Purpose

This Privacy Policy describes:

- The information we collect;
- How we use that information;
- When we share information;
- Rights;
- And how to get in contact.

Overview

In providing you with our services we need to know things about you. We will only collect information we need to provide you with the services you have requested and will handle your information with the care. Any information we receive about you will be subject to strict controls to eliminate the risk of misuse – including unauthorized access to, or disclosure of, your personal data.

This Privacy Policy applies to information that InstantMoney may collect about clients to our platform (even if you do not become a customer), companies and individuals who register for our services, and continue using our services, and any other person who contacts us over the telephone or in writing.

Please read this notice carefully, together with our Terms and Conditions and any other documents referred to within. Here we explain the basis on which any information we collect about you, or that you provide to us, will be processed by us and other parties in providing you with the services you use.

For the purposes of this Privacy Policy, the term “personal information” means any data that can identify you as an individual for example name, address and contact information.

If you would like to know more about any of the terms of this Privacy Policy, please contact us so that we can help you with any questions or concerns.

What information InstantMoney collects and how its Collected.

Information provided to us

To use InstantMoney’s services, you will be asked to provide identifying information about yourself (e.g. name, address, and email address), your company and documents to verify the information provided.

In order to make payments, you will be asked to provide the information required to facilitate the payment – e.g. beneficiary information, bank account details and source of funds.

Through the course of our business relationship, we may ask for additional evidence in order for us to comply with our legal and regulatory obligations – e.g. anti-money laundering regulations. These can include, but are not limited to, documents required to verify any information provided or evidence of source of funds.

Information collected when using our InstantMoneys' Platforms or Apps

Our Platform is designed to provide you with a better experience for fraud prevention.

For the detection and prevention of fraud and cyber-crime, we will collect information, including session, device and IP address to help ascertain the legitimacy of the account login.

Public information

For non-registered users, we may contact you using publicly available information or information from third parties, which you have agreed to being shared, to let you know about products that could be relevant for your business.

Transactional information

For Partners once your account is fully set up and you begin to transact with us we will collect, process and store your financial and transactional information. This information includes the amount, currency, type of transaction, source of funds, exchange rate, recipient name and bank details.

Information InstantMoney recieves from third parties

To protect ourselves and our customers against fraud, we verify the information provided against Sanctions Lists and Electronic Identity Verification Services. In the course of verification, we receive and process information about you from such services.

Individuals who are not registered users

Parties that are connected

We will collect information about connected parties to client during the course of the business relationship from the client to comply with our legal and regulatory obligations - e.g. directors or shareholders of a company.

Beneficiaries

To provide the service, InstantMoney will collect information required to be able to send a payment to an individual, who may not be a client. This will include name and account details that are required by regulations to process the payment.

Purpose for processing data

As necessary to perform our contractual obligations. – To ensure we process payments and fulfil our side of the contract we will process transaction information and verification information.

As necessary to comply with our legal obligations. – As a financial services company we must collect and process certain information to comply with applicable laws and regulations. These include for:


- Completing due diligence to prevent money laundering and financial crime
- Financial reporting
- Establishment and defence of legal rights
- For activities relating to the prevention, detection and investigation of crime

Information on connected parties and beneficiaries is used for the purpose it is collected to comply with regulations and to make payments on the client’s behalf. We will not use this information to market to the non-registered individual unless they have specifically consented to receive these communications.

As necessary for our own legitimate interests – InstantMoney’s aim is to provide an excellent service. There is additional information we may collect that will help us:

- To be able to provide our customers with an excellent service – e.g. contact details, hours of availability and languages
- To notify our customers of market changes, products and event information that is relevant to them
- To provide service update notifications of any changes to our products and service that affect our customers

Based on your consent:

- To provide general product and market insight to make the most of your experience
- To perform market research through surveys to help improve our products
- To provide feedback in the development and improvement of products
- To provide offers and incentives

Who do we share your data with?

The way we access, process and transmit your information and our level of security remains consistent across the organisation.
For transparency, verification and legal requirements, we are required to include certain information on the payment which could include:
– Your name
– Your date of birth
– Your address – Beneficiary details
– Your national identity reference (e.g. passport)

Additionally, we may share your details with a trusted partner for marketing purposes if you have given your consent to do so.

