Data Protection and Privacy Policy
Data protection registration
Exchangeo Limited is registered with the Information Commissioner’s Office under the Data Protection Act (DPA). Our registration number is ZA045757, and the register can be checked here.
Terminology
The terms “we”, “us” and “our” shall refer to Money Mover and the terms “you”, “your”, “user” or “customer” refer to users of any services provided by Money Mover. As used in this policy, the singular shall include the plural and references to “he” shall include both the masculine and the feminine.
Introduction
Money Mover is committed to protecting personal data. This Data Protection and Privacy Policy describes how and why we collect and use personal data. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy statement or as stated at the point where we collect the data.
Personal data is any information relating to an identified or identifiable living person. Money Mover processes personal data to enable us to provide a currency exchange and money transfer service, maintain our accounts and records to the required legal and regulatory standards and to promote our services. The means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.
When collecting and using personal data, our policy is to be transparent about why and how we process it.
Collection of personal data
Our policy is to collect only the minimum amount of personal data necessary to carry out the services we provide for the the purposes agreed with our users. Where we collect personal data for email marketing purposes, all new subscribers are required to go through a ‘double opt-in’ process to confirm their consent unambiguously and minimise false or fraudulent subscriptions.
Use of personal data
We use personal data for the following purposes:
- Providing our services
We provide a range of services which require us to process personal data in order to carry out our customers’ instructions. For example, we require personal data, such as the identity of the user, his or her IP address, the reason for the payment and the details of the recipient, in order to carry out an international payment on his or her behalf. - Administering, managing and developing our businesses and services
We process personal data in order to run our business, including:- managing our relationship with customers;
- developing our business and services (such as identifying customer needs and improvements in service delivery);
- maintaining and using IT systems;
- hosting, or facilitating the hosting of events; and
- administering and managing our website, systems and applications
- Security, quality and risk management activities
We have security measures in place to protect our and our customers’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We monitor the services provided to customers for quality purposes, which may involve processing personal data stored on the relevant customer file. We have policies and procedures in place to monitor the quality of the service we provide and manage risks associated with them. We collect and hold personal data as part of our customer engagement and acceptance procedures. As part of those procedures we carry out searches using publicly available sources (such as credit checks, internet searches and sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations and check that there are no issues that would prevent us from providing our services to a particular customer (such as sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues). - Providing our users with information about us and our range of services
Our customers may consent to the use of their contact details to receive relevant content such as newsletters, announcements, offers, thought leadership and invitations to events from us. If you decide that you no longer wish to receive marketing content from Money Mover please note that we may still need to send you emails with factual and transactional information relating to the services that we provide to you. - Complying with any requirement of law, regulation or a professional body of which we are a member
As with any provider of financial services, we are subject to legal, regulatory and professional obligations. We need to maintain certain records to demonstrate that our services are provided in compliance with such obligations and those records may contain personal data.
We are continually looking for ways to help our customers and improve our business and services. We may use personal information that we receive in the course of providing our services for other lawful purposes, including analysis to better understand a particular issue, industry or sector, provide insights to our customers, to improve our business, service delivery and offerings and to develop new technologies and offerings. To the extent that the information we receive in the course of providing our services contains personal data, we will de-identify the data prior to using the information for these purposes.
