Last updated: February 1, 2019
Gebo Group LLC (“Gebo Group”, “we”, “us” and “our”) respect and
protect the privacy of visitors to our websites and the counterparties
describes our information handling practices when you access content we
own or operate on the websites located at gebo.io (http://www.gebo.io/),
or any other websites, pages, features, or content we own or operate
(collectively, the “Site(s)”) and/or when you use the Gebo Group mobile
app, any Gebo Group API or third party applications relying on such an
API, and related services (referred to collectively hereinafter as
have any questions about this Privacy Notice, please contact us at
By accessing and using our Services, you signify acceptance to the
disclosure of your personal information as described further below. If
you do not agree with or you are not comfortable with any aspect of this
time, and when required by law, we will notify you of changes to this
email (sent to the e-mail address specified in your profile) or by means
of a notice on our Services prior to the change becoming effective.
Gebo Group may provide additional “just-in-time” disclosures or
additional information about the data collection,use and sharing
practices of specific Services. These notices may supplement or clarify
Gebo Group’s privacy practices or may provide you with additional
choices about how Gebo Group processes your personal information.
THE PERSONAL INFORMATION WE COLLECT
Personal information is data that can be used to identify you
personal information that you voluntarily submit to us and that we
anonymized data as it cannot be used to identify you.
sell, rent or loan any personal Information to any third party.
We collect personal information to provide you with our Services.
When we require certain personal information from users it is because we
are required by applicable law to collect this information or it is
relevant for specified purposes. Any information you provide to us that
is not required is voluntary. You are free to choose whether to provide
us with the types of personal information requested, but we may not be
able to serve you as effectively or offer you all of our Services when
you do choose not to share certain information with us.
For example, we collect personal information which is required under
the law to open an account, add a payment method, or execute a
transaction. We also collect personal information when you use or
request information about our Services, subscribe to marketing
communications, request support, complete surveys, or sign up for a Gebo
Group event. We may also collect personal information from you offline,
such as when you attend one of our events, or when you contact support.
We may use this information in combination with other information we
collect about you, as set forth in this Notice.
Here are some specific examples of the types of personal information Gebo Group may collect and how we may use it:
- When you create a profile or use Gebo Group Services, we, or our
affiliates vendors acting on our behalf may collect the following types
of information to meet our legal obligations: your name, date of birth,
social security number, driver number ID, personal ID, address, phone,
email, full bank account details and/or credit card numbers that you
link to your Gebo Group profile or input when you use Gebo Group
Services. Gebo Group will use this information to fulfill your requests
and provide the relevant Services.
- If you seek permissions to raise Digital Currency buy and sell
limits associated with your Gebo Group profile, we may require you to
provide additional information which we may use in collaboration with
service providers acting on our behalf to verify your identity or
address, and/or to manage risk as required under applicable law. This
information may include your date of birth, taxpayer or government
identification number, a copy of your government-issued identification,
or other personal information. We may also obtain information about you
from third parties such as credit bureaus and identity verification
- Whenever you contact us or respond to our communications (e.g.,
email, telephone, written), we receive your contact information and any
other personal information you choose to provide us. Gebo Group will use
such information to fulfill your requests or to provide services.
- You may choose to provide us with access to certain personal
information stored by third parties such as social media sites (such as
Facebook and Twitter). The information we have access to varies by site
and is controlled by your privacy settings on that site and your
In addition, we may collect personal information disclosed by
you on our message boards, chat features, blogs and our other services
to which you are able to post information and materials. Any information
that is disclosed in those forums becomes public information and may
therefore appear in public ways, such as through search engines or other
publicly available platforms, and may be “crawled” or searched by third
parties. It could also be read, collected or used by other users to
send you unsolicited messages. Please do not post any information that
you do not want to reveal to the public at large.
HOW YOUR PERSONAL INFORMATION IS USED
Our primary purpose in collecting personal information is to provide
you with a secure, smooth, efficient, and customized experience. In
general, we use personal information to create, develop, operate,
deliver, and improve our Services, content and advertising, and for loss
prevention and anti-fraud purposes. Examples of how we may use this
- To comply with our legal obligations.
- To prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted user terms.
- To process transactions and send notices about your transactions.
- To verify your identity by comparing your personal information against third-party databases.
- To send administrative or account-related information to you.
- To enforce our agreements with third parties.
- To resolve disputes, collect fees, and troubleshoot problems.
- For quality control and staff training.
- To enhance security, monitor and verify identity or service access, combat spam or other malware or security risks.
- To provide you with Gebo Group Services and support that you request.
