Globnk Privacy Policy

Last Updated: [17.03.2025]

1. Introduction

Globnk (“we”, “us”, “our”) is committed to protecting your privacy and ensuring the security of your personal data. We comply with the EU General Data Protection Regulation (GDPR) the Personal Data Protection Act of 10 May 2018, as well as the Electronic Communications Law of 12 July 2024 and other relevant data protection laws in all our data handling practices . This Privacy Policy explains how Globnk PL sp. z o.o. (registered in Poland at Bartycka 22B/21A, 00-716 Warsaw) collects, uses, shares, and protects your information when you use our services. We strive to use clear and plain language so you can easily understand our practices and your rights.

2. Data Collected

We collect various types of information necessary to provide our payment and cryptocurrency services and to comply with legal requirements. This includes:

Personal Identification Data: Information that identifies you, such as your full name, date of birth, nationality, contact details (email address, phone number, physical address), and government-issued identification details (e.g. passport or ID card number) . For corporate clients, we also collect company identification information and details of beneficial owners .
Financial Data: Financial information needed to process transactions, like your bank account number or payment card details, and, where applicable, cryptocurrency wallet addresses. We may also record your tax identification number or other financial identifiers for compliance.
Transaction History: Details about payments and transactions you make through our platform, including sender and recipient names, amounts, dates, currency, and related details . This helps us maintain accurate records of your transactions and assist with customer service and auditing.
Compliance and Verification Data: Information collected for Know Your Customer (KYC), Anti-Money Laundering (AML), and other compliance checks. This includes identity verification documents (such as copies of your ID or passport), proof of address (e.g. utility bills), source of funds declarations, and results from checks against fraud prevention and cybersecurity compliance databases . We only collect what is necessary to meet our legal obligations in these areas.
Marketing and Analytics Data: Data about your use of our website and services for analytics and marketing purposes. For example, this may include how you interact with our platform, pages visited, features used, and responses to marketing campaigns. We gather some of this information via cookies and tracking technologies (such as Google Analytics and other third-party tools), which can collect device information, browser type, IP address, and browsing behavior . This helps us understand user engagement and improve our services.
Other Information You Provide: If you communicate with us (for instance, via customer support inquiries, surveys, or feedback forms), we will collect the information you choose to give us, which may include personal data. We only use this information for the purposes for which you provide it.

Globnk will always inform you when personal data is requested, and we limit collection to what is adequate, relevant, and necessary for the purposes described in this policy.

3. How Data is Used

We use your data to operate our platform, provide you with services, fulfill legal requirements, and improve your user experience. Specifically, Globnk uses collected data for:

Transaction Processing: To facilitate payments, stable token purchases, conversions, and transfers on our platform. For example, we use your financial and identification data to execute transactions and ensure funds reach the intended recipients.
Compliance and Legal Obligations: To perform identity verification (KYC) and due diligence checks required by law, including anti-money laundering and counter-terrorist financing regulations. Your data is used to screen against compliance databases and verify that transactions are lawful. We also use data to meet record-keeping obligations, tax reporting, and to respond to lawful requests by authorities.
Fraud Prevention and Security: To protect our platform and you from fraud, cyber threats, or unauthorized access. We may analyze transaction patterns and use compliance data to detect and prevent fraudulent activities or security incidents. This can include cross-verifying information with fraud prevention services or cybersecurity databases to ensure your account’s integrity.
Providing and Improving Services: To deliver the services you request, maintain your account, and personalize your experience. For instance, we use transaction history and usage data to provide customer support, troubleshoot issues, and develop new features. Analytics data helps us understand how users interact with our platform so we can improve functionality and user-friendliness.
Marketing (with Consent): If you have given us your consent, we use your contact information and preferences to send you promotional communications about new features, products, or special offers. We may tailor these marketing messages based on your usage patterns or transaction history. You can opt out of marketing at any time (see Withdrawing Consent below). We do not send you marketing communications unless you have agreed to receive them.
Aggregated Analytics: We may use data about how individuals use our services in an aggregated and anonymized form (so it does not identify you personally) to compile statistical reports. This helps us and our partners understand trends and business performance, and improve our services and marketing strategies.

