Information on data processing policy
Last Modified 23.05.2018
We encourage you to read information below carefully. We applied all effort to make it as comprehensive as possible. If you still have any questions, we will be happy to explain to you any terms or points which are still unclear to you.
By providing personal data to us via Agents, you consent to our processing of your data in accordance with this policy and our General Terms and Conditions. If you do not agree to the terms set out in these policy, please do not continue to use our services.
If you wish to withdraw already given consent to our processing of your data at any time, please, address a relevant request to the contacts given below.
We are obliged to keep the personal data minimum of 10 years according to Anti Money Laundering and Terrorist Financing regulations for financial institutions in the European Union. If there are other legal reasons for keeping personal data longer than the specified time, the data keeping period may be extended by the time necessary to fulfill the legal obligations of the company or in some cases for an indefinite period. Legal reasons include but not limited to the requirements of regulators and other law enforcement agencies, lawsuits.
Your personal information will be processed, stored and protected according to the EU General Data Protection Regulation – GDPR, Regulation 216/679/EU, effective 25.05.2018.
This policy will be regularly reviewed and updated.
1. Who will hold your information?
Your information will be held by Mayzus Financial Services Limited, trading as MoneyPolo (“MoneyPolo”, “our”, “us” or “we”). We are registered in England and Wales (No. 06721866) and regulated by the Financial Conduct Authority as a payment institution for the provision of payment services. Our registered office address is 42 Upper Berkeley, St. Marylebone, London W1H 5QL. For the purposes of the to the EU General Data Protection Regulation – GDPR, Regulation 216/679/EU, effective 25.05.2018 (“GDPR”) the data controller is MoneyPolo.
2. What information we collect and why?
Once given you have given your consent to Terms of Business and consent on your personal data processing, you enter into business relations with MoneyPolo and conclude an agreement with MoneyPolo. All the services, data collection and further data processing are based on this agreement.
- 2.1 We may receive personal information and contact details from you, such as but not limited to name, date of birth, nationality, place of birth, your photographs, address, telephone number, email address and bank account details. If you are a corporate entity, we may also collect your registered name, registered office address, memorandum of association, articles of association, list of current shareholders, list of current directors, annual return, identification and proof of address of beneficial owners, directors and any power of attorney.
We collect and process the above-mentioned information when you:
- 2.1.1 open an account with us;
- 2.1.2 use the services made available on our site;
- 2.1.3 complete any surveys we ask you to complete for research purposes (although you will never be obliged to respond to them);
- 2.1.4 enter any competitions or participate in any promotions sponsored by us;
- 2.1.5 respond to our direct marketing activities;
- 2.1.6 correspond with us by post, email or via the “Send Message” and “Send Feedback” forms on our site; or
- 2.1.7 report a problem with our site.
- 2.2 We may collect information about you contained in any documents you provide to us for the purposes of verifying and processing your application for an account with us.
- 2.3 We may collect information about your transactions and your activities when you apply for an account with us and carry out a transaction using our services. Such information may include without limitation the identity of the other party to the transaction, their location and the currency and amount of the payment.
- 2.4 We may receive information about you from third parties, including but not limited to credit reference agencies and other providers of public information.
- 2.6 If you contact us by telephone or in writing, we may keep a record of the content of that correspondence or phone call.
- 2.7 We may monitor or record communications with us in which you take part:
- 2.7.1 to assist us with the development of our services;
- 2.7.2 to train our staff;
- 2.7.3 if so requested by order of the Court, regulatory body or law enforcement organisation.
- 2.8 With regard to each of your visits to our site, we may automatically collect the following:
- 2.8.1 technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- 2.8.2 information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
- 2.9 Our services are not intended for use by those under the age of 18 and we do not knowingly collect personal information from those who are under the age of 18. If you are under the age of 18, please do not apply for an account with us, provide any personal information to our site or use our site in any other way.
3. What do we do with your information?
- 3.1 We use information held about you to:
- 3.1.1 administer and process your application for an account with us;
- 3.1.2 administer and maintain our customer accounts and records;
- 3.1.3 provide our services to you and ensure secure transaction processing;
- 3.1.4 improve our site to ensure that our service continues to be the most appropriate service for your needs and that content from our site is presented in the most effective manner for you and your computer;
- 3.1.5 help us in our efforts to keep our site safe and secure;
- 3.1.6 verify your identity and to respond to any query that you may raise with us;
- 3.1.7 fulfil any contractual obligations we have with you;
- 3.1.8 monitor and assess to prevent fraud, money laundering, financing terrorism, market abuse, embargo and other financial crimes
- 3.1.9 send registered users of our site email communications from time to time regarding updates and changes to our services and any technical, operational, administrative and legal notices important to our site which we consider essential.
- 3.2 We do not disclose your personal information to any third parties for direct marketing purposes. However, we may share personal data with third party companies and organisations contracted to us to help supply, maintain or facilitate our site or our services. These third parties may include (without limitation) IT support teams, banks, exchange facilities having control or jurisdiction over us and electronic search providers carrying out anti-money laundering and sanction checks for us.
