PRIVACY POLICY

1.     Introduction

This Privacy Policy (“Privacy Policy”) sets out the basis on which RFX Financial Services Limited (whose details appear in Clause 17 of the CurrencyWire Payment Services Agreement (“Agreement”), trading as CurrencyWire (“CurrencyWire”, “we”, “us”, “our”)) will process any data that may be used to identify you (“personal data”) collected by either or both of them from you, or about you from third parties  as controllers under the Data Protection Act 2018 (including the General Data Protection Regulation (EU) 2016/679, and any replacement statute from time to time (the “DPA”).

Capitalised terms not otherwise defined in this Privacy Policy shall have the meaning given to them in the Agreement of which this Privacy Policy forms part, or the DPA. The Agreement and the Privacy Policy determine CurrencyWire’s respective responsibilities under the DPA.

If you have any questions regarding this Privacy Policy, please email us at: dataprotection@currencywire.co.uk.

You can complain to the Information Commissioner’s Office if you consider there has been a breach of the DPA in connection with your personal data.

2.     The information CurrencyWire collects

CurrencyWire operates the Service and only collects personal data relevant to the processing of Payment Transactions and your use of the Service and the administration and enforcement of the Agreement.

CurrencyWire may collect and process the personal data specified in Annex A, for the relevant purpose and on the relevant legal basis also specified in that Annex.

3.     Where we store your personal data

The personal data described in Annex A of this Privacy Policy is stored in the EEA. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Once we have received your information, we will use procedures and security features to try to prevent unauthorised and unlawful access and processing, as well as accidental loss, destruction or damage. We use sophisticated website encryption technology to protect sensitive date that you submit to us online. We use this technology to reduce the risk of your data being intercepted by unauthorised persons during transmission. However, the transmission of information via the Internet is not completely secure and, while we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website and any transmission is at your own risk.

Your personal data will be stored for the duration of the Agreement and for such time thereafter as required by Applicable Law or the limitation period for bringing contractual claims under or in relation to the Agreement.

4.     Use of Personal Information

CurrencyWire may use information held about you in the ways explained in Annex A to this Policy.

5.     Disclosure of your information

CurrencyWire will keep your personal data confidential and only disclose it to others for the purposes explained in Annex A to this Policy. 

6.     Processing of personal data not provided to us by you

CurrencyWire will also check your details with a fraud prevention agency/agencies and credit reference agencies and if you give false or inaccurate information and CurrencyWire identifies fraud, this will be recorded and may be shared by those agencies with other organisations and CurrencyWire, so that CurrencyWire and those other organisations, including law enforcement agencies and debt collection agencies, may access, use and search these records to:

(a)   help make decisions about credit and credit related services, for you and members of your household;

(b)   help make decisions on motor, household, credit, life and other insurance proposals and insurance claims, for you and members of your household;

(c)   trace debtors, recover debt, prevent fraud, and to manage your accounts or insurance policies;

(d)   prevent fraud and money laundering, for example, when:

  • Checking details on applications for credit and credit related or other facilities;

  • Managing credit and credit related accounts or facilities;

  • Checking details on proposals and claims for all types of insurance; and

  • Checking details of job applicants and employees.

Our primary service provider in this respect is IVXS UK Limited trading as ComplyAdvantage which is registered with the UK Information Commissioner’s Office under number ZA054290, who in turn may obtain information and services from credit reference agencies and fraud prevention agencies. Please contact us at dataprotection@currencywire.co.uk if you want to receive more information.

More information about credit reference agencies, their role as fraud prevention agencies, the data they hold, for how long, your rights and how they use personal data is available at the following links to each agency’s Credit Reference Agency Information Notice:

7.     Your rights

The table in Annex B to this Privacy Policy explains your rights under the DPA and how to exercise them. This Privacy Policy provides confirmation of the details required in relation to your right of access.

The Website may, from time to time, contain links to and from the websites of 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 CurrencyWire does not accept any responsibility for, and shall not be liable for these policies. Please check these policies before you submit any personal data to these websites.

