Privacy Policy - United Kingdom

Who are we?

Seif Financial (UK) Limited (“SeifMoney”) is an EMI agent with offices in the United Kingdom. We provide e-wallet and payment services through a United Kingdom licensed third party.

What, Why?

It is important that you know exactly what we do with the personal information you and others make available to us, why we collect it and what it means for you. This document outlines the approach to Data Privacy SeifMoney is taking to fulfil our obligations under the Data Protection Act 2018, as implemented on the 25th of May 2018. Being transparent and providing accessible information to individuals about how we will use their personal data is a key element of our organization.

The collection and use of data from a variety of sources is essential to our ability to provide our payment Services in a safely manner and is helping us to reduce the risk of fraud and money laundering. If you disagree with the practices described in this privacy policy, you should take the necessary steps to remove cookies from your computer/device after leaving our website(s) and not continue to use our Services.

Who is the Data Controller?

For personal data processed under this privacy policy, the data controller is;

Seif Financial (UK) Limited, 130 Shaftesbury Avenue, London W1D 5EU, United Kingdom

The personal data we would like to collect from you is:

  • First Name and Surname (with title);
  • Date of birth;
  • Email;
  • Proof of address documents;
  • ID Documents;
  • Other personal information such as telephone recordings; security questions, user ID;
  • Address;
  • Gender;
  • Bank Account details;
  • Telephone number;
  • Transactional information; and
  • CCTV footage where you visit SeifMoney offices.

The personal data we collect will be used for the following purposes:

  • Providing payment and e-wallet services to you as per our contractual obligations;
  • To promote, analyze and improve our products and services.
  • Process your account information, payment transactions, funds remittance and provide our Services.
  • Verify identity for compliance with the applicable laws regarding the prevention of money laundering and the prevention of terrorist financing or misuse of services.
  • Manage risk, or to detect, prevent, and/or mitigate fraud or other potentially illegal or prohibited activities or were requested by law enforcement for investigation of crime.
  • Respond to inquiries and provide customer support (for example in relation to payment refunds/chargebacks).
  • For audits, regulatory purposes, and compliance with industry standards.
  • To send communications regarding new services or products, events, offers and other news regarding our products and services.
  • To develop new products and to improve or modify our Services.

Our legal basis for processing the personal data:

  • receipt of your consent;
  • performance of a contract where you are a party;
  • legal obligations that SeifMoney is required to meet;
  • national law.
  • Any legitimate interests pursued by us, or third parties we use, are as follows: 
  • the prevention of fraud, money laundering, counter terrorist financing or misuse of services.

NOTICE

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data: public interest; legal obligation (mandatory for compliance with a legal or regulatory obligation); performance of a contract to which you are a party or to take steps at your prior to entering a contract) and our legitimate interest.

Consent

By using our services you are consenting to this privacy policy  and you are giving us permission to process your personal data specifically for the purposes identified above. Consent is required for SeifMoney to process personal data, but it must be explicitly given. Where we are asking you for sensitive personal data, we will always tell you why and how the information will be used.

Consent for Underaged

SeifMoney services are not available for anyone under the age of 18 years. In any case, please be aware that children need specific protection with regard to their personal data, as they may be less aware of the risks, consequences and safeguards concerned, and also of their rights in relation to the processing of personal data for the purposes of using these services.

Withdrawal of Consent Conditions

You may withdraw consent from direct marketing at any time by contacting us via support@seifmoney.com or sending a letter through the postal service to our office. Please note, where you have consented to your data being used for carrying out financial transactions, then the right to withdraw consent does not exist. As a payment service provider, SeifMoney is obliged to retain data concerning financial transactions for 6 years in accordance with national law for the purpose keeping financial records, and of preventing, detecting and investigating, possible money laundering or terrorist financing. In any case, a withdrawal of consent for information processing required in the process of carrying out our services will cause for immediate termination of service.

Cross-Border Data Transfers & Third-Party Disclosures

In limited situations where SeifMoney stores or transfers personal information outside the United Kingdom, robust procedures and safeguarding measures apply to secure, encrypt and maintain the integrity of the data. SeifMoney will complete continual reviews of any third parties with sufficient adequacy decisions, such as the The General Data Protection Regulation 2016/679 in the European Union, Privacy Shield framework in the United States of America, and provisions for binding corporate rules, standard data protection clauses or approved codes of conduct. SeifMoney will further perform due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information. SeifMoney undertakes that it shall not transfer Personal Data outside of the United Kingdom unless in full compliance with Article 46 of the Data Protection Act 2018, and shall not transfer data outside of the United Kingdom unless the following conditions are fulfilled:   

  • The data subject has enforceable rights and effective legal remedies; 
  • SeifMoney shall comply with its obligations under the data protection legislation by providing an adequate level of protection to any personal data that is transferred (or, if it is not so bound, uses its best endeavours to assist the customer in meeting its obligations); 
  • SeifMoney complies with any reasonable instructions notified to it in advance with respect to the processing of the personal data; and 
  • Upon written direction shall delete or return personal data (and any copies of it) unless SeifMoney is required by Law to retain the personal data.

Where SeifMoney is required to transfer personal data to the United States of America, SeifMoney shall only send such personal data to third-party sub-contractors that meet the minimum requirements contained under the Privacy Shield framework, or in the standard contractual clauses for the transfer of personal data to processors established in third countries under Data Protection Act 2018. 

These measures may include reviewing third parties' privacy and security standards, verifying if they have certified their compliance with the EU-U.S. Privacy Shield Framework and, where applicable, the Swiss-U.S. Privacy Shield Framework and/or entering into appropriate contracts (on the basis of the template adopted by the EU Commission and available via its homepage).