- To better understand our counterpartys and end-users and the way they use and interact with Gebo Group Services.
- To provide a personalized experience, and implement the preferences you request.
- To communicate with you about our events or our partner events.
- To customize, measure, and improve Gebo Group Services and the content and layout of our website and applications.
- To deliver targeted marketing, service update notices, and
promotional offers based on your communication preferences (where this
is in accordance with the law).
We will not use your personal information for purposes other
than those purposes we have disclosed to you, without your permission.
From time to time we may request your permission to allow us to share
your personal information with third parties. You may opt out of having
your personal information shared with third parties, or from allowing us
to use your personal information for any purpose that is incompatible
with the purposes for which we originally collected it or subsequently
obtained your authorization. If you choose to so limit the use of your
personal information, certain features or Gebo Group Services may not be
available to you.
INFORMATION FROM THIRD PARTY SOURCES
From time to time, we may obtain information about you from third
party sources as require or permitted by applicable law, such as public
databases, credit bureaus, ID verification partners, resellers and
channel partners, joint marketing partners, and social media platforms.
Public Databases, Credit Bureaus & ID Verification Partners
We obtain information about you from public databases and ID
verification partners for purposes of verifying your identity. ID
verification partners use a combination of government records and
publicly available information about you to verify your identity. Such
information includes your name, address, job role, public employment
profile, credit history, status on any sanctions lists maintained by
public authorities, and other relevant data. We obtain such information
to comply with our legal obligations, such as anti-money laundering
laws. In some cases, we may process additional data about you based on
public interest grounds to ensure our Services are not used fraudulently
or for other illicit activities.
Resellers, Channel Partners, Joint Marketing Partners, and Social Media Platforms
We collect information about your publicly available social media
profile, interests or preferences, and pageview information from some
business partners with which we operate co-branded services or joint
offerings. There are multiple purposes for collecting this information.
First, we process such information to better understand you and/or
maintain and improve the accuracy of the records we hold about you as
well as to position, promote or optimize our Services. In addition, we
may also use this information in conjunction with your browsing habits /
preferences (as obtained from our data partners) and your contact
details, professional information and Gebo Group transaction history to
deliver targeted advertising and marketing to you, where permitted by
applicable law and in accordance with your advertising / marketing
preferences. Second, we also process such information to provide support
to you as part of our contractual obligations to you. Lastly, we
process such information in the public interest because it helps us
monitor, prevent and detect fraud. Once we obtain such information from
third parties, we do not subsequently share it with any other third
parties except as described in this Policy. This information is shared
with Gebo Group’s processors and corporate group as necessary to perform
WHY WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES
We take care to allow your personal information to be accessed only
by those who really need to in order to perform their tasks and duties,
and to share with third parties who have a legitimate purpose for
accessing it. Gebo Group will never sell or rent your personal
information. We will only share your information in the following
- We share your information with third party identity verification
services in order to prevent fraud. This allows Gebo Group to confirm
your identity by comparing the information you provide us to public
records and other third party databases. These service providers may
create derivative data based on your personal information that can be
used solely in connection with provision of identity verification and
fraud prevention services.
- Gebo Group may use Plaid Technologies, Inc. (“Plaid”) or comparable
service provider to verify your bank account and confirm your bank
account balance prior to approving a transaction.
- We share your information with financial institutions with which we partner to process payments you have authorized.
- We may share your information with companies or other entities that
we plan to merge with or be acquired by. Should such a combination
occur, we will require that the new combined entity follow this Privacy
Policy with respect to your personal information. You will receive prior
notice of any change in applicable policies.
- We may share your information with companies or other entities that
purchase Gebo Group assets pursuant to a court-approved sale under U.S.
- We may share your information with law enforcement, and officials,
or other third parties when we are compelled to do so by a subpoena,
court order, or similar legal procedure, or when we believe in good
faith that the disclosure of personal information is necessary to
prevent physical harm or financial loss, to report suspected illegal
activity or to investigate violations of our Counterparty Agreement or
any other applicable policies.
If you establish a Gebo Group profile indirectly on a third
party website or via a third party application, any information that you
enter on that website or application (and not directly on a Gebo Group
website) will be shared with the owner of the third party website or
application and your information will be subject to their privacy
HOW WE PROTECT AND STORE PERSONAL INFORMATION
We understand how important your privacy is, which is why Gebo Group
maintains appropriate physical, technical and administrative safeguards
to protect the security and confidentiality of the personal information
you entrust to us.
We may store and process all or part of your personal and
transactional information, including certain payment information, such
as your encrypted bank account and/or routing numbers, in the United
States and elsewhere in the world where our facilities or our service
providers are located. We protect your personal information by
maintaining physical, electronic, and procedural safeguards in
compliance with the applicable laws and regulations.
