Privacy Policy

1.

Introduction

1.1

This Privacy Policy sets out the way in which CurrencyTransfer Limited (“we” or “us) collects and processes Personal Information, as well as the steps we take to protect such information.

1.2

By utilising our Services, you acknowledge that you have read, and agree to, the terms of this Privacy Policy and that you consent to the use by CurrencyTransfer Limited of your Personal Information for the purposes set out in paragraph 3 of this Privacy Policy. If you do not wish to provide your Personal Information on the basis set out in this Privacy Policy, you should not enter the relevant information on the Website or provide your Personal Information to us otherwise. However, if you do not provide your Personal Information, you may not be able to use all of the Services we offer.

1.3

Capitalised terms not defined in this Privacy Policy shall be as defined in the Terms & Conditions.

1.4

This website www.currencytransfer.com is operated by CurrencyTransfer Limited of 7-10 Chandos Street (1st Floor), London, W1G 9DQ. CurrencyTransfer Limited is a company registered with the ICO, with registration number ZA068429.

1.5

Definitions:

1.5.1

You” means the user who is using the services of CurrencyTransfer Limited

1.5.2

“Personal Data” means information that specifically identifies an individual or that is linked to information that identifies a specific individual.

1.5.3

“Visitor” means an individual other than a user, who uses the public area, but has no access to the restricted areas of the Site or Service.

1.6

Principle:
This policy is based on the following data protection principles:

The processing of personal data shall take place in a lawful, fair and transparent way;
The collecting of personal data shall only be performed for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
The collecting of personal data shall be adequate, relevant and limited to what is necessary in relation to the purpose for which they are processed;
The personal data shall be accurate and where necessary, kept up to date;
Every reasonable step shall be taken to ensure that personal data that are inaccurate having regard to the purposes for which they are processed, are erased or rectified without delay;
Personal data shall be kept in a form which permits identification of the data subject for no longer than it is necessary for the purpose for which the personal data are processed;
All personal data shall be kept confidential and stored in a manner that ensures appropriate security;
Personal data shall not be shared with third parties except when necessary in order for them to provide services upon agreement;
Data subjects shall have the right to request access to and rectification or erasure of personal data, or restriction of processing, or to object to processing as well as the right of data portability.

2.

The information we collect

2.1

As part of providing you with the Services, we collect your Personal Information on registering an account. “Personal Information” means any information from which you can be personally identified.

a)

we may collect, store and use information about your computer, mobile device or other item of hardware through which you access the Website and your visits to and use of the Website (including without limitation your IP address, geographical location, browser/platform type and version, Internet Service Provider, operating system, referral source/exit pages, length of visit, page views, website navigation and search terms that you use;

b)

to the extent that we collect and process documentation on behalf of our contributing foreign exchange companies to assist them with complying with various statutory requirements including without limitation anti-money laundering procedures, we may collect a copy of your passport, director and shareholder information, driving licence and evidence of proof of address. These documents contain various elements of personal and company information.

c)

if you choose to subscribe to our service, you will be required to enter your email address;

d)

you may be given opportunities to provide us with other information from time to time;

e)

when you contact us by email or telephone or through any contact form provided on the Website, we may ask you to provide some or all of the following information:

i)

your name;

ii)

your address;

iii)

your email address; and/or

iv)

details of any search effected by you and/or any transaction executed by you with any partner broker.

2.2

Not all the personal information we hold about you will come always directly from you. We may also collect information from third parties such as our partners (Google Analytics, Olark, MailChimp, SendGrid, Hubspot, Pipedrive, & Slack) service providers (Assure Hedge, Corpay Clear Treasury, GC Partners, moneycorp, MoneyNet, Plexus Payments, Privalgo, RationalFX and Sable International) and publicly available websites (i.e Facebook, Google, Twitter, Instagram, LinkedIn), to comply with our legal and regulatory obligations, offer Services we think may be of interest, to help us maintain data accuracy and provide and enhance the Services.

3.

What is the currencytransfer marketplace?

3.1

We will process your Personal Information in accordance with the GDPR and to provide you with the Services. We will process your Personal Information to enable us to:

a)

to provide our services to you on the marketplace;

b)

to assist our foreign exchange companies with providing their services to you;

c)

to manage and administer the Marketplace;

d)

to enable you to use the Marketplace;

e)

to send you newsletters and other relevant and targeted promotional communications;

f)

to notify you of changes we have made or plan to make to the Website and / or Marketplace;

g)

to send you email and trade confirmations and a welcome email as necessary;

h)

to request feedback from you on any transaction effected by you through our platform;

i)

to deal with enquiries, complaints and feedback from you and our service providers;

j)

to provide third parties with statistical anonymised information about our users;

k)

to analysis and improve the services offered on the Website.