We may share your information with trusted companies providing services to us under confidentiality agreements or to companies that assist us in meeting our obligations to you and our regulators– e.g. the processing of bank transactions. These companies do not have any rights to market other services with you.

We will certify that the company is based in a country with adequate data protections under their law, or that we enforce contractual obligations or require them to be certified with a framework of protection deemed suitable by us. InstantMoney Limited performs due diligence to ensure third parties are compliant with applicable legal and contractual requirements.

Also, we may share your information with any person acting on your behalf provided that you have given us the permission to do so.

Regulators and Law enforcement

We may need to pass necessary information on to regulatory bodies, the police/law enforcement agencies or other third parties where we are legally compelled to do so – e.g. if we have reason to believe an individual is acting fraudulently and using our services for an illegal purpose.

We will never sell any personal data that we hold about you. How long do we keep your personal information for?

InstantMoney Limited will only retain your information for as long as its necessary for providing our service to you and will not hold or process your information for any longer than we are legally required to. The criteria used to determine the appropriate retention includes:

– Regulatory requirements InstantMoney is subject to
– Whether a legal claim could be brought against InstantMoney
– Necessity of information to provide our service to our customers
– The legal basis for processing – e.g. consent

Information about connected parties and beneficiaries, which may not belong to a client, are stored for a period to comply with applicable legal requirements.

Communications

We communicate with you on a regular basis via email and phone to provide excellent customer service and fulfil requests.

Additionally, we use your email address, phone number and postal address to:
– Provide notification as part of the on-boarding and trading lifecycle
– Send you important changes to our products and services
– Send notices and disclosures required by law

Due to the service-orientated nature of these communications, you cannot opt out to receiving these.

Marketing

As part of our service, InstantMoney would like to keep you up to date concerning our products and services.

Once you are a client of InstantMoney, we may use your information to provide product information, and rate and market updates that are relevant to you and/or your company.

We may also use your information (whether you are a registered user or a visitor to our platform) to keep you up to date on general products, market updates or rate movements provided you have given your consent to do so.

If you change your mind on which communications you would like to receive or how you would like to receive them or you decide that you do not wish to receive these types of communications, you can remove your consent at any time by:

– emailing info@myinstantmoney.co.uk;
– managing your preferences through the online trading platform, if you are a registered user;
– Or, at the bottom of any email that you receive.

You will not miss out on any service we provide by not choosing to receive marketing from us and you can change your mind whenever you like as often as you like.

Rights

We recognise and support the rights outlined below that you have in relation to your personal information under General Data Protection Laws including the General Data Protection Regulation. If you would like to exercise any of the below rights then please contact us and we will respond to your query.

We will require you to provide proof of your identity and to provide sufficient information to allow us to locate your information.

To ask for information that INSTANTMONEY Limited holds about you to be corrected

If you notice any of the information on your account is incorrect, you can contact us and we will make any necessary changes, subject to verification of the information.

InstantMoney Limited will retain your information only for as long as necessary based on our obligations and business needs, this will be in line with our data retention policy. Additionally, you can request for your data to be deleted, subject to our legal and contractual obligations.

We will retain a record of your erasure request but we will not use this information for any other purpose.

InstantMoney Limited not to further process information.

If you make a request for us to stop processing information, we will investigate to see if there is compelling reason for processing to continue and will discuss the conclusion of the investigation with you.

You can not object to the processing which is a legal obligation or where we must process your information to satisfy a contract to which you are a party.

Security

We store all data electronically in a secure manner to protect its confidentiality, integrity and accessibility. Data is stored on servers which are protected by actively maintained firewalls. We make use of up-to-date anti-virus software and our servers have restricted access.

If you provide paper based documentation for the purpose of identity verification these will be stored electronically and the original will be destroyed securely or returned to you.

Transmission of data on the internet can never be completely secure. We do not and cannot guarantee the security of information collected or transmitted electronically however, we take reasonable care to safeguard your personal information.

Changes to our privacy policy

We may amend this policy from time to time. If we make any changes that will affect you, we will be sure to let you know. This will always be published publicly on our website here.