- 3.3 We may use your data to contact you for market research purposes and to provide you with information about our services, offers and promotions which may be of interest to you. If we do so, we will contact you by email or SMS. If you do not want us to use your data in this way, you can withdraw prior consent to use your data for marketing purposes any time by clicking unsubscribe button in the promotion email, you can also contact us using the contact details below or ask our agents at their offices.
- 3.4 We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our website users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
- 3.5 Your information may be used by us for the purpose of research and statistical analysis and internal customer service monitoring.
- 3.7 We may disclose your personal data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
- 3.8 We may disclose your personal data to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or if we reasonably believe that disclosure of your personal data to third parties is necessary in order to enforce or apply our Terms of Website Use and other agreements; or to protect our rights, property, or safety or that of our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
- 3.9 We are required by statute to make a disclosure to the Financial Intelligence Unit where we know or suspect that a transaction involves money laundering or terrorist financing. Where we are required to make a disclosure in relation to one of your transactions, we will not be able to inform you about the disclosure or our reasons for making it.
- 3.10 We may disclose your personal data in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets and their advisers. If our business is sold your details will be passed onto the new owners of the business.
- 3.11 We may employ the services of other parties for dealing with various matters in connection with our site and the services provided on our site. The providers of such services may have access to your personal data.
- 3.12 The period of use of the personal data supplied by you will not be longer than we deem necessary but may be unlimited.
4. Keeping information up to date and secure
- 4.1 If any of the information that you have provided to us changes, for example if you change your email address or other contact details, or if you wish to close your account with us, please update your account details on our site or, alternatively, contact us using the contact details below.
- 4.2 Where we have given you (or where you have chosen) a user name and password which enable you to access certain parts of our site, you are responsible for keeping your user name and password confidential. We ask you not to share this information with anyone.
5. Where we store your data
- 5.1 All information you provide to us is stored on our secure servers. We have in place a level of security appropriate to the nature of the data and the harm that might result from a breach of security. 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 to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features in diligent effort to prevent unauthorised access.
- 5.2 The data that we collect from you may be transferred to 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. Such staff maybe engaged in, among other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing outside the EEA. We will take all steps reasonably necessary to ensure adequate security for your personal data.
7. Your Rights
We process your data fairly, correctly and in accordance with the law. Below you will find information on the rights you have connected with your data. If there is something unclear, we are prepared to explain it to you. Please, use the contacts given below.
You may have certain rights under the GDPR in relation to the information that we hold about you. These rights include the rights set out below:
- 7.1 You are entitled to have access to your personal data. You may request by writing to us (at the address given below), details of your information which we hold and the purposes for which it is held. We will provide this information within 40 days of your request, subject to any routine processing continuing between that time and the time of response. You may be charged a reasonable fee (as permitted by the GDPR) for this information.
- 7.2 You are entitled to request that we stop using information about you for the purpose of direct marketing (i.e. the communication to you (by whatever means) of any advertising or marketing material);
- 7.3 You are entitled to require us to ensure that no decision taken by or on behalf of us and which significantly affects you is based solely on the automated processing of your information, for the purpose of evaluating such matters as, for example, your creditworthiness, reliability or conduct;
- 7.4 You are entitled to require a correction of errors in the personal information held about you. If we disagree that information is inaccurate you are entitled to apply to ask the court for an order that such erroneous information be rectified, blocked, destroyed, or erased.
- 7.5 You are authorised to withdraw your consent at any time in those cases where we have requested your consent to carry out the data processing. The withdrawal of your consent will not inﬂuence the processing of your data throughout the period when you have validly issued the consent and it will likewise not inﬂuence the processing of your data on other legal grounds, if they apply (for example, the adherence to the legal obligations or for the purposes of our justified interests).
- 7.6 You can refuse to provide us with the personal data which we request from you. If, however, this involves information which must be compulsorily provided, we will be unable to provide you with the associated services.
- 7.7 You are entitled to restrict marketing. If you have given us consent for marketing or if commercial oﬀers are sent to you from us on other justified grounds, you may withdraw your consent at any time using contact details below. Please note that, if you limit marketing, we can still continue to contact you because of our services, i.e. we can still use your contact information for the purpose of sending service reports and for purposes other than marketing.
- 7.8 The data protection legislation gives the customers the right to access the personal data that MoneyPolo has about them. Unless there is a particular reason, MoneyPolo approves customer requests regarding disclosure of their information to third parties after checking that the applicant is the person concerned. Additionally, in case of inaccurate information that we know about, we will apply the necessary changes to it.
- 7.9 If you as a customer require information or require information to be disclosed to a third party, MoneyPolo is entitled to charge you a minor fee for any administrative work and costs involved in producing this information.
7.10 You are entitled to the right to lodge a complaint with a supervisory authority
Information Commissioner’s Office (ICO) ico.org.uk
ICO helpline Telephone: 0303 123 1113
8. Third-Party Websites
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
10. Contact Details
Mayzus Financial Services Ltd
Office 404, 42 Upper Berkeley St,
London W1H 5QL, United Kingdom
Tel: +44 (0) 20 339 74034
Fax: +44 (0)20 8397 4818
Business hours: 9.00 am to 6.00 pm, Monday to Friday