Last updated: 14th November 2024
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, identity documents, address. When we conduct anti-money laundering and fraud monitoring, prevention and detection activities, we may also receive identity data about you from our business partners, financial service providers, identity verification services, and publicly available sources as necessary to confirm client's identity and prevent fraud.
Contact Data includes email address, phone numbers, etc.
Financial Data includes bank account, financial statements, history of operations, account statements, messages and documents sent or received with the payment.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased, transactions that you have submitted and received, their date, time, amount, currencies used, exchange rate, beneficiary details, details and location of the merchant, device information used to facilitate the payment and the payment instrument used.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website, platform.
Profile Data includes transactions made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, platform, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website, platform or app feature.
However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not purposely collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). However, we may obtain such data by complementary means whenever you supply us with the documents that are required for your identification.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
---|---|---|
To register you as a new customer | (a) Identity (b) Contact (c) Financial | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation |
To respond to your inquiries and fulfil your requests, such as to respond to your questions and comments | (a) Identity (b) Contact (c) Financial (d) Transaction | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to provide good customer service) |
To process and perform your operations including: (a) Manage payments, fees and charges (b) Execute transactions (c) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) To resolve conflicts, manage litigation, resolve issues, and provide you customer service (c) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to provide good customer service; to keep our records updated and to study how customers use our products/services) |
To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To administer and protect our business and our website, platform and app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant website, platform and app content and advertisements to you and measure or understand the effectiveness of the services we provide to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our website, platform and app, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website, platform and app updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests (to develop our products/services and grow our business) |