Privacy Notice
Scope/Document Purpose
This document outlines the Privacy Policy and the requirements for publication of the reasons on why we collect, retain, and use personal and sensitive data. The Policy outlines the responsibilities for the Executive Management team and should be read in conjunction with the policies listed at the end of this document. This document will be reviewed annually or when required by the Data Protection Officer, reflecting any changes to legislation or perceived risk.
Definitions
Cookies
A cookie is a small file of data, typically of letters and numbers, that a website asks your browser to store on your computer or mobile device. Cookies are sent back to the originating website on each subsequent visit, and are essential to the effective operation of our website, and to enable you to shop online with us.
Consent
Freely given, specific, informed and unambiguous indication of the data subject's wishes, a clear, affirmative action which agrees to the processing of personal data.
Data Breach
A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
Data Controller
Means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Data Processor
A natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller.
Data Subject
A living individual / natural person.
Personal Data
Any information relating to an identified or identifiable natural person ('data subject'); anyone who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Special Category Data
Personal data, revealing:
- racial or ethnic origin;
- political opinions;
- religious or philosophical beliefs;
- trade-union membership;
- data concerning health or sex life and sexual orientation;
- genetic data; or
- biometric data
- criminal data (convictions and offenses)
Policy (Introduction/Objectives)
When you register with us or ask us to provide you with any of our products or services, you are agreeing that we may handle your information in accordance with this Privacy Notice and other associated policies relating to the protection of personal and sensitive data.
We use your information only in accordance with this Notice and take all necessary steps to ensure we keep your information secure.
This Notice should be read carefully along with our Terms & Conditions (T's & C's); by accessing our websites you confirm that you have read, understood, and agree to them.
How to contact us
We are a member of Western Union Ireland Holdings Ltd. As a group of companies we are registered in England and Wales.
Eurochange – Registered No: 02519424
Our Registered Office: Essex House, Rutherford Close, Meadway Corporate Centre, STEVENAGE, Hertfordshire, SG1 2EF
If you have any questions about our Privacy Policy or the information that we hold about you, please contact us in writing by email at [email protected] or by post to the Data Protection Officer at: eurochange Ltd, PO Box 435, Stevenage, Hertfordshire SG1 9GA.
How we collect your information
Most of the personal data that we process is provided to us directly by you or your business (directors, officers, and ultimate beneficial owners). We will collect your information when:
- you apply for employment
- you register / on board with us
- you register / on board with one of our clients through our white label website service
- you speak with us over the telephone, when you write to us (by post or by email)
- you transact with us or use our products and services either in branch, online or at your place of work/business
- when you visit our website. We may use cookies to collect information about your use of our and, our white label, websites and the devices that you use
Information may also be obtained from third parties, such as:
- trusted data controllers for the purpose of transacting within Agent relationships
- credit agencies, fraud prevention, law enforcement, government departments/agencies, accreditation/licensing providers
- open source and online search services, i.e. media, electoral registers, Companies House
- social media, inc. Facebook, Twitter, TikTok, LinkedIn etc.
Cookies
In general, you can visit eurochange and our white label websites, without identifying who you are, or revealing any information about yourself. However, cookies are used to store small amounts of information on your computer, which allows certain information to be recalled by the web server when required.
Some cookies are essential to the effective operation of our website. Other cookies enable us to track your interests to enhance the experience of our website and provide more targeted information. We also use cookies to monitor website traffic. This information is used in aggregate form to help us understand what information is most useful to visitors of our website and to help us improve our website content.
You can modify your browser settings to prevent all cookies from being stored; however, this may prevent you from using certain functionality of our website and could negatively impact your experience. Please see our Cookies Policy for more information.
Registration and administration
We use your information to enable you, once your registration / on boarding is complete, for the administration of your account, to contact you, to update our records about you, and to respond to, and process your queries and requests. Personal information may be checked against third party/independent systems that review the electoral register and other databases to validate your identity.
Monitoring
We record and may monitor and use:
- CCTV inc. voice recording, telephone calls, and transcripts of our telephone calls with you, in case we need to check we have carried out your instructions correctly, to resolve queries or issues, for regulatory purposes, to help improve the quality of our service. Conversations may also be monitored for staff training purposes.