3.2

If at any time you wish us to stop processing your Personal Information for the above purposes, then you must contact us and we will take the appropriate steps to stop doing so. Please note that this may mean that your Account will be closed. You may contact us by sending an email to [email protected], and/or [email protected].

3.3

To ensure a good quality of service we may monitor any communication you have with us whether in writing or by electronic mail (“recordings”) or any inbound and outbound calls done by any member of the CurrencyTransfer Limited team. Any recordings remain the property of CurrencyTransfer Limited and will be used only for the purposes listed above.

3.4

In the event that the purposes for processing change, then we will notify you as soon as practicable and seek any additional consent that may be required.

4.

Disclosing your personal information

4.1

Except as described in this Policy, we will not intentionally disclose the Personal Data that we collect or store on the Service to third parties without your prior explicit consent. We may disclose information to third parties in the following circumstances:

4.2

Except to the extent required by any applicable law or governmental or judicial body, we will only disclose such of your personal information to our foreign exchange companies as is required for us or them to perform our or their services to you.

4.3

We will use all reasonable endeavours to ensure that any foreign exchange companies to whom we disclose your confidential information is compliant with the Data Protection Act 1998 (or an equivalent standard) as regards its use and storage of your personal information.

4.4

Once you trade with one of any foreign exchange companies, you give permission for such contributing foreign exchange company to disclose personal information and transactional information to us for the following reasons:

a)

to enable us to track the amount of commission payments due to us from the broker;

b)

to enable us to contact you to request feedback on the transaction; and

c)

to improve our services to you by tailoring the Marketplace to your requirements.

4.5

In the event that we sell or buy any business or assets, we may disclose your personal data and transaction data to the prospective seller or buyer of such business or assets. If substantially all of the assets of CurrencyTransfer Limited are acquired by a third party, personal data and transaction data held by it about its customers will be one of the transferred assets.

4.6

We will disclose your personal information if we are under a duty to disclose or share your personal data and transaction data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or to protect the rights, property, or safety of currencytransfer.com, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.4.10 If at any time you wish us to stop processing your Personal Information for the above purposes, then you must contact us and we will take the appropriate steps to stop doing so. Please note that this may mean that your Account will be closed. You may contact us [email protected].

5.

Limitations on use

5.1

We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. Your principal rights under the GDPR are as follows:.

a)

the right for information (a £10 may be charged to meet our costs in providing you with the details we hold about you);

b)

the right to access;

c)

the right to rectification;

d)

the right to erasure; the right to be forgotten

e)

the right to restrict processing;

f)

the right to object to processing;

g)

the right to data portability;

h)

the right to complain to a supervisory authority; and

i)

the right to withdraw consent.

5.2

If you wish to access or amend any other Personal Data we hold about you, or to request that we delete any information about you, you may contact us by sending an email to [email protected]. We will acknowledge your request within seventy-two (72) hours and handle it promptly. CurrencyTransfer Limited will respond to these requests within a month, with a possibility to extend this period for particularly complex requests in accordance with Applicable Law. We will retain your information for as long as your account is active, as needed to provide you services, or to comply with our legal obligations, resolve disputes and enforce our agreements.

5.3

You may update, correct, or delete your Account information and preferences at any time by accessing your Account. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

5.4

You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some or all of the features and functionality of the Service.

5.5

At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law.

5.6

In accordance with Applicable Law, we reserve the right to withhold personal data if disclosing it would adversely affect the rights and freedoms of others. Moreover, we reserve the right to charge a fee for complying with such requests if they are deemed manifestly unfounded or excessive. CurrencyTransfer Limited may charge a reasonable administrative-cost fee if further copies are requested.

5.7

We may use your personal data for the purposes of automated decision-making when displaying your activity and offers based on your trends and interest. When such processing takes place, we will request your explicit consent and provide you with the option to opt-out. We may also use automated decision making in order to fulfill obligations imposed by law, in which case we will inform you of any such processing. You have the right to object to the processing of your personal data for automated purposes at any time by contacting us at [email protected].

6.

Contacting us

6.2

For full details about the CurrencyTransfer Limited group members and where they operate please contact us at: +44 (0) 20 7096 1036 or [email protected].

6.2

If at any time you believe that we have not adhered to this Privacy Policy, please contact us at [email protected] and we will seek to promptly determine and correct the problem.

7.

Advertising and use of cookies

We collect browser and cookie information when you first navigate to our websites. We use cookies to give you a better customer experience and for use of access. Certain cookies will allow you to leave and re-enter our Websites without re-entering your password. This will be monitored by a web server.

