We collect information from and about You when You register with us or use our products, or use our website or software applications (collectively, the “Services”).
- When creating an account, we ask You for detailed information, including Your name, email, address, phone and date of birth which we will use to verify Your identity and protect against fraud, among other reasons discussed below.
- We may also gather Personal Information at other times when managing Your Siglo account, such as when You buy top-ups, during support or customer care or during investigations.
- When You use a location-enabled device with our Service, we may collect geographical location data or use various means to determine Your location, such as sensor data from Your device that may, for instance, provide data on nearby cell towers and Wi-Fi access spots.
As You interact with our website or software application, we may automatically collect technical data about Your equipment, browsing actions and patterns in the app or website. We collect this information by using cookies, server logs and other similar technologies. Cookies are small data files stored on Your hard drive by a website. Cookies help us make our website and Service and Your use of them better by allowing us to recognize Your browser and capture and remember certain information. You can also adjust Your browser settings to disable cookies, but it may affect Your ability to use the Service and our website.
We may share and receive data from third parties about You. This may include technical data from analytics and advertising partners like Google, from identity verification providers, as well as from financial institutions.
Siglo only collects the Personal Information that we need in order to offer and support our Services and to meet our legal and regulatory obligations, which may vary depending on our relationship with You and Your use of our Services.
Here is an overview of the Personal Information we collect from or about You:
- Identity verification data: To verify Your identity, we collect Your name, date of birth, address and email, and other similar information. We may require You to provide additional Personal Information to verify Your identity, including Your date of birth, taxpayer or government identification number, or a copy of Your government-issued identification. We may obtain information from affiliated and non-affiliated third parties, such as credit bureaus, identity verification services and other screening services to verify that You are eligible to use our Services and will associate that information with the information we collected from You.
- Application use data: We may collect data on Your interaction and use of our Services. This includes visits to our app or website, sign-up activity, Your wallet activity, or other payment details to enable You to enter into transactions on the Services, and additional information You may disclose to our member support team in order to resolve problems You report.
- Your device data: We collect and process Your internet protocol (IP) addresses, Your app login data, browser type and version if you visit our website, time zone setting and location, operating system and platform and other technology on the devices You use to access this website or any of our software applications.
Marketing data: We collect and process Your preferences in receiving marketing from us, Your email address and where You may have seen Siglo advertisements.
We have set out below some of the ways in which we may use and process Your Personal Information, and which of the legal bases we rely on to do so.
Note that we may process Your Personal Information for more than one lawful ground depending on the specific purpose for which we are using that data. There are rules and regulations across the globe that require we identify our users, including anti-corruption, anti‐bribery, anti‐terrorism, anti‐money laundering and other laws.
- Keeping You informed: It is important for security and financial transparency that we keep You aware of Your transactions and related activity at Siglo. We will send You emails with confirmations, invoices, technical notices, updates, security alerts, legal and support and administrative messages.
- Investigations: Occasionally, we are obliged to look at Your account activity in order to check and protect against fraudulent, unauthorized or illegal behavior.
- Legal user care: We strive to make sure You can easily use our products with no headaches, but sometimes You need help. Our user care team will occasionally need access to Your account data in order to fix any issues or answer Your questions.
- Managing and improving our Services: We like to understand how our members engage and use Siglo in order to make sure Siglo is the best it can be. This process includes combining different account, transactional, marketing and other data to analyze the effectiveness and performance of our Services.
- Communicating with You: We want You to be aware of product updates, news, events, and promotions and, if You consent, we will send You information, including regular personalized emails, to keep You up to date with all things Siglo.
- Business operations: We may need to use Your personal information for our business operations, including internal training and administration, legal compliance, to enforce our legal rights, to protect third party rights, and in connection with a business transition such as a merger, an acquisition by another company, or a sale of all or a portion of our assets.
- Website and software applications: We use data analytics to improve our website and software applications, activities and operations, products/services, events, etc.
Third party data: If You authorize applications or third-party integrations on or using our Service, these parties may receive detailed information about Your account, Your use of the Service, transaction history or even the ability to take actions on Your behalf. Information collected by these applications or third-party integrations are subject to their terms and policies.
We collect and use your Personal Information as described above in order to:
- Present our website and software application and their content in the best possible way for You and on the basis of our legitimate interests to keep our website and software applications updated and relevant, including to develop our business outreach and business operations, and for marketing purposes and to develop marketing strategies;
- Support our business processes including our information technology (“IT”), electronic communications and electronic documents storage, management and transmissions, to fulfill our contractual obligations toward You, or, if not applicable, on the basis of our legitimate interests to provide the best user service we can, to support our business operations, administration, IT services, and network security, and to prevent fraud;
- Perform customer services, including compliance services, to fulfill our contractual obligations toward You, and to comply with legal and regulatory requirements applicable to us (including the need to prevent and combat money laundering);
- Enforce our legal rights, or to protect the rights of third parties it is in our or a third party’s legitimate interest to do so; and
- For all other purposes, to comply with our legal and regulatory obligations.
We have implemented security measures to prevent Your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
We protect Your Personal Information by maintaining physical, electronic and procedural safeguards, incorporating tested security technologies, in compliance with applicable laws. We may use network safeguards such as firewalls and data encryption, enforce physical access controls, and authorize access to Personal Information only for those people who require access to fulfill their job responsibilities.