We ensure that any use of your data is supported by a valid legal basis under GDPR (such as fulfilling a contract with you, complying with a legal obligation, our legitimate interests in improving and securing our services, or your consent, as applicable). We do not use your personal data for any purpose that is incompatible with the purposes outlined above, and we do not engage in automated decisions about you without human involvement, unless explicitly allowed by law and with your knowledge.

4. Data Sharing

Globnk does not sell your personal data. However, in order to provide our services and comply with laws, we may share your information with trusted third parties under strict conditions. Such data sharing is done only as necessary and with adequate safeguards. The types of entities with whom Globnk may share user data include:

Financial Partners and Banking Platforms: We work with licensed financial institutions (such as banks, payment processors, and electronic money institutions) to execute transactions on your behalf . For example, if you transfer funds, we share necessary information with the banking partner or payment network to process the payment. We also may share certain data with financial partners who help us offer services like the Globnk stable token or card programs. This sharing is limited to what is required (e.g. your name, account number, and transaction details) and is done in line with banking regulations.
Cryptocurrency Exchanges and Blockchain Networks: If you engage in cryptocurrency transactions (such as converting stable tokens to other digital currencies), we may need to share relevant data with partner cryptocurrency exchanges or blockchain service providers to complete the transaction. This could include wallet addresses and transaction details, ensuring the exchange can execute the trade and maintain compliance.
Compliance and Cybersecurity Databases: Globnk may share your information with third-party services that assist with compliance checks, fraud prevention, and security. For instance, we might send identification details to identity verification services or check your data against anti-fraud and AML databases to ensure you are not on sanction or watchlists (PAYMENT SERVICE – Terms 1.0.docx). Similarly, if required, we share data with cybersecurity firms to investigate or prevent security incidents. This is done to comply with legal obligations and to protect against fraud or illicit activity .
Marketing and Analytics Partners: We utilize third-party companies to help us with analytics and, if you have consented, marketing. These partners (such as Google Analytics, and services provided by companies like Name.com or Holister) may receive certain analytics data (e.g. cookies identifiers, IP address, and usage data) to analyze how users use our site or to assist in delivering marketing messages. They act on our instructions and do not use this data for their own purposes. For example, Google Analytics helps us understand website traffic and usage patterns . We ensure any marketing analytics firm we use complies with privacy laws and offers opt-outs for data collection (see Cookies and Tracking Technologies and Withdrawing Consent sections).
Cloud Storage and Service Providers: Globnk relies on reputable cloud computing and storage services to host our platform and data (for example, secure data centers or cloud infrastructure providers). Your personal data may be stored on cloud servers operated by third parties on our behalf. We choose providers who implement strong security measures and, where possible, keep data within the EU. When we use providers outside the EEA, we implement appropriate safeguards for international data transfers (see International Data Transfers below). These service providers are bound by contracts that require them to protect your data and only process it according to our instructions.
Affiliates and Business Partners: If Globnk is part of a corporate group, we may share data with our affiliated companies for internal administrative purposes or to provide you with integrated services. All such entities are required to uphold the privacy protections described in this policy.
Legal and Regulatory Authorities: Where required by law or necessary to protect our rights, we may disclose personal data to law enforcement agencies, regulators, government authorities, or courts. For example, we might need to share data to comply with a subpoena, tax reporting requirements, or an investigation into illegal activity . We will only do so after verifying the request is legally valid and limit the data shared to what is necessary.

In all cases of data sharing, Globnk remains responsible for the protection of your data. We ensure that any third party that receives your data is obligated to safeguard it through appropriate data protection agreements or contracts. Whenever personal data is transferred to a processor or partner, we take steps to ensure they handle your data with the same level of care and security that we do.