Retention Period

SeifMoney will process personal data for the duration of the contract for services and will store the personal data for six (6) years after that date of termination of the contract.

We will retain personal data for the period necessary to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law. Please note that we have a variety of obligations to retain the data that you provide to us, including to ensure that transactions can be appropriately processed, settled, refunded or charged-back, to help identify fraud and to comply with anti-money laundering and other laws and rules that apply to us and to our financial service providers.

Your Rights as a Data Subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

Your rights

What does this mean?

The right to be informed

You have the right to be provided with clear, transp-arent and easily understandable information about how we use your personal data, and your rights. This is why we are providing you with the information in this Privacy Policy.

The right of access

You have the right to access any personal data we hold about you (subject to certain restrictions). In exceptional circumstances we may charge a reasonable fee for providing such access but only where permitted by law (e.g. where your request is manifestly unfounded or excessive).

The right to rectification

You have the right to have your personal data rectified if it is incorrect or outdated and/or completed if it is incomplete.

The right to erasure/right to be forgotten

In some cases, you have the right to have your personal data erased or deleted. Note this is not an absolute right, as we may have legal or legitimate grounds for retaining your personal data.

The right to object to direct marketing, including profiling

You can unsubscribe or opt out of our direct marketing communication at any time. The easiest way to do this is by clicking on the "unsubscribe" link in any email or communication we send you or follow any other opt-out instructions communicated to you. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our Services.

The right to withdraw consent at any time for and personal data processing based on consent

You can withdraw your consent to our processing of your personal data when such processing is based on consent. Where you withdraw your consent, this does not affect the lawfulness of our processing before your withdrawal.

The right to object to processing based on legitimate interests

You may object at any time to our processing of your personal data when such processing is based on our legitimate interests.

The right not to be subject to a decision based solely on automated decision-making which produces legal effects or similarly significant effects

You may have the right not to be subject to such type of automated decision-making about you, unless: (i) you gave us your explicit consent to use your personal data to make our decision; (ii) we are allowed by law to make our decision; or (iii) our automated decision was necessary to enable us to enter into a contract with you.

The right to lodge a complaint with a supervisory authority

You have the right to contact the data protection authority of your country in order to lodge a complaint against our data protection and privacy practices. Do not hesitate to contact us at the details below before lodging any complaint with the competent data protection authority as we will always seek to resolve your complaint in the first instance.

The right to data portability

You have the right to move, copy or transfer personal data from our database to another. This only applies to personal data that you have provided, where processing is based on a contract or your consent, and the processing is carried out by automated means.

The right to restriction

This right means that our processing of your personal data is restricted, so we can store it, but not use nor process it further.It applies in the following limited circumstances set out in the EU General Data Protection Regulation:• the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;• the processing is unlawful and you object to the erasure of your personal data and request us to restrict the ways in which we processe your personal data;• We no longer need your personal data for the purposes of its processing, but you require the personal data for the establishment, exercise or defence of legal claims;• You object to our processing of your personal data based on our legitimate interests, pending the verification whether our legitimate grounds override your rights and freedoms.

The right to turn on/off cookies

The settings from the Internet browsers are usually programmed by default to accept cookies, but you can easily adjust it by changing the settings of your browser or, where available, by using the tools on our websites.Many cookies are used to enhance the usability or functionality of a website; therefore disabling some types of cookies may prevent you from using certain parts of our websites.If you wish to manage your preferences regarding the cookies which are set by our websites, please use the tool available on the particular website (if applicable), or refer to the Help function within your browser to learn how to manage your settings within your browser. For more information please consult the following links:http://www.aboutcookies.org/.

Changes to this privacy policy

We may amend this privacy policy from time to time. Any changes we may make to our privacy policy in the future will be posted on our website and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by SeifMoney (or third parties as above), or how your complaint has been handled, you have the right to lodge a complaint directly with the CurrencyCloud Limited by email to complaints@currencycloud.com or by vising https://www.currencycloud.com/legal/complaints-procedure/

Cookies

When you access our websites or use our Services, we or our authorized services providers may place small data files on your computer or other device. These data files may be cookies, pixel tags or "flash cookies" (collectively "cookies"). The cookies set may obtain information about you, your computer or device, your use of our website and your general internet usage. These technologies help to make it easier for you to log on and use the websites, to recognize you as a customer, provide feedback to us as to which parts of the website you visit, so we can assess the effectiveness of the site and provide a better, faster, and safer experience.

Necessary Cookies

These cookies are essential and are required for the operation of our website. They enable you to navigate around the website and use its features. They include, for example, cookies that enable users to log into secure areas of our websites.

Performance/Analytical cookies

These cookies collect information about how you use the website, including which pages you go to most often and if you get error messages from certain pages. This assists us to improve the way in which our website works, for example, by ensuring that you can find what you are looking for easily.

Functionality cookies

These cookies allow a website to remember your preferences (for example, your choice of language or region). They are used to recognize you when you return to our website.

Targeting cookies

These cookies record your visit to our website, the individual pages visited, and the links followed. These cookies are used to tailor marketing to you and your interests. Information collected by tracking cookies is commonly used to target online advertising. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign.

We may use third parties, such as advertising networks and exchanges, to allow us to serve you advertisements. These third-party ad networks and exchange providers may use third-party cookies, web beacons, or similar technologies to collect information about your visit to our site and elsewhere on the Internet. The information that these third parties collect may be used to provide you with more relevant advertising on our sites or elsewhere on the web. Third party cookies are covered by the third parties' privacy policies.