CurrencyWire aims to keep your personal data up-to-date, so please advise them of any changes by e-mailing dataprotection@currencywire.co.uk or by updating the Service.

You must notify CurrencyWire by emailing dataprotection@currencywire.co.uk within thirty days if any of any change in your name, residential address, telephone number, e-mail address, or referees' address, and any other details that it reasonably considers to be material to its dealings with you in relation to the Service.

8.     Release, Indemnity and Liability

While CurrencyWire has used and shall use its reasonable endeavours to ensure that all your personal data that it holds shall be kept confidential as required by the DPA, CurrencyWire shall not be liable for any loss or damage incurred by you in the event that third parties wrongly gain access to your personal data, other than through CurrencyWire’s own breach of the DPA, negligence, breach of contract or wilful misconduct.

To the extent permitted by applicable law, CurrencyWire’s liability (and the liability of any of its affiliates and partners) arising from or in connection with this Privacy Policy shall be limited to the amount of any fees you pay to CurrencyWire.

To the extent permitted by applicable law, CurrencyWire shall not be liable for any indirect, special or consequential loss or damage, including loss of income or revenue, loss of business, loss of contract, loss of anticipated savings, loss of goodwill, loss of opportunity, or loss of data.

9.     Cookies

Cookies are data files containing small amounts of information which are downloaded to the device or browser you use when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website which recognises that cookie.

We use cookies in order to ensure our Service functions correctly and to improve our understanding of how you use the Service in order to make improvements.  Cookies cannot harm your computer. 

In general, there are four different types of cookie set out below and we explain in the following table which ones we use:

  • Necessary cookies: those required for the operation of the Service, which do not gather information about you that could be used for marketing or remembering where you have been on the internet.

  • Analytical/performance cookies: these allow us to collect information about how you use the Service, such as, how you move around our website and if you experience any errors. These cookies do not collect personal data. The information collected is anonymous and is only used to help us improve the way the Service works, understand what interests our users generally and measure how effective our advertising is.  Some of the performance cookies we use are issued as part of services provided by third parties, like Google Analytics.

  • Functionality cookies: these are used to provide services or to recognise you when you return to our website. These would enable us to personalise our content for you, greet you by name and remember your preferences and improve your visit.

  • Targeting cookies: these record your visit to the Service, the pages you have visited and the links you have followed. They are linked to services provided by third parties, such as "Like" and "Share" buttons. The third party provides these services in return for recognising that you have visited our website and are subject to the privacy policy of the third party who set them (e.g. a social media or network service). The third party may subsequently use information about your visit to target advertising to you on other websites and present you with advertisements that you may be interested in.

Where does the cookie originate? Necessary Performance Functional Targeting
cm.currencywire.co.uk / cm.racingfx.co.uk x x

Please note that configuring your computer and/or mobile browser to reject ‘necessary’, ‘performance’ or ‘functional’ cookies may severely impact your experience on our website and some parts of the Service will not function at all.

All browsers provide tools that allow you to control how you handle cookies: accept, reject or delete them. These settings are normally accessed via the ‘settings’, 'preferences' or 'options' menu of the browser you are using, but you could also look for a ‘help’ function or contact the browser provider. If you are unsure as to how to manage your cookies, please see the following links to view instructions for the most commonly used web browsers:

You should check the privacy policy and tools provided by any third party services you may use that set Targeting cookies on your browser or device.

Please note that we can also collect information about Service usage from data contained in “log files” from third parties. Log files are not cookies; they do not contain any personal data; and they are not used to identify your personal use of the Service. When you request any web page from the Service, web servers automatically obtain your domain name and IP address, but they reveal nothing personal about you and that data is only used to examine Service traffic in aggregate, to investigate abuse of the Service and its users, and/or to cooperate with law enforcement. Such data is not disseminated to third parties, except in aggregate.