- transactional information to help to detect or prevent crime or other breaches of our policies.
These measures are conducted due to the nature of risk associated with the type of business that we operate, and that we operate within highly regulated industries.
Prevention and detection of crime
Our products and services, are subject to laws and regulation for:
- money laundering
- fraud
- terrorist financing
- bribery and corruption
- sanctions
We may be required by this legislation, the regulators, by the Police or other law enforcement agencies (e.g., in connection with criminal prosecutions, money laundering or fraud investigations), by order of a court or otherwise by law, to use and share your information in the detection, prevention or prosecution of crime, tax evasion, fraud or for audit purposes.
Credit controls and debt collections agencies
We may share your information with credit control or debt collection agencies, if you owe us money and we engage their services to recover funds owed to us by you.
On a business sale or purchase
If we decide we want to sell our business, or receive an offer to buy our business, we may have to share some of your information with a prospective purchaser and their advisors. If our business is sold, the new owner will use your personal information in the same way as set out in this notice.
Opt-in Marketing
Where you have given your consent, we may contact you by post, telephone, email, or text to provide you with information about products and services that we think may be of interest to you. You can opt out of receiving marketing communications from us at any time by contacting us or by using the unsubscribe function, that is available on all of our email communications with you.
We may provide information about you to companies outside of our business (when the white label service is in place), to use for their own marketing purposes, when you have given us your consent to do so.
Our contractual obligations
We use your personal information to:
- register your interest with us
- open an account and meet our contractual obligations to you
- provide you with products and services which you use, or information on similar products or services which we think may be of interest to you (if you have opted in to receive such information). This may include information concerning promotions or offers
- notify you about changes or developments relating to our products and services that you use
We might contact you by post, telephone, email, or text unless you have asked us not to. If you are a registered client/customer, we may also display personalised advertising to you when you use social media or other websites.
Data retention
When information is no longer needed as defined by our Retention Policy, the data will be deleted or anonymised when no longer needed. Databases are managed with systemised housekeeping programmes to identify when the correct time period has elapsed and will automatically operate on a daily basis.
We may retain certain records for other legitimate purposes (including after your relationship with us has ended), e.g., to resolve any potential disputes, cross-check against future applications and to comply with other reporting, legislative and retention obligations.
Where there is a legal requirement to segregate data from the destruction process, this is managed according to our Retention Policy and flagged within the system, and when no longer needed for complaint handling or for the detection/prevention of crime, it will be un-flagged for the automated process to complete.
Information security
All data that we collect is held on servers located within the EEA, is kept secure, and personal data is only used for the purposes specified in this notice. We regularly review our security processes and procedures to ensure that they are effective. Only those within eurochange who are authorised, have access to your personal information.
Your rights
Under data protection law, you have rights including:
- Your right of access – You have the right to ask us for copies of your personal information.
- Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing – You have the right to object to the processing of your personal information in certain circumstances.
- Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us, in writing at [email protected] or by post to the Data Protection Officer at: eurochange Ltd, PO Box 435, Stevenage, Hertfordshire SG1 9GA, alternatively you can find contact details relating to our business or affiliated white label clients on our respective websites.
Children's Online Privacy Protection Act compliance
We are in compliance with the requirements of COPPA (Children's Online Privacy Protection Act); we do not collect any information from anyone under 18 years of age. Our website, products and services are all directed to people who are at least 18 years old or older.
Changes which may affect you
We keep our Privacy Policy under regular review. Any changes we make will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Policy.
How to complain
If you have any concerns about the use of your personal information, you can make a complaint to us by writing to:
Data Protection OfficerEurochange Ltd
PO Box 435
STEVENAGE
Hertfordshire
SG1 9GA
You can also complain to the ICO if you are unhappy with how we have used your data.
Information Commissioner's OfficeWycliffe House
Water Lane
WILMSLOW
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: www.ico.org.uk
You can find out more about the Act and your rights by visiting the website of the Information Commissioner.
Responsibilities
This Privacy Notice was approved by the Board of Directors and is issued on a version-controlled basis under the signature of the Managing Director (MD).