5. User Rights

As a user of Globnk, especially if you are located in the European Union or a jurisdiction with similar laws, you have certain rights regarding your personal data under the GDPR and other data protection regulations. We respect and uphold these rights, which include:

Right to Access: You have the right to request a copy of the personal data we hold about you and to obtain information about how we process it. This means you can ask us to confirm whether we are processing your personal information and provide you with a full overview of the data and purposes.
Right to Rectification: If any of your personal data is incorrect or incomplete, you have the right to request that we correct or update it without undue delay . For example, if you change your email address or discover an error in your data, you can ask us to fix it. We encourage you to keep your account information up to date, and we will also notify relevant third parties (like those we’ve shared data with) about the corrections when required.
Right to Erasure (Right to be Forgotten): You may ask us to delete your personal data in certain circumstances. For instance, if the data is no longer necessary for the purposes it was collected, or you have withdrawn your consent and we have no other legal ground for processing, you can request erasure. We will honor valid requests for deletion, provided that we are not required to retain the data for legal reasons (such as ongoing contractual relations or compliance obligations).
Right to Data Portability: You have the right to receive the personal data that you have provided to us in a structured, commonly used, and machine-readable format, and to have that data transmitted to another controller where technically feasible . In practice, this means upon request we can provide you with your data (for example, basic account information and transaction data) in a format like CSV or JSON so that you can port it to another service. This right applies when our processing is based on your consent or on a contract with you and is carried out by automated means.
Right to Restrict Processing: You can request that we limit the processing of your data in certain situations . For example, if you contest the accuracy of your data or have objected to processing (see below), you may ask that we stop using the data (beyond simply storing it) until the issue is resolved. When processing is restricted, we can still keep your data but will not use it for other purposes without your consent, except as allowed by law.
Right to Object: You have the right to object to certain types of processing. Notably, you can object to processing of your personal data for direct marketing at any time, and we will stop using your data for that purpose once you object. You can also object if we are processing your data based on our legitimate interests or for a task in the public interest, and you feel it impacts your rights—unless we have a compelling legitimate ground to continue.
Rights Related to Automated Decision-Making: Globnk does not make any solely automated decisions (without human involvement) that produce legal or similarly significant effects about you, unless such processing is necessary for a contract, authorized by law, or you have explicitly consented. If we ever implement automated decision-making (for example, automated fraud screening), you have the right to request human intervention, to express your point of view, and to contest the decision.
Right to Withdraw Consent: If we are processing your personal data based on your consent, you have the right to withdraw that consent at any time . Withdrawing consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, and it will not affect processing of your data under other legal bases. (We provide details on how to withdraw consent in the Withdrawing Consent section below.)
Right to Lodge a Complaint: If you believe your privacy rights have been violated or you are not satisfied with our handling of your data, you have the right to lodge a complaint with a supervisory data protection authority in your country. For EU users, this is typically the Data Protection Authority in the country of your residence or work, or in the location where an issue occurred. We encourage you to contact us first so we can address your concerns, but you are free to contact the authority directly.

You can exercise any of these rights by contacting us (see Contact Information at the end of this policy). We will respond to your requests as soon as possible and no later than required by law (generally within one month for GDPR requests). Please note that some rights are subject to certain legal exceptions – for example, even if you request deletion, we might retain data if required for legal compliance. In any case, we will explain the outcome of your request and the reasoning behind it. There is no fee for exercising your rights, except in rare cases of excessive or unfounded requests, in which case we may charge a reasonable fee or refuse the request in accordance with law.

6. Data Retention

Globnk retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or to comply with applicable legal, accounting, or regulatory requirements. Given the financial nature of our services, we are subject to laws that require certain records to be kept for specific periods. In particular, we will retain your data for upto seven (7) years after your client relationship with us has ended, unless a longer retention is required or justified by other legal obligations. This retention period aligns with financial regulations and audit requirements in many jurisdictions (for example, keeping financial transaction records for around 7 years for regulatory compliance and audits).

This means that after you close your account or otherwise stop using Globnk’s services, we will securely store your data for seven years before deletion. During this period, your data is archived and only accessed if necessary for purposes such as resolving disputes, complying with investigations, enforcing our agreements, or meeting tax and accounting obligations. After the seven-year retention period (or any longer period mandated by law) has elapsed, we will delete your personal data or anonymize it so that it can no longer be associated with you.

In some cases, different types of data may be kept for shorter periods. For example, marketing data (for users who never became customers) might be kept only for a couple of years, and web analytics logs may be retained for a shorter duration unless needed for security. We regularly review the data we hold and erase or anonymize information that is no longer needed.

