneyPoolsCash

 UNITED STATES: NEW YORK
AFGHANISTAN
BELARUS
CUBA
ERITREA
IRAN, ISLAMIC REPUBLIC OF
LIBYA
RUSSIAN FEDERATION
SOMALIA
SOUTH SUDAN
SYRIAN ARAB REPUBLIC
VENEZUELA, BOLIVARIAN REPUBLIC OF
NORTH KOREA (DPRK)
PALESTINE, STATE OF
MYANMAR
ZIMBABWE
YEMEN
LEBANON
NICARAGUA
NAURU