In addition, we limit access to Your Personal Information to those employees, agents, contractors and other third parties who have a need to know for business purposes. They will only process Your Personal Information on our instructions and they are subject to a duty of confidentiality. Those with access to Your Personal Information are required to keep all of Your Personal Information confidential.
It is important to note that security risks exist and no organization can genuinely promise You otherwise. Bad actors may defeat even the most carefully considered and implemented safeguards. We cannot guarantee that your data will not be stolen or lost, even with the safeguards that we have in place.
We sometimes share Your information internally between employees and contractors of Siglo (including those based outside the EEA), in particular in connection with activities undertaken jointly or in common with such group members and/or provide information technology and system administration services and to undertake management reporting.
We do not sell, trade or otherwise transfer to third parties Your Personal Information, other than to third parties who assist us in operating our Service, conducting our business or supporting our users. We require that those third parties agree to keep this information confidential and secure on the same conditions and protection levels we provide to You as a member.
We may also release Your information to certified and authorized law enforcement officials when we believe release is appropriate to comply with the law, enforce our terms or policies, or protect the rights, property, or safety of Siglo, our members or others.
Finally, in the event of the sale or transfer of ownership of Siglo or the Services, Your data would be shared with the new owners.
Siglo is incorporated in Gibraltar and headquartered in Mexico. Many of our affiliates and third-party service providers are based outside the EEA, so processing of Your Personal Information will involve a transfer of Your Personal Information outside the EEA and may be maintained or accessed in servers or files located in countries outside the EEA, including in the United States.
By voluntarily providing Your Personal Information on or via the Siglo app or website, You consent to its transfer, processing and storage in the United States other countries outside the EEA, some which have not been deemed by the EEA to have “adequate” privacy safeguards.
Under the General Data Protection Regulation (“GDPR”), Siglo is the controller and responsible for any of our software application or website and any EEA Personal Information that is provided to us via our software application or website. On occasions, for certain processing activities, an affiliate of Siglo may act as a data processor for Siglo or another affiliate of Siglo.
Whenever we transfer Your EEA Personal Information out of the EEA, we ensure a similar degree of protection is afforded to it. We may share data with organizations and countries that:
- The European Commission say have adequate data protection.
- We’ve agreed standard data protection clauses with.
Please contact us at [email protected] if You are located in the EU and want further information on the specific mechanism used by us when transferring EEA Personal Information out of the EEA.
You have the right to:
- Access the Personal Information we store about You or to request a copy of it.
- Request that we correct inaccurate data about You.
- Ask us to delete or block Your data, although for legal reasons we cannot always do this.
- Withdraw Your consent to receive marketing emails.
To do any of the above simply email a request to: [email protected]
Under the relevant privacy laws of the EEA (including the European Union’s GDPR) You may have a number of important rights with respect to Your Personal Information. For further information on each of those rights, including the circumstances in which they apply, please see the Guidance from the UK Information Commissioner’s Office on individual’s rights under the European Union’s GDPR.
Siglo maintains reasonable procedures to help ensure that Your Personal Information is reliable for its intended use, and is accurate, complete and current.
- We will only retain Your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, as well as other factors required by GDPR, Know Your Customer, Anti-Money Laundering or other laws to which we are subject.
When it is no longer necessary to retain Your Personal Information, we will securely delete it, subject to applicable law and regulations.
- In some circumstances, we may anonymize Your Personal Information (so that it can no longer be associated with You) for research or statistical purposes in which case we may use this information indefinitely without further notice to You.
- If You request that we stop sending You marketing materials, we will continue to keep a record of Your contact details and the appropriate information to enable us to comply with Your request not to be contacted by us.
Please be aware that we may keep Your Personal Information for five years or more from the date You cease to use the Services, depending on applicable law or regulations in the jurisdictions we operate.
We are concerned to protect the privacy of children aged 13 or under. We do not knowingly solicit or collect information from individuals under the age of 13. If we become aware that a child under the age of 13 has provided us with Personal Information, we will close the account and restrict their information. If you believe that we might have collected Personal Information from a child under the age of 13, please contact using the information below.
In compliance with applicable laws, we will send You personalized marketing information, including by emails, and such information may include product and service updates, industry news, our events, activities and offers, about our business and personnel and tips. We may combine Your Personal Information such as age, transaction history and account usage to improve the value and specificity of these communications.
You can ask us to stop sending You marketing messages or information through email at any time by following the opt-out links on any marketing message sent to You or by contacting us at [email protected] at any time.
In the event You opt out of receiving these marketing messages or publications, this will not apply to Personal Information collected by or provided to us in connection with a specific purpose, request, order, event or activity or any dealings with You.
If You would like to unsubscribe from any email publication You can also click on the ‘unsubscribe’ button at the bottom of the relevant email publication.
It is important that the Personal Information we hold about You is accurate and current. Please keep us informed if Your Personal Information changes during Your relationship with us.
The Siglo App or website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about You. We do not control any third-party content and are not responsible for their privacy statements. When You leave our app or website, we encourage You to read the privacy statement of the content You visit.
You can direct any questions or complaints about the use or disclosure of Your Personal Information to us by contacting us as set out below. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of Your Personal Information as soon as possible.
If You are a resident of the European Union and are dissatisfied with the resolution of Your complaint in respect of Your EEA Personal Information, You may contact the EU data protection authority in Your jurisdiction using the contact details provided here for further information and assistance.