Please note, if you exercise your right to deletion, we will delete the data that we are not legally required to keep. However, we will retain the data we must preserve by law (for instance, KYC information and transaction records needed under anti-money laundering laws) for the full required period even if that extends beyond your account closure. Rest assured, any retained data remains subject to this Privacy Policy and applicable data protection laws. We store it securely and do not use it for any purpose other than compliance.

7. Personal Data of Individuals Under 18 Years of Age

The Globnk’s services are not intended for individuals under the age of eighteen (18). If you are under 18, you may not use the Globnk’s services or provide us with your personal data. If the Globnk becomes aware that personal data of an individual under 18 is being processed, such data may be promptly deleted. If you suspect that the Administrator may have such data, please contact the Administrator immediately.

8. International Data Transfers

Globnk primarily stores and processes personal data on servers located within the European Union to provide a high level of data protection. However, due to the global nature of financial services and the partners we work with, some of your data may be transferred to, or accessible from, countries outside the European Economic Area (EEA). For example, if you initiate or receive a global payment, or we engage a service provider based outside the EU (such as a cloud service or an analytics provider), your data might be processed in a non-EU country.

When we transfer personal data outside of the EU/EEA, we take steps to ensure that an equivalent level of data protection is maintained as under EU law. These steps include:

Adequacy Decisions: Where possible, we transfer data to countries that the European Commission has determined offer an adequate level of data protection. This means those countries’ laws are deemed essentially equivalent to EU data protection standards.
Standard Contractual Clauses: In cases where we send data to a country that is not deemed adequate, we will use European Commission-approved Standard Contractual Clauses (SCCs) in our agreements with the receiving party . These clauses are legal commitments that require the recipient to protect your data according to GDPR standards.
Additional Safeguards: We may implement further measures such as encryption in transit and at rest, strict access controls, and periodic audits of our partners, especially if data is stored or processed in jurisdictions with differing privacy laws. Our contracts with processors also include commitments to uphold privacy, and where applicable, we conduct Data Protection Impact Assessments for high-risk transfers.
Transparency and Accountability: We maintain a record of cross-border data transfers and ensure that there is a valid legal basis for each transfer. Our staff are trained to handle personal data securely regardless of where it is accessed.

Despite our efforts to keep data within the EU, by using Globnk’s services you acknowledge that your data may be transferred internationally as described. We will always strive to minimize unnecessary cross-border data flows. If we need to transfer your information to international organizations or foreign authorities (for example, for global compliance purposes), we will do so in strict accordance with data protection laws and only when required or permitted by those laws.

If you would like more information about international data transfers or specific safeguards we apply to overseas processors, you can contact us (see Contact Information). We will be happy to provide further details, as we want you to feel confident about how your data is handled globally.

9. Cookies and Tracking Technologies

Like most online platforms, Globnk uses cookies and similar tracking technologies to ensure our website functions properly, to enhance your user experience, and to collect analytics information. Cookies are small text files that are stored on your device (computer, smartphone, etc.) when you visit our site. They serve a variety of purposes which we outline below, along with the third-party tools we use that may set their own cookies or tracking technologies:

Essential Cookies: These are necessary for the operation of our website. They enable core functionality such as security, network management, and accessibility. For example, essential cookies keep you logged in during your session and help us verify your identity. Without these cookies, services you have asked for (like accessing secure account areas) cannot be provided.
Preference Cookies: These cookies allow our site to remember your choices and preferences (such as language or region) to provide a more personalized experience. They may store settings like which dashboard view you prefer, so you don’t have to reset it every time.
Analytics Cookies: We use analytics and performance tracking tools to understand how users interact with our website. Specifically, we use Google Analytics – a web analytics service provided by Google – to collect information about usage of our site. Google Analytics cookies gather data such as what pages you visit, how long you stay, how you arrived at our site, and what you click on. This information is aggregated and does not directly identify you; it helps us analyze website traffic and user behavior to improve our services. (Google may also receive and process this information for its own analytics purposes; however, we have configured Google Analytics to anonymize IP addresses where possible, to enhance your privacy.) You can learn more about how Google Analytics works and how to opt out in the Withdrawing Consent section below.
Third-Party Analytics and Tracking: In addition to Google Analytics, we may incorporate other third-party services that use cookies or similar technologies. For example, Name.com may provide services related to our domain or site hosting that involve cookies (for instance, if our site is built on a Name.com platform, certain Name.com cookies might track performance or user interactions). Holister is another third-party tool we use for user experience analysis and/or marketing analytics. Holister’s cookies might track how you navigate our site or respond to certain features, which helps us optimize the platform. We also use cookies from services like Holister to measure the effectiveness of marketing campaigns and to understand our audience better. Any third-party cookie use is reviewed by us to ensure it aligns with our privacy commitments, and these third parties are obligated to protect your data.
Marketing and Advertising Cookies: Currently, Globnk does not host third-party ads on our platform, but if we engage in any marketing tracking (such as remarketing via Google or social media pixels), we will use cookies that track your browsing to tailor advertising content. Such cookies would only be used with your consent. They record your visit to our site, the pages you have visited, and the links you have followed. If we ever use advertising cookies, we will update this policy and ask for your consent through the cookie banner.

Upon your first visit to our website (and periodically thereafter), we will present you with a cookie consent banner or pop-up, allowing you to accept or reject non-essential cookies. You can choose to allow all cookies, reject non-essential ones, or customize your preferences. Your choice will be remembered in a cookie itself. Please note that if you disable certain categories of cookies (like analytics or preference cookies), some features of the site may not function optimally, but the site should still be generally accessible.

In addition to our banner, you can manage cookies through your browser settings. Most web browsers let you control cookies via their settings preferences, including deleting cookies or blocking them entirely. However, blocking all cookies might hinder some features of our service.

For more information on the specific cookies and tracking technologies we use (including their names, purposes, and lifespans), please refer to our separate Cookie Policy or cookie list, if available. We aim to be transparent about our use of cookies and will update our cookie disclosures as we add or remove partners or change how we use these technologies.

10. Withdrawing Consent

Where Globnk is relying on your consent to process your data (such as for marketing emails or for using non-essential cookies/analytics), you have the right to withdraw that consent at any time . We make it easy for you to manage your consents:

Marketing Communications: If you have consented to receive promotional emails or newsletters, you can unsubscribe at any time by clicking the “unsubscribe” link included in the footer of any marketing email we send you. Once you opt out, we will stop sending you marketing emails. Please note that even if you opt out of marketing messages, we may still send you transactional or service-related communications (for example, notifications about your account, security alerts, or updates to our terms) as these are not promotional. You can also withdraw consent or update your marketing preferences by contacting us directly via email or through your account settings if such an option is provided.
Cookies and Analytics: When it comes to analytics or tracking tools like Google Analytics, you have several options to withdraw or prevent your data from being used e.g.You can adjust your cookie preferences on our website at any time by accessing our cookie settings (for example, through a “Cookie Preferences” link on our site) and disabling analytics cookies.
Other Consents: If at any point we seek your consent for something not covered above (for example, participating in a testimonial or survey), you can always revoke that consent by contacting us. We will honor such requests and, as applicable, cease the processing in question.

Withdrawing consent will generally not have negative consequences on your use of Globnk’s core services. However, if you withdraw consent for certain cookies or tracking, some functionality (like personalized content or performance analytics) might be limited. If you withdraw consent for marketing, you simply won’t receive promotional communications from us moving forward.

Importantly, once you withdraw consent, we will stop the processing that was based on consent. Any processing that does not rely on consent (for example, processing necessary for providing the service or for compliance with law) will continue as usual. Withdrawal of consent does not affect the lawfulness of processing done before the withdrawal.

If you have any trouble changing your preferences or opting out, please contact us and we will assist you. Our goal is to ensure you have full control over your personal data.