For example, we use computer safeguards such as firewalls and data
encryption, we enforce physical access controls to our buildings and
files, and we authorize access to personal information only for those
employees who require it to fulfill their job responsibilities. Full
credit card data is securely transferred and hosted off-site by a
payment vendor in compliance with Payment Card Industry Data Security
Standards (PCI DSS). This information is not accessible to Gebo Group
However, we cannot guarantee that loss, misuse, unauthorized
acquisition, or alteration of your data will not occur. Please recognize
that you play a vital role in protecting your own personal information.
When registering with our Services, it is important to choose a
password of sufficient length and complexity, to not reveal this
password to any third-parties, and to immediately notify us if you
become aware of any unauthorized access to or use of your account.
Furthermore, we cannot ensure or warrant the security or
confidentiality of information you transmit to us or receive from us by
Internet or wireless connection, including email, phone, or SMS, since
we have no way of protecting that information once it leaves and until
it reaches us. If you have reason to believe that your data is no longer
secure, please contact us at the email address, mailing address or
As a global entity, Gebo Group may store, transfer, and otherwise
process your personal information in countries outside of the country of
your residence, including the United States and possibly other
HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION
You are entitled to review, correct, or amend your personal
information, or to delete that information where it is inaccurate. You
may do this at any time by logging in to your profile and clicking the
My Profile tab . This right shall only be limited where the burden or
expense of providing access would be disproportionate to the risks to
your privacy in the case in question, or where the rights of persons
other than you would be violated.
If you close your Gebo Group profile, we will mark your profile in
our database as “Closed,” but will keep your profile information in our
database for a period of time described above. This is necessary in
order to deter fraud, by ensuring that persons who try to commit fraud
will not be able to avoid detection simply by closing their account and
opening a new account. However, if you close your account, your personal
information will not be used by us for any further purposes, nor sold
or shared with third parties, except as necessary to prevent fraud and
assist law enforcement, as required by law, or in accordance with this
RETENTION OF PERSONAL INFORMATION
We store our counterparty’s personal information securely throughout
the life of the counterparty’s Gebo Group profile. Gebo Group will
retain your personal information for a minimum of five years or as
necessary to comply with our legal obligations or to resolve disputes.
COLLECTION & USE OF INFORMATION COLLECTED AUTOMATICALLY
We receive and store certain types of information automatically, such
as whenever you interact with the Sites or use the Services. This
information does not necessarily reveal your identity directly but may
include information about the specific device you are using, such as the
hardware model, operating system version, web-browser software (such as
Firefox, Safari, or Internet Explorer) and your Internet Protocol (IP)
address/MAC address/device identifier.
For example, we automatically receive and record information on our
server logs from your browser, including how you came to and used the
Services; your IP address; device type and unique device identification
numbers, device event information (such as crashes, system activity and
hardware settings, browser type, browser language, the date and time of
your request and referral URL), broad geographic location (e.g. country
or city level location) and other technical data collected through
cookies, pixel tags and other similar technologies that uniquely
identify your browser. We may also collect information about how your
device has interacted with our website, including pages accessed and
links clicked. We may use identifiers to recognize you when you arrive
at the Site via an external link, such as a link appearing on a third
CHILDREN’S PERSONAL INFORMATION
We do not knowingly request of collect personal information from any
person under the age of 18. If a user submitting personal information is
suspected of being younger than 18 years of age, Gebo Group will
require the user to close his or her profile and will not allow buying
or selling digital currencies. We will also take steps to delete the
information as soon as possible. Please notify us if you know of any
individuals under the age of 18 using our Services so we can take action
to prevent access to our Services.
California Privacy Rights
If you are a California resident, you have the right to request
information from us regarding the manner in which we share certain
categories of your personal information with third parties for the third
parties’ direct marketing purposes. California law provides that you
have the right to submit a request to us at our designated address and
receive the following information: (a) the categories of information we
disclosed to third parties for the third parties’ direct marketing
purposes during the preceding calendar year; and (b) the names and
addresses of third parties that received such information, or if the
nature of their business cannot be determined from the name, then
examples of the products or services marketed.
You are entitled to receive a copy of this information in a
standardized format and the information will not be specific to you
individually. You may make such a request by emailing email@example.com.
HOW TO CONTACT US
if you have a complaint, you should first contact us either by emailing
us at firstname.lastname@example.org or by writing to us at Gebo Group LLC., 25 Park Lane South, Jersey City, New Jersey 07310.