Annex A

Personal Data Collected Purpose Basic for processing

(a) Information that you provide by filling in forms on the Website. This includes information provided at the time of registering to use the Service, posting material or requesting further services. We may also ask you for information when you report a problem with the Website;

(b) Your contact details, including your e-mail address, home address and telephone numbers;

(c) Records of any correspondence between you and CurrencyWire;

(d) Details of transactions you carry out through the Website;

(e) Details of your visits to the Website and the resources that you access;

  • To manage and administer the Website;
  • To enable you to use the Website;
  • To deal with enquiries, complaints and feedback from you;
  • To give you any notices under the Agreement;
  • To keep you informed about your Payment Orders and Payment Transactions;
  • To update CurrencyWire’s records;
  • To identify, prevent, detect or tackle fraud, money laundering and other crime;
  • To carry out checks required by applicable regulation or regulatory guidance;
  • To carry out our obligations arising from and exercise our rights under, any agreements between you and either of us or other users of the Service, including tracing and recovering payments and debts;
  • To check any instructions given to us, for training purposes, for crime prevention and to improve the quality of our customer service.

To disclose to third parties:
  • If it is under a duty to disclose or share your personal data in order to comply with any legal obligation;
  • To enforce this Privacy Policy or the Agreement;
  • to a credit reference agency to check your identity and to prevent fraud, (it will also keep a record of your request and use it whenever anyone applies to be authenticated in your name);
  • to agents and subcontractors, acting for either us, to use for the purpose of operating the Website and the Service;
  • to anti-fraud agencies, for the purpose of preventing and detecting fraud;
  • to debt collectors and other third parties to trace you and recover any debt;
  • In the event that CurrencyWire sells any business or assets, in which case it may disclose your personal data to the prospective seller or buyer of such business or assets;
  • To protect the rights, property, or safety of it, its customers, or others (which includes exchanging information with other companies and organisations for the purposes of fraud protection);
  • To investigate, prevent or detect fraud or carry out checks against money laundering;
  • For audit purposes and to meet obligations to any relevant regulatory authority or taxing authority.
processing is necessary for:
  • the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
  • compliance with a legal obligation to which we are subject;
  • the purposes of the legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
information about the device(s) you use to access the Website and your visits to and use of the Website (including your Internet Protocol address, 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 used)
  • to improve your browsing experience by personalising the Website;
  • To develop and improve the Service;
  • To ensure that content on the Website is presented in the most effective manner for you and for your computer;

To disclose to third parties:
  • To comply with a current judicial proceeding, a court order or legal process served on us, any request by the FCA or any other regulator who may have jurisdiction over us from time to time or for audit purposes and to meet obligations to any relevant regulatory authority or taxing authority;
  • To enforce this Privacy Policy or the Agreement;
processing is necessary for:
  • the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
  • the purposes of the legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
CurrencyWire may make and retain copies of passports or other identification evidence that you provide for anti-money laundering and anti-fraud purposes;
    To identify, prevent, detect or tackle fraud, money laundering and other crime;
  • To carry out checks required by applicable regulation or regulatory guidance;

To disclose to third parties for:
  • To comply with a current judicial proceeding, a court order or legal process served on us, any request by the FCA or any other regulator who may have jurisdiction over us from time to time or for audit purposes and to meet obligations to any relevant regulatory authority or taxing authority;
  • To enforce this Privacy Policy or the Agreement;
  • to a credit reference agency to check your identity and to prevent fraud, (it will also keep a record of your request and use it whenever anyone applies to be authenticated in your name);
  • to anti-fraud agencies, for the purpose of preventing and detecting fraud;
processing is necessary for:
  • the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
  • compliance with a legal obligation to which we are subject;
  • the purposes of the legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
Records of any surveys that you may be asked to complete; Your e-mail address.
  • To provide you with information, products or services that you request or which CurrencyWire decides may interest you;
  • For statistical analysis;
  • To identify which elements of the Service, Website or other products might interest you.
With your consent

Annex B
Your Rights

Your Right and How to Exercise Them Exception
Right of Access:

To obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information:

(a) the purposes of the processing;

(b) the categories of personal data concerned;

(c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;

(d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

(e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning youor to object to such processing;

(f) the right to lodge a complaint with a supervisory authority;

(g) where the personal data are not collected from you, any available information as to their source;

(h) the existence of automated decision-making, including profiling, referred to in Article 22(1) of the GDPR and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

How to exercise:

This Privacy Policy provides confirmation of the details required in relation to your right of access.