11. Security Measures

Globnk takes the security of your personal data very seriously. We employ high-level security measures to protect your information from unauthorized access, disclosure, alteration, or destruction. This includes a combination of technical safeguards, organizational policies, and physical security controls designed to keep your data safe. Some of the key security practices we follow include:

Encryption: We use encryption technology to protect personal data during transit and at rest. When you enter sensitive information (such as financial details) on our platform, that data is encrypted using industry-standard protocols (like TLS/SSL) for transmission. We also encrypt stored data in our databases or cloud storage to render it unreadable to unauthorized persons.
Access Controls: We restrict access to personal data to authorized personnel only. Globnk employees, contractors, and agents who need to process your data for the purposes of their job must abide by strict confidentiality obligations. We employ authentication measures, such as strong passwords and two-factor authentication, to prevent unauthorized access to systems where personal data is stored. User accounts are protected by passwords, and we urge you to choose a strong password and keep it confidential.
Monitoring and Testing: Our systems are regularly monitored for vulnerabilities, and we use firewalls and intrusion detection systems to guard against external threats. We also conduct periodic security assessments and penetration testing through qualified experts to probe our defenses. These proactive measures help us identify and fix potential security issues before they can be exploited.
Organizational Policies: Globnk has internal policies and training in place to ensure staff handle personal data securely and in compliance with this Privacy Policy. We limit what data can be downloaded or transferred, and maintain protocols for responding to security incidents. In the unlikely event of a data breach that poses a risk to your rights and freedoms, we will notify you and the relevant authorities as required by law.
Third-Party Security: When we engage third-party processors or partners to handle data on our behalf (such as cloud providers or analytics services), we ensure they meet stringent security requirements. We review their security certifications and practices, and include data protection agreements that obligate them to protect your information to high standards.

While we cannot guarantee absolute security (no method of transmission or storage is 100% secure), we follow best practices and continually update our security measures to deal with new threats. We also encourage you to play a role in protecting your data: please use unique and strong passwords for your Globnk account and notify us immediately if you suspect any unauthorized access or suspicious activity.

Our commitment to security is ongoing – we are regularly improving our safeguards to keep up with industry standards and evolving cyber threats. We will not detail every measure here (to maintain security effectiveness and because techniques may change), but rest assured that protecting your data is a top priority for Globnk.

12. Changes to the Policy

Globnk may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. If we make changes, we will post the revised policy on our website and update the “Last Updated” date at the top. For any significant or material changes, we will take additional steps to notify you: for example, we might send you an email notification or display a prominent notice within the Globnk platform. We will provide you with reasonable advance notice of material changes when required by law.

Your continued use of Globnk’s services after the effective date of the updated Privacy Policy will constitute your acceptance of the changes. However, if any changes require your consent (for example, if we plan to use your data for a new purpose that requires consent), we will obtain your consent as necessary. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

If you do not agree with the changes to the Privacy Policy, you should discontinue use of our services and contact us to address any concerns. We archive previous versions of our Privacy Policy and will make them available for review upon request, so you can see how our policy has evolved.

13. Contact Information

Your questions, comments, and concerns about privacy are important to us. If you have any questions about this Privacy Policy or about how Globnk handles your personal data, or if you wish to exercise your data protection rights, please contact us using the details below:

Email: You can reach our privacy team at support@globnk.com. Please include the subject line “Privacy Inquiry” or “Data Protection Request” to ensure it reaches the correct team. If you are exercising a specific GDPR right, you may use that in the subject (for example, “Right of Access Request”).
Postal Mail: If you prefer to write to us, you can send mail to our registered office address:
Globnk PL sp. z o.o.
Attn: Privacy Officer/Data Protection Officer
Bartycka 22B, apt. 21A
00-716 Warsaw
Poland
Contact Form: We may provide a contact form on our website for privacy inquiries. If available, you can submit your request through that form, and it will be directed to our data protection team.

We will respond to your inquiry as soon as possible, and no later than within the timeframes required by law. If you are contacting us to exercise your rights, we might need to verify your identity for security purposes (to ensure we don’t disclose data to the wrong person). This could involve asking for additional information.

Globnk is grateful that you trust us with your financial and personal data. We are committed to working with you to promptly resolve any issue or concern regarding privacy. If you feel that we have not addressed your complaint satisfactorily, remember you also have the right to contact your local data protection authority.

Thank you for reading our Privacy Policy. Your privacy and security are our priority, and we will continuously work to ensure that we deserve your trust.