Privacy and Cookie Statement

1 Policy statement

1.1 Transpaygo Limited is registered as a data controller with the Information Commissioner’s Office (“ICO”) with Registration number: ZA143304.

1.2 Throughout the course of our activities we will collect, store and process personal data about our customers, website users, employees, contractors, suppliers, subcontractors, payment and delivery services, business partners, analytics providers and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.

1.3 Data users are obliged to comply with this policy when processing personal data on our behalf. Any breach of this policy may result in disciplinary action.

2 About this policy

2.1 The types of personal data that Transpaygo Limited (“we”) may be required to handle include information about current, past and prospective customers, website users, employees, contractors, suppliers, subcontractors, business partners, analytics providers, others that we communicate with and third parties. The personal data, which may be held on paper or on a computer or other media, is subject to certain legal safeguards specified in the Data Protection Act 1998 (“the Act”) and other regulations.

2.2 This policy sets out the basis on which we will process any personal data we collect from data subjects, or that is provided to us by data subjects or other sources.

2.3 This policy does not form part of any employee's contract of employment and may be amended at any time.

2.4 This policy sets out rules on data protection and the legal conditions that must be satisfied when we obtain, handle, process, transfer and store personal data.

2.5 The Data Protection Compliance Manager is responsible for ensuring compliance with the Act and with this policy. If you have any questions about how we protect or use your data, please email us at [email protected] with the header “PRIVACY POLICY”. Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Data Protection Compliance Manager.

3 Definition of data protection terms

3.1 Data is information which is stored electronically, on a computer, or in certain paper-based filing systems.

3.2 Data subjects for the purpose of this policy include all living individuals about whom we hold personal data. A data subject need not be a UK national or resident. All data subjects have legal rights in relation to their personal information.

3.3 Personal data means data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual (for example, a name, address or date of birth) or it can be an opinion about that person, their actions and behaviour.

3.4 Data controllers are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed. They are responsible for establishing practices and policies in line with the Act. We are the data controller of all personal data used in our business for our own commercial purposes.

3.5 Data users are those of our employees and self-employed contractors (“contractors”) whose work involves processing personal data. Data users must protect the data they handle in accordance with this data protection policy and any applicable data security procedures at all times.

3.6 Data processors include any person or organisation that is not a data user that processes personal data on our behalf and our group companies. Employees of data controllers are excluded from this definition but it could include suppliers which handle personal data on Transpaygo Limited’s behalf.

3.7 Processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.

3.8 Sensitive personal data includes information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. Sensitive personal data can only be processed under strict conditions and all of the sensitive data we process will be information which has been made public by the data subject.

3.9 Specific Purposes include providing international money transfer services for our customers, maintaining customers’ online accounts on our websites, improving and maintaining our services, obeying to our regulatory obligations, promoting our own products and services, maintaining our own accounts and records and supporting and managing our employees and contractors.

4 Data protection principles

4.1 Anyone processing personal data must comply with the eight enforceable principles of good practice. These provide that personal data must be:

4.1.1 processed fairly and lawfully;

4.1.2 processed for limited purposes and in an appropriate way;

4.1.3 adequate, relevant and not excessive for the purpose;

4.1.4 accurate;

4.1.5 not kept longer than necessary for the purpose;

4.1.6 processed in line with data subjects' rights;

4.1.7 secure; and

4.1.8 not transferred to people or organisations situated in countries without adequate protection.

5 Fair and lawful processing

5.1 The Act is not intended to prevent the processing of personal data, but to ensure that personal data is processed fairly and without adversely affecting the rights of the data subject.

5.2 For personal data to be processed lawfully, the data must be processed on the basis of one of the legal grounds set out in the Act. These include, among other things, the data subject's consent to the processing, or that the processing is necessary for the performance of a contract with the data subject, for the compliance with a legal obligation to which the data controller is subject, or for the legitimate interest of the data controller or the party to whom the data is disclosed. When sensitive personal data is being processed, additional conditions must be met. When processing personal data as data controllers in the course of our business, we will ensure that those requirements are met.

