Polityka prywatności

Main data processing information

Personal data collected via the GlobalTips mobile application and the designated website (together, the “Platform”) is processed by GlobalTips Europe, UAB, a company established in Lithuania, legal entity code 305942984, registered address Naugarduko g. 3-401, LT-03231, Vilnius, Lithuania ("Company” or “GlobalTips”). GlobalTips acts as a data controller of the personal data collected from all categories of Platform users (“Users”), including:

below:

  • Payers (guests) – individuals making payments such as Tips, Bills or Orders;‍
  • Recipients – employees of Merchants (e.g., waiters, baristas, concierges, drivers) receiving Tips or other payments;‍
  • Merchants and their staff – legal entities and their authorized employees (e.g., managers, administrators, accountants) using the Platform for payment acceptance, accounting, and reporting purposes.

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Definitions

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

  • Platform – the GlobalTips mobile application and designated website.
  • User – any individual using the Platform, including:
    • Payer (Guest) – an individual making payments such as Tips, Bills or Orders;
    • Recipient – an employee of a Merchant (e.g., waiter, barista, concierge, driver) receiving Tips or other payments;
    • Merchant and Merchant Staff – legal entities and their authorized employees (e.g., managers, administrators, accountants) using the Platform for payment acceptance, accounting and reporting.
  • Tip – a voluntary monetary amount transferred by a Payer to a Recipient through the Platform, not being payment for goods or services.
  • Bill – a payment request generated by a Merchant for goods or services provided to a Payer.
  • Order – goods or services selected by a Payer via the Platform and payable through the Platform.
  • Loyalty Program – a promotional or bonus scheme established and managed by a Merchant, accessible through the Platform.
  • Payment Method – any payment instrument available on the Platform, including international methods (payment cards, ApplePay, GooglePay) and local payment methods available in the respective jurisdiction.
  • Payment Service Provider (PSP) – licensed acquiring partner processing payments via the Platform, including Stripe (https://stripe.com/legal/privacy) and Fenige (https://www.fenige.com/privacy-policy). These providers act as separate data controllers in relation to payment processing.
  • Service Fee – fee charged by GlobalTips for the use of the Platform, where applicable, displayed to the Payer prior to payment.

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Purposes and legal basis of processing

GlobalTips processes personal data of different categories of Users (Payers, Recipients, Merchants and their staff) for the following purposes:

  • Provision of services – to enable Users to use the Platform (make or receive payments such as Tips, Bills, or Orders, join loyalty programs, administer Merchant accounts).
    Legal basis: performance of a contract (GDPR Art. 6(1)(b)).
  • Payment processing – to transmit payment data to licensed payment service providers (Stripe, Fenige).
    Legal basis: performance of a contract and legal obligations under AML/KYC laws (GDPR Art. 6(1)(b),(c)).
  • Customer service – answering questions, handling complaints, processing feedback.
    Legal basis: legitimate interest (GDPR Art. 6(1)(f)).
  • Feedback administration – collection of IP address, time and other technical data when feedback is submitted.
    Legal basis: performance of a contract (GDPR Art. 6(1)(b)).
  • Loyalty programs – sharing relevant personal data with Merchants to administer loyalty programs.
    Legal basis: User’s consent (GDPR Art. 6(1)(a)).
  • Marketing communications – sending promotional messages from GlobalTips (only with consent) or from Merchants (only with separate User consent).
    Legal basis: User’s consent (GDPR Art. 6(1)(a)).
  • Platform improvement and statistics – analyzing usage, performance, and anonymized statistics (e.g. via cookies).
    Legal basis: User’s consent (GDPR Art. 6(1)(a)).
  • Legal compliance – fulfilling obligations under tax, AML, financial and accounting regulations.
    Legal basis: legal obligation (GDPR Art. 6(1)(c)).

Communications and notifications

The User acknowledges and agrees that the Platform may deliver different types of notifications and communications:

(i) Service notifications – including confirmations of payments, Tips received, payout notifications, technical notices, and other essential communications. These are necessary for the functioning of the Platform and do not require separate consent.

(ii) Administrative notifications – including updates to these T&C, the Privacy Policy, or other legally required notices. These are mandatory and may be delivered via the Platform, email, or push notifications. Continued use of the Platform constitutes acceptance of such updates.

(iii) Marketing communications (GlobalTips) – including offers, promotions, and newsletters. These are delivered via email, push notifications, or SMS only if the User has given explicit prior consent (opt-in). The User may withdraw such consent at any time.

(iv) Marketing communications (Merchants) – Merchants may send marketing or loyalty-related messages (including personalized offers) only if the User has explicitly joined the Merchant’s Loyalty Program or otherwise consented to receive such communications. GlobalTips does not control or endorse the content of such communications and shall not be liable for their accuracy, legality, or usefulness.

(v) Inbox messages – the Platform includes an Inbox section where the User can view messages from GlobalTips or Merchants, including marketing offers. These messages are only visible when the User opens the Inbox and are not delivered as push notifications, emails, or SMS. Inbox messages are considered in-app content and therefore do not require separate opt-in consent under ePrivacy rules.

The User may manage their notification preferences within the Platform settings and may withdraw consent for marketing communications at any time, without affecting the lawfulness of communications already sent.

Categories of personal data we process

GlobalTips processes different categories of data depending on the User’s role on the Platform

For Payers (guests):

  • Identification and contact details (name, email, phone, where provided voluntarily).
  • Payment details (payment card or other Payment Method data, tokenized identifiers, transaction history).
  • Technical data (device type, browser, IP address, cookies, log data).
  • Feedback data (any information voluntarily provided in reviews or comments).
  • Loyalty data (participation in Merchant loyalty programs, rewards, activity history).