For more information on the use of cookies, how you can control their use, and information relating to our internet-based and mobile advertising, please refer to our cookies policy for more detail.

7.1

Cookies are text files stored, either on a temporary or persistent basis on the hard drive of your computer. Cookies are used for authenticating, session tracking and maintaining specific information about the use and users of the Website (including user site preferences or the contents of electronic shopping carts). Cookie files may also be placed on your computer by Google Analytics for the purposes as set out in this paragraph.

7.2

The data collected by cookies is anonymous. You can delete all cookies that are already on your computer’s hard drive by searching for files with “cookie” in it and deleting them. In addition, if you want to stop cookies from being stored on your computer, you can edit your browser settings so that cookies are blocked. Unfortunately, if you block cookies you may not be able to use the full functionality of the Website. For more information about cookies, please visit: www.allaboutcookies.org

7.3

Web beacons consist of a small string of software code that represents a graphic image request on a Web page or email. There may or may not be a visible graphic image associated with the web beacon and often the image is designed to blend into the background of a Web page or email. Web beacons can be used for many purposes – including site traffic reporting, unique visitor counts, advertising auditing and reporting, and personalization. Web beacons used by www.currencytransfer.com collect only anonymous data.

7.4

In order to improve our Website and the services we offer you, we use (temporary and persistent) cookies, authorised third parties cookies, web beacons and/or other technologies to collect non-personally identifiable data. This non-personally identifiable data helps us to track browsing behaviour, to create specific or tailor-made offers or advertisements, and to monitor and record the visits and use of the Website.

7.5

In order to understand how people use our website and for marketing analysis and quality improvement purposes, we (and/or third party service providers) may collect, record, process and use on an anonymous basis certain information (including the total number of transactions, viewed web pages, referring/exit pages, platform type, date/time stamp information and details like the number and location of mouse clicks on a given page, mouse movements, scrolling activity and the search words you use while being on and using the Website.

7.6

If you register with us or if you continue to use the Website or Marktplace, you agree to our use of cookies.

7.7

You further agree to use the Website and Marketplace only for lawful purposes.

7.8

From time to time you may find links to third party websites on the Website. These links are provided for your information only and are not recommended by www.currencytransfer.com. www.currencytransfer.com has no control over the content of third party sites and acc#epts no responsibility or liability for them or for any loss or damage that may arise from your use of them. When accessing a third party website, you are advised to check such website’s terms of service and privacy policy to ensure compliance with applicable laws.

8.

Minors and children’s privacy

8.1

Protecting the privacy of minors is especially important. Our Service is not directed to children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18. If you are under 18 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Data has been collected on the Service from persons under 18 years of age, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained an Account on the Service, then you may alert us at [email protected] and request that we delete your child’s Personal Data from our systems.

9.

Security

9.1

We take appropriate security measures to protect against loss, misuse and unauthorized access, alteration, disclosure, or destruction of your information. CurrencyTransfer Limited has taken steps to ensure the ongoing confidentiality, integrity, availability, and resilience of systems and services processing personal information, and will restore the availability and access to information in a timely manner in the event of a physical or technical incident.

9.2

No method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or organisational safeguards. If you believe your Personal Data has been compromised, please contact [email protected].

9.3

If we learn of a security systems breach, we will inform you of the occurrence of the breach in accordance with applicable law.

10.

Privacy settings

10.1

Although we may allow you to adjust your privacy settings to limit access to certain Personal Data, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users with whom you may choose to share your information. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorized persons. We have taken the necessary steps to protect your personal information as much as possible in transit by utilising HTTPS on our Website and TLS 1.2 (a strong protocol), ECDHE_RSA with P-256 (a strong key exchange), and AES_128_GCM (a strong cipher).

11.

Data retention and international transfers

11.1

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

11.2

All information you provide to us is stored on our secure servers.

11.3

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

11.4

We transmit personal information using Secure Sockets Layer (SSL) software which encrypts information you input. Further, to the extent that we collect any credit card or bank account information from you, we will only reveal the last four digits of your credit card number when confirming an order. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

12.

Data protection officer

12.1

CurrencyTransfer Limited has appointed a Data Protection Officer (“DPO”) who is responsible for matters relating to privacy and data protection. Currency Transfer’s DPO can be reached at: [email protected];

13.

Changes to this privacy policy

13.1

Please note that this Privacy Policy may change from time to time. If we change this Privacy Policy in ways that affect how we use your Personal Information, we will advise you of the choices you may have as a result of those changes. We will also post a notice that this Privacy Policy has changed.