6 Processing for limited purposes

6.1 In the course of our business, we will collect and process personal data. This may include data we receive directly from a data subject (for example, by completing forms or data fields on our websites, enquiring about our product or service or by corresponding with us by mail, phone, email or other social media functions on our website) and data we receive from public and third party sources (including, for example, business partners, employees, contractors, payment and delivery services, banks and other financial institutions, debt collection, tracing agencies, credit reference agencies, government agencies, regulatory bodies and others).

6.2 We will only process personal data for the Specific Purposes or for any other purposes specifically permitted by the Act. The data we process might include but is not limited to:

• 6.2.1 Data subject’s personal details such as: date of birth, professional credential, contact information (for example: name, postal address, e-mail address and phone number), financial and credit card information;
• 6.2.2 Data subject’s employment and educational details, family details, lifestyle and social circumstances and business activities;
• 6.2.3 Technical information, including the Internet Protocol (“IP”) address used by a data subject to connect his computer to the Internet, his login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• 6.2.4 Information about a data subject’s visit, including the full Uniform Resource Locators (“URL”) clickstream to, through and from our website (including date and time); products viewed or searched for by a data subject; 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;
• 6.2.5 Information about a data subject which we receive from public and third party sources (as above) to verify the data subject’s identity and eligibility for our services.

7 Adequate, relevant and non-excessive processing

We will only collect personal data to the extent that it is required for the Specific Purposes or to comply with legal obligations. We will not hold more personal data than we need for the Specific Purposes.

8 Accurate data

We will take reasonable steps to ensure that personal data we hold is accurate and kept up to date. We will check the accuracy of any personal data at the point of collection and at reasonable intervals afterwards. We will consider challenges to the accuracy of the information that we hold and we will take all reasonable steps to amend or securely destroy inaccurate or out-of-date data.

9 Timely processing

We will not keep personal data longer than is necessary for the purpose or purposes for which they were collected. At reasonable intervals we will review the length of time that we hold personal data and we will take all reasonable steps to securely destroy, or erase from our systems, all data which is no longer required.

10 Processing in line with data subject's rights

10.1 We will process all personal data in line with data subjects' rights, in particular their right to:

• 10.1.1 request access to a copy of any data held about them by us (see also clause 11);
• 10.1.2 prevent the processing of their data for direct-marketing purposes;
• 10.1.3 request that decisions which significantly affect them are not based solely on the processing of personal data by automatic means;
• 10.1.4 ask to have inaccurate data amended, erased or destroyed (see also clause 8);
• 10.1.5 request that all personal data relating to them be permanently erased and not circulated further (“right to be forgotten”);
• 10.1.6 object to processing that is being conducted without their consent;
• 10.1.7 prevent processing that is likely to cause damage or distress to themselves or anyone else; and
• 10.1.8 claim compensation for damages caused by a breach of the Act.

10.2 Data subjects have the right to submit complaints about us to the ICO at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

11 Dealing with subject access requests

Data subjects may make a formal request for the information we hold about them. This request must be made in writing and may be subject to a fee of £10 to meet our costs in providing the information we hold on the data subjects.

12 Data security

12.1 We will take appropriate security measures against unlawful or unauthorized processing of personal data, and against the accidental loss of, or damage to, personal data.

12.2 We will put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data will only be transferred to a data processor if he agrees to comply with those procedures and policies, or if he puts in place adequate measures himself.

12.3 We will maintain data security by protecting the confidentiality, integrity, and availability of the personal data, defined as follows:

• 12.3.1 Confidentiality means that only people who are authorized to use the data can access it.
• 12.3.2 Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.
• 12.3.3 Availability means that authorized users should be able to access the data if they need it for authorized purposes. Personal data should therefore be stored on the Transpaygo Limited’s central computer system instead of individual PCs.

