Data Protection and Privacy Policy

Data protection registration
MoneyMovr Limited (Money Mover) is registered with the Information Commissioner’s Office under the Data Protection Act (DPA). Our registration number is ZA045757, and the register can be checked here.

Terminology
The terms “we”, “us” and “our” shall refer to Money Mover and the terms “you”, “your”, “user” or “customer” refer to users of any services provided by Money Mover. As used in this policy, the singular shall include the plural and references to “he” shall include both the masculine and the feminine.

Introduction
Money Mover is committed to protecting personal data. This Data Protection and Privacy Policy describes how and why we collect and use personal data. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy statement or as stated at the point where we collect the data.

Personal data is any information relating to an identified or identifiable living person. Money Mover processes personal data to enable us to provide a currency exchange and money transfer service, maintain our accounts and records to the required legal and regulatory standards and to promote our services. The means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.

When collecting and using personal data, our policy is to be transparent about why and how we process it.

Collection of personal data
Our policy is to collect only the minimum amount of personal data necessary to carry out the services we provide for the the purposes agreed with our users. Where we collect personal data for email marketing purposes, all new subscribers are required to go through a ‘double opt-in’ process to confirm their consent unambiguously and minimise false or fraudulent subscriptions.

Use of personal data
We use personal data for the following purposes:

  • Providing our services
    We provide a range of services which require us to process personal data in order to carry out our customers’ instructions. For example, we require personal data, such as the identity of the user, his or her IP address, the reason for the payment and the details of the recipient, in order to carry out an international payment on his or her behalf.
  • Administering, managing and developing our businesses and services
    We process personal data in order to run our business, including:
    • managing our relationship with customers;
    • developing our business and services (such as identifying customer needs and improvements in service delivery);
    • maintaining and using IT systems;
    • hosting, or facilitating the hosting of events; and
    • administering and managing our website, systems and applications
  • Security, quality and risk management activities
    We have security measures in place to protect our and our customers’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We monitor the services provided to customers for quality purposes, which may involve processing personal data stored on the relevant customer file. We have policies and procedures in place to monitor the quality of the service we provide and manage risks associated with them. We collect and hold personal data as part of our customer engagement and acceptance procedures. As part of those procedures we carry out searches using publicly available sources (such as credit checks, internet searches and sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations and check that there are no issues that would prevent us from providing our services to a particular customer (such as sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues).
  • Providing our users with information about us and our range of services
    Our customers may consent to the use of their contact details to receive relevant content such as newsletters, announcements, offers, thought leadership and invitations to events from us. If you decide that you no longer wish to receive marketing content from Money Mover please note that we may still need to send you emails with factual and transactional information relating to the services that we provide to you.
  • Complying with any requirement of law, regulation or a professional body of which we are a member
    As with any provider of financial services, we are subject to legal, regulatory and professional obligations. We need to maintain certain records to demonstrate that our services are provided in compliance with such obligations and those records may contain personal data.

We are continually looking for ways to help our customers and improve our business and services. We may use personal information that we receive in the course of providing our services for other lawful purposes, including analysis to better understand a particular issue, industry or sector, provide insights to our customers, to improve our business, service delivery and offerings and to develop new technologies and offerings. To the extent that the information we receive in the course of providing our services contains personal data, we will de-identify the data prior to using the information for these purposes.

Data retention
We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable laws or regulations).

In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is 7 years. After this point, data shall be deleted and related accounts deactivated.

Security
We take the security of all the data we hold very seriously. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure. Furthermore we have implemented suitable monitoring procedures to detect any gaps in our processes.

When and how we share personal data and locations of processing
We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

Money Mover uses third parties located in other countries to help us run our business. As a result, personal data may be transferred outside the countries where we and our customers are located. Where data is transferred outside the European Union ("EU") we have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU, such as the European Commission approved standard contractual clauses. The European Commission approved standard contractual clauses are available here.

Personal data held by us may be transferred to:

  • Third party organisations that provide applications/functionality, data processing or IT services to us
    We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud-based software-as-a-service providers, customer relationship management, identity management, website hosting and management, data analysis, data back-up, messaging, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.
  • Third party organisations that otherwise assist us in providing goods, services or information
  • Auditors and other professional advisers
  • Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation
    Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

Changes to this privacy statement
We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review.

This privacy statement was last updated on 8 June 2018.

Data controller and contact information
The data controller is MoneyMovr Limited (a limited company registered in England and Wales under registration no. 8780601 and with its registration address at Milton Hall, Ely Road, Milton, Cambridge, CB24 6WZ).

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Data Protection Officer
MoneyMovr Limited
Milton Hall
Ely Road
Milton
Cambridge
CB24 6WZ

Email: support@moneymover.com
Phone: 01223 928 030

Individuals’ rights and how to exercise them
Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights. Where we decide how and why personal data is processed, we are a data controller and include further information about the rights that individuals have and how to exercise them below.

Access to personal data
You have a right of access to personal data held by us as a data controller. This right may be exercised by emailing us at support@moneymover.com. We may charge for a request for access in accordance with applicable law. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits (30 days from 25 May 2018).

Accuracy and amendment of personal data
We take proactive measures to ensure that the data we hold is accurate and up-to-date. If we become aware that personal data we hold is inaccurate, we to take all practicable steps to correct it. If we are unable to correct errors, then the data will be erased in accordance with our data retention policy.

To update personal data submitted to us, you may email us at support@moneymover.com or, where appropriate, contact us via the relevant website registration page, or by amending the personal details held on relevant applications with which you registered.

Withdrawal of consent
Where we process personal data based on consent, individuals have a right to withdraw consent at any time. Where we do not process personal data based on consent, we rely on another legal basis. To withdraw consent to our processing of your personal data please email us at support@moneymover.com or, to stop receiving an email from a Money Mover marketing list, please click on the unsubscribe link in the relevant email received from us.

Other data subject rights
This privacy statement is intended to provide information about what personal data we collect about you and how it is used. As well as rights of access and amendment referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure/deletion, to restrict or object to our processing of personal data, and the right to data portability. Some of these rights will only be available from 25 May 2018.

If you wish to exercise any of these rights, please send an email to support@moneymover.com 

Minors policy
Money Mover does not knowingly solicit or hold information from individuals which have not reached the age of majority in their country of residence, and such individuals should not apply to use our services. If we later obtain actual knowledge that a user has not achieved the age of majority in his or her country of residence, we will take steps to remove that user’s information from our systems. If you believe that we might hold any information about minors, please contact us at support@moneymover.com 

Complaints
We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to support@moneymover.com. We will investigate and respond to any complaints we receive.

You also have the right to lodge a complaint with the Information Commissioner's Office (“ICO”) (the UK data protection regulator). For further information on your rights and how to complain to the ICO, please refer to the ICO website.

Cookies

What are cookies?
Cookies are small files, typically consisting of letters and numbers, which are downloaded onto a device when a user accesses certain websites. Cookies are sent back to the originating website on subsequent visits which allows the website to recognise a user’s device.

Why we use cookies
We use cookies to enable you to navigate between pages efficiently, remember your preferences, and generally improve your experience of using the Money Mover website.

Your Consent
By using our site you consent to our Cookie Policy.
For further information about cookies, including how to change your browser settings for cookie use, click here.

Data Protection contacts
If you need to contact Money Mover with any questions about data protection, privacy or cookies then please send your request to support@moneymover.com