Privacy Policy

Introduction

The money remittance service is provided by RemitM Limited (CRN:07956213) (“RemitM”). Remitm treats your privacy rights very seriously and will deal with any Personal Information (the term “Personal information” refers to information that could identify, or is related to the identity of, an individual) you provide to us strictly in accordance with the following privacy principles.

This Privacy Policy should be read in conjunction with the client agreement that you enter into with Remitm (“Client Agreement”).

Privacy Principles

Purpose
1. These Privacy Principles describe how we collect, use and disclose your Personal Information.

2. We will collect your Personal Information only for the purpose of providing our services to you and any purpose that is directly incidental to the provision of those services. In the event that we wish to use your Personal Information for any other purpose, we will identify such purpose and obtain your consent before doing so, unless the new purpose is required by law.

3. We are always willing to explain to you the purposes for which information is being collected.

Consent
4. We will seek your consent to the use of your Personal Information either expressly or impliedly, depending on the circumstances and the type of information collected. For example, we will rely on your implied consent when you give us your name, address, telephone number and other details necessary for us to verify your identity in accordance with the provisions of the Client Agreement.

5. Your consent may also be given by an authorised representative or a person having Power of Attorney.

6. You may withdraw your consent at any time, subject to any legal restrictions and subject to any contractual restrictions you have already entered into with us, and provided that you give us reasonable notice in writing. We will explain to you the implications of such withdrawal.

7. We may from time to time send you information that is relevant to the provision of our services. If, at any time, you do not wish to receive that information, you may by sending us an email opt-out and request that you are not included in any future mail-outs.

8. There may be circumstances in which we are obliged to collect, use, or disclose certain Personal Information without your consent. Such circumstances could include the following:

(i) a serious and imminent threat to someone’s life, health or safety;
(ii) a serious threat to public health or public safety;
(iii) unlawful activity has been, is being or may be engaged in;
(iv) disclosure is required or authorised by law;
(v) the use or disclosure is necessary for the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law including the enforcement of laws relating to the confiscation of the proceeds of crime; or
(vi) the use or disclosure is necessary for the protection of the public revenue, the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct or the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal.

Limiting Collection and Retention of Information
9. The amount and type of information collected by us will be limited to that which is necessary to provide our services and the information shall be retained only for as long as may be necessary for the fulfillment of the purpose for which the information is collected.

10. You acknowledge that we are obliged under the relevant anti-money laundering and counter-terrorism legislation to retain information relating to personal identity for 7 years.

11. Subject to any legislative requirements, we will destroy, erase, or make anonymous your personal information when it is no longer required to fulfill the purpose for which it has been collected.

Accuracy
12. We will make reasonable efforts to ensure that your Personal Information is sufficiently accurate, complete and up-to-date to minimise the possibility that inappropriate information may be used to make a decision about you.

13. We will not routinely update your Personal Information unless such a process is necessary to fulfill the purposes for which the information was collected. In accordance with the Client Agreement, you must notify us as soon as possible if any of the information you have provided to us has changed.

Internet Technology
14. When registering or creating an account at our website, we collect your password and login name and other information we may request in order to identify you, maintain security of our website and verify and control access to your account or online profile. If you make inquiries through the e-mail links, forms or other contact methods provided on our websites, these inquiries are forwarded to the relevant office or department and are used to respond to your inquiry and maintain a record of correspondence.

15. We use Internet technologies like cookies and web beacons to facilitate the services we provide on our websites and your use of our websites, including for the following reasons.

(i) To assist us in providing services to you.
(ii) To allow you to change web pages during your visit without having to re-enter your password.
(iii) To store your preferences and other information and to track activity on our website.
(iv) To better understand the effectiveness of our promotional campaigns.
(v) To determine whether you came to our site from a banner ad or an affiliate website.
(vi) To deliver Information specific to your interests on additional web sites.
(vii) To determine whether you’ve acted on our promotional messages

NOTE: A “cookie” is a text file placed on your computer’s hard drive by a web server, which allows for personalisation of certain aspects of your visit to that website. “Web beacons” are transparent electronic images placed in the web code that collect non-personal data while visiting a website. Cookies and web beacons can usually be disabled by changing your browser preferences. Your browser usually has documentation on how to disable cookies and web beacons.

Note that disabling cookies may limit the performance of Remitm’s websites. If cookies are disabled, certain features of our websites may not function properly, and you may not be able to register or use your online account.

Disclosure to Third Parties
16. We may disclose your Personal Information to any member of the Remitm Group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006).

17. We may disclose your personal information to third parties for the following purposes:

(i) in the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business assets;
(ii) if Remitm’s, or substantially all of its assets, are acquired by a third party, in which case Personal Information held by us about our customers will be one of the transferred assets; and (iii) in accordance with obligations imposed on us by our third party service providers so that they may process your transactions.

18. We may disclose or share your personal information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

19. The Personal Information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who works for us or for one of our service providers. Such staff may be engaged in, among other things, the processing of your transaction, the processing of your payment details and the provision of support services.

By submitting your personal information, you agree to this transfer, storing or processing. We will take all reasonable steps to ensure that such Personal Information is treated securely and in accordance with this Privacy Policy.

Children's Privacy
20. Our website is not directed at children under the age of 18. We will not knowingly collect or maintain Personal Information on our website from those we actually know are under the age of 18.
External Websites
21. Our website may be linked to or from third party websites. These links are provided as a convenience only. We are not responsible for the content or privacy principles of websites that are linked to or from our website. You are advised to review the privacy policies of any third party websites you visit.
Safeguards
22. We have in place a range of security safeguards to protect your Personal Information against loss or theft, as well as unauthorised access, disclosure, copying, use, or modification, regardless of the format in which it is held.

23. The methods of protection we employ may depend on the sensitivity of the information and the format in which it is contained. Security measures include: technological measures including SSL 128 bit encryption for all data transfers over the Internet, physical measures such as locked filing cabinets and restricted access to offices and strategic measures such as security clearances and limiting access to a “need-to-know” basis.

24. We make every effort to ensure that our staff are aware of the importance of maintaining the confidentiality of personal information, however you acknowledge that authorised employees, agents, representatives and third parties may require access to your Personal Information in order to enable us to provide our service and we cannot accept responsibility for any unauthorised activities on their part.

25. You acknowledge that no data transmission over the internet or the telephone can be guaranteed to be perfectly secure. Any Personal Information you submit to us or access electronically or over the telephone is done at your own risk. We do not guarantee or warrant the security of information transmitted in these ways. You acknowledge that third parties could unlawfully intercept your transmissions or may wrongly instruct you to disclose Personal Information while posing as Remitm representatives.

Access
26. We will upon request and within 10 days of any such request allow you access to your Personal Information. The requested information shall be provided or made available in a form that is generally understandable.

27. If you point out to us that any information held by us is inaccurate or incomplete, we will take appropriate action to amend the information as required and, if necessary, notify any third party of the correction.

28. You acknowledge that there may be circumstances in which we may refuse access to some or all of your Personal Information, including where the provision of access would be too costly, the information may contain references to other individuals or for legal, investigative, security or commercial proprietary reasons.

Complaints
29. We have procedures in place to receive and respond to complaints or inquiries about our policies and practices relating to the handling of Personal Information. For more information, see our Complaints Policy.

30. We take all complaints seriously and will investigate all complaints.

Contact
31. If you have any queries about this Privacy Policy or any complaints about our privacy practices, please contact our Compliance Officer at privacy@remitm.com.

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