Under the DPA, you have a right to access certain personal records that CurrencyWire holds about you. Any access request may be subject to a fee to meet CurrencyWire’s costs in providing you with details of the information they hold about you if the request is unfounded or excessive. You can exercise the right at any time by contacting CurrencyWire at dataprotection@currencywire.co.uk.

Right to rectification:

to obtain from us without undue delay the rectification of inaccurate personal data concerning you.

We must communication to each recipient to whom the rectified personal data have been disclosed, unless this proves impossible or involves disproportionate effort.

We shall inform you about those recipients if you request it. You can exercise the right at any time by contacting CurrencyWire at dataprotection@currencywire.co.uk.

Right to erasure:

to obtain from us the erasure of personal data concerning you without undue delay where:

(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

(c) you object to the processing based on legitimate interest where there are no overriding legitimate grounds for the processing;

(d) the personal data have been unlawfully processed;

(e) the personal data have to be erased for compliance with a legal obligation to which we are subject. We must communication to each recipient to whom the erased personal data have been disclosed, unless this proves impossible or involves disproportionate effort.

We shall inform you about those recipients if you request it. You can exercise the right at any time by contacting CurrencyWire at dataprotection@currencywire.co.uk.

Processing is necessary for

(b) compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us; or

(e) the establishment, exercise or defence of legal claims.

Right to request the restriction of processing concerning you:

to obtain from us restriction of processing where:

(a) the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;

(b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead;

(c) we no longer need the personal data for the purposes of the processing, but it is required by you for the establishment, exercise or defence of legal claims;

(d) you object to the processing based on legitimate interest pending the verification whether our legitimate grounds override yours.

We must communication to each recipient to whom the restricted personal data have been disclosed, unless this proves impossible or involves disproportionate effort.

We shall inform you about those recipients if you request it. You can exercise the right at any time by contacting CurrencyWire at dataprotection@currencywire.co.uk.

Where processing has been restricted under this right, such personal data shall, with the exception of storage, only be processed:

(a) with your consent; or

(b) for the establishment, exercise or defence of legal claims; or

(c) for the protection of the rights of another natural or legal person; or

(d) for reasons of important public interest of the Union or of a Member State.

The right to data portability:

to receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us, where:

(a) the processing is based on consent or is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract; and

(b) the processing is carried out by automated means. You have the right to have the personal data transmitted directly from us to another controller, where technically feasible. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to the right to erasure.

You can exercise the right at any time by contacting CurrencyWire at dataprotection@currencywire.co.uk.

That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
The right to object to processing:

to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on processing necessary for the purposes of the legitimate interests pursued by us or a third party (except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data), including profiling.

You can exercise the right at any time by contacting CurrencyWire at dataprotection@currencywire.co.uk.

Where:

(a) we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject; or

(b) for the establishment, exercise or defence of legal claims.

The right to ask us not to process your personal data for direct marketing purposes:

to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. You have the right to ask CurrencyWire not to process your personal data for marketing purposes. CurrencyWire will usually inform you (before collecting your data) if it intends to use your data for such purposes or if it intends to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms used to collect your data.

You can also exercise the right at any time by contacting CurrencyWire at dataprotection@currencywire.co.uk.

The right not to be subject to automated individual decision-making, including profiling:

to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

You can exercise the right at any time by contacting CurrencyWire at dataprotection@currencywire.co.uk.

If the decision:

(a) is necessary for entering into, or performance of, a contract between you and us;

(b) is authorised by Union or Member State law to which we are subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or

(c) is based on the data subject's explicit consent. In the cases referred to in points (a) and (c) we shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on our part, to express his or her point of view and to contest the decision.