For Recipients (employees of Merchants):

  • Identification data (name, position, employer).
  • Payment and payout details (bank account, card number, other payout methods).
  • KYC/AML data (where required by law, e.g., ID document details, date of birth).
  • Technical data (device, browser, IP address, usage logs).

For Merchants and their staff (managers, administrators, accountants):

  • Identification data of the Merchant (company name, registration details, tax ID).
  • Contact data of Merchant staff (names, emails, phone numbers).
  • Business account data (contracts, invoices, reports).
  • Technical data related to access and use of the Merchant dashboard or administrative tools.

For all Users:

  • Service data (transactions, interactions within the Platform).Technical data (cookies, device, browser, log files).

Disclosure of your information

GlobalTips shares personal data only where necessary for the functioning of the Platform and in accordance with this Privacy Policy:

  • Payment Service Providers (PSPs): Payments and payouts are processed through licensed PSPs, including Stripe (https://stripe.com/legal/privacy), Fenige (https://www.fenige.com/privacy-policy), and Finstrument (https://finstrument.pl/static/assets/pdf/FINSTRUMENT_polityka-prywatnosci-20230801.pdf). These providers act as separate data controllers in relation to payment and payout processing. This means that, in addition to this Privacy Policy, the User’s personal data related to payments will also be processed under the privacy policies of the respective PSPs. We encourage Users to review those policies carefully.
  • Merchants: If a User joins a Merchant’s Loyalty Program or submits feedback linked to a Merchant, relevant data (such as name, contact details, loyalty activity, or feedback content) will be shared with that Merchant. In this case, the Merchant acts as a separate data controller.
  • Recipients (employees of Merchants): Data necessary to process and settle Tips or other payouts will be shared with the Recipient’s employer (Merchant) and financial institutions involved in payout processing.
  • Service providers and contractors: GlobalTips may engage trusted third-party processors (e.g., IT hosting, analytics, customer support) who process data on our behalf under data processing agreements compliant with GDPR.
  • Authorities and regulators: Personal data may be disclosed where required by applicable law (e.g., AML/CFT, tax laws) or in response to lawful requests from supervisory authorities, courts, or regulators.

In all cases, we ensure that appropriate safeguards are in place to protect the User’s data and comply with GDPR.

Data retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, and in line with applicable legal requirements:

  • Payers (guests): payment and transaction data are retained for 5 years in accordance with anti-money laundering (AML) and accounting obligations. Marketing and loyalty data are retained until the User withdraws consent.
  • Recipients (employees of Merchants): payout and KYC/AML data are retained for the period required by financial and tax regulations (normally 5–10 years, depending on jurisdiction).
  • Merchants and Merchant staff: business account and contractual data are retained during the contractual relationship with GlobalTips and thereafter for the statutory retention period required under tax and accounting laws.
  • All Users: technical data (e.g., logs, cookies) are retained only as long as necessary for security, analytics or service improvement, and are deleted or anonymised thereafter.

Once retention periods expire, personal data will either be securely deleted or anonymised.

International transfers

GlobalTips processes and stores personal data within the European Economic Area (EEA). We do not transfer personal data outside the EEA.

In the event that such a transfer becomes necessary in the future (e.g., due to the involvement of a third-party service provider), GlobalTips will ensure that it takes place only in compliance with the GDPR, using appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission.

User rights

Under the General Data Protection Regulation (GDPR), all Users of the Platform (Payers, Recipients, Merchants and their staff) have the following rights:

  • Right of access – to obtain confirmation whether we process your personal data and to access a copy of such data.
  • Right to rectification – to request correction of inaccurate or incomplete personal data.
  • Right to erasure (“right to be forgotten”) – to request deletion of your personal data where there is no legal basis for its further processing.
  • Right to restriction of processing – to request limitation of data processing in certain cases (e.g., pending correction or objection).
  • Right to data portability – to receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller.
  • Right to object – to object to processing based on legitimate interests or for direct marketing purposes.
  • Right to withdraw consent – where processing is based on consent (e.g., marketing, loyalty programs), you may withdraw such consent at any time.
  • Right to lodge a complaint – to file a complaint with your local data protection authority.

To exercise your rights, you may contact us at support@globaltips.io.

Cookies and analytics

The Platform uses cookies and similar technologies to ensure proper functioning, improve performance, and provide analytics.

  • Necessary cookies – required for the operation of the Platform (e.g., session management, security). These do not require User consent.
  • Analytics and performance cookies – used to collect aggregated statistics about how the Platform is used, to improve user experience. For this purpose, we use:
    • Google Tag Manager – for managing analytics and marketing tags;
    • Google Analytics – for traffic and usage analysis;
    • Amplitude – for product analytics and user behavior insights.
      Legal basis: User’s consent (GDPR Art. 6(1)(a)).

Users may withdraw or change their consent at any time via the cookie settings on the Platform.

  • Marketing cookies – may be used with the User’s explicit consent to deliver personalized offers and measure campaign effectiveness.

More information about the types of cookies used, their duration, and management options is available in our Cookie Policy.

Contacts and complaints

If you have any questions about this Privacy Policy or about how your personal data is processed, you may contact us at:

GlobalTips Europe, UAB

Naugarduko g. 3-401, LT-03231, Vilnius, Lithuania

Email: support@globaltips.io

If you believe that your data protection rights have been violated, you have the right to lodge a complaint with the competent supervisory authority.

You also have the right to lodge a complaint with your local data protection authority within the European Union.

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