12.4 Security procedures include:

• 12.4.1 Entry controls. Any stranger seen in entry-controlled areas should be reported.
• 12.4.2 Secure lockable desks and cupboards. Desks and cupboards should be kept locked if they hold confidential information of any kind. Personal information is always considered confidential.
• 12.4.3 Methods of disposal. Paper documents should be shredded. Digital storage devices should be physically destroyed when they are no longer required.
• 12.4.4 Equipment. Data users must ensure that individual monitors do not show confidential information to passers-by and that they log off from their PC when it is left unattended.

13 Disclosure and sharing of personal information

13.1 Sharing with Selected Third Parties

We may share personal data we hold with selected third parties including, business associates, clients, contractors, payment and delivery services, credit reference agencies, banks and other financial institutions, debt collection, tracing agencies, credit reference agencies, government agencies, regulatory bodies, others professional advisers, current, past or prospective employers and service providers for the Specific Purposes.

13.2 Other Disclosure Scenarios

We may also disclose personal data we hold to third parties in the following scenarios:

13.2.1 Sale or Purchase of Business or Assets

In the event that we sell or buy any business or assets, we may disclose personal data we hold to the prospective seller or buyer of such business or assets.

13.2.2 Acquisition by a Third Party

If we or substantially all of our assets are acquired by a third party, personal data we hold will be one of the transferred assets.

13.2.3 Legal Obligation or Protection of Rights

We may disclose or share a data subject's personal data in order to comply with any legal obligation, or in order to enforce or apply any contract with the data subject or other agreements; or to protect our rights, property, or safety of our employees, contractors, clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

14 Cookies

14.1 Use of Cookies

We use cookies on our site to detect the multiple use of our service, by the same user/Internet connection owners. Cookies are small text files that are stored and saved by your Internet browser on your computer. They are used to improve our website and our service. These are usually called "session cookies", which are deleted after the end of your visit. In part, these cookies usually provide information to automatically recognize you again. This recognition is made possible through the stored IP address in the cookie. This acquired information is used to improve our services and to allow you easier access to our site. You may refuse the use of cookies by selecting the appropriate settings on your browser; however, we would like to point out that you may not be able to use all features of our website in this case.

14.2 External Cookies integrated in our website

Listed are some but not all external cookies and the use of these cookies which we use on our site.

14.2.1 Use of Google Analytics with anonymity feature

We use Google Analytics on our website, a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 United States, hereinafter "Google". Google Analytics uses "cookies", text files that are stored on your computer and thereby allow analysis of your use of the website. The information generated by these cookies, e.g., time, place and frequency of your Website visits including your IP address, will be transferred to Google in the US and stored there.

14.2.2 Use of Facebook recommend components

On our page we are or may be making use of plug-ins from Facebook, products of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA, in short "Facebook". On every visit to our site that features a Facebook plug-in, the plug-in induces your browser to download the component from Facebook. Facebook will be notified which specific site you are visiting on our homepage. If you are visiting our site while you are logged on to Facebook, Facebook will collect through its plugins information which specific site you are visiting and will allocate that information to your Facebook profile. For instance if you are clicking on "like" or leave a comment, the collected data will be allocated to your Facebook profile and saved. Further, the information that you have visited our site be forwarded to Facebook, whether you click a Facebook plugin or not.

If you wish to avoid being tracked by Facebook in the above mentioned ways, you will need to log out of your Facebook account before visiting our site. Facebook's privacy details for its plug-ins with further detailed information about the tracking, transfer, and use of data collected by Facebook, your rights and about your profile settings can be found here: Facebook's Privacy Policy.

External tools can be used to block Facebook-social-plugins with the help of add-ons usable by all major browsers: Facebook Social Plugins Blocker. Here you will find an overview of all of Facebook's plugins that are in use: Facebook Plugins Overview.

15 Changes to this policy

We reserve the right to change this policy at any time. Where appropriate, we will notify data subjects of those changes by mail or email.