Privacy Policy - Ria Money Transfer

PRIVACY POLICY

v.1.1 31.10.2017

INTRODUCTION

  1. This policy (the “Privacy Policy”) explains how Euronet Payment Services Limited, trading as Ria, and referred to in this Privacy Policy as “Ria”, “we”, “our” or “us” uses and handles information that you provide to Ria in connection with the money transfer services available through riamoneytransfer.co.uk (“Our Website”) (“Our Service”); such information is referred to in this Privacy Policy as “Your Information” as further defined at paragraph (c) below.
  2. Euronet Payment Services Limited is data controller in relation to Your Information that is provided by you to Ria in relation to Our Service. This Privacy Policy applies to Ria’s use and handling of Your Information.
  3. The information we collect and hold about you may include: your name, email address, postal address, proof of postal address, occupation, date of birth, other contact information (for example, telephone number(s)), your identification documentation such as your driving licence and / or passport and / or details set out on such identification documentation, details of transactions you carry out or have carried out through Our Website and of the fulfilment of such transactions, the IP address of your computer or device used to access Our Website and your responses to any questions or requests we may ask you in connection with the provision of Our Service (for example, information required for compliance purposes to evidence the source of your funds). For convenience, this Privacy Policy refers to any and all such information as "Your Information".
  4. Before you provide any of Your Information to us in connection with Our Service, request a money transfer pursuant to Our Service or accept our terms and conditions in relation to such a transfer, you should read this Privacy Policy. If you do not agree with the terms of this Privacy Policy then you should not provide us with any of Your Information in connection with Our Service.

When you provide any of Your Information in connection with Our Service, including when you register or ask for a money transfer pursuant to Our Service, you agree that Your Information may be collected, used, shared and stored in accordance with this Privacy Policy.

Please note that we may update this Privacy Policy from time to time by posting a new version on Our Website and you should check Our Website frequently for any updates or changes to this Privacy Policy which may affect you.



CONTENTS

We are committed to protecting and respecting your privacy. This Privacy Policy explains how we use Your Information, how we share Your Information and the steps we take to protect Your Information.

Specifically, this Privacy Policy covers:

  1. COLLECTION OF YOUR INFORMATION
  2. OUR USE OF YOUR INFORMATION
  3. SHARING YOUR INFORMATION
  4. SHARING, USING AND STORING YOUR INFORMATION OUTSIDE OF THE UK
  5. BENEFICIARY INFORMATION
  6. GENERAL INFORMATION SECURITY
  7. COOKIES
  8. YOUR RIGHTS
  9. HOW TO CONTACT US
  1. COLLECTION OF YOUR INFORMATION
    1. We may collect Your Information when you indicate that you would like to receive Our Service, when you register with us, when you complete forms on or otherwise visit Our Website or when you correspond with us by phone, email or otherwise.
    2. Where you permit the use of cookies (see the 'Cookies' section below) we may collect such cookies and use them to help personalise your online experience, ensure you can navigate Our Website efficiently and perform certain functions. Due to their core role of enhancing or enabling usability or site processes, disabling cookies may prevent you from using certain parts of Our Website and it may also mean that some features on Our Website will not function.
  2. OUR USE OF YOUR INFORMATION
    1. Registration and administration. We may use and store Your Information to enable you to register with us and, once your registration with us 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.
      1. Compliance and prevention and detection of crime. As a condition of allowing you access to Our Services, we must verify Your Information as part of our customer due diligence and compliance obligations, including in respect of anti-money laundering, counter terrorist financing, fraud and suspicious transaction legislation and regulation and governance. In many cases this verification will happen through the use of an electronic identification verification and checking service provided to us by a third party (see section 3 below). We may also undertake manual identification and compliance verification using Your Information or otherwise undertake compliance transaction analysis and / or monitoring using Your Information (such as reviewing Your Information when your transactions are placed “on hold” as a result of Ria’s compliance filters being triggered). We may be required by applicable law, regulation, a court or competent regulatory or law enforcement bodies to use Your Information in the detection, prevention or prosecution of crime, tax evasion, fraud or other breach of law or regulation.
    2. Our Services. We may use and store Your Information so that we can supply you with Our Services which you have requested and / or which you use and to meet our contractual obligations to you. We may also use Your information to notify you about changes or developments relating to Our Services which you have requested and / or which you use, including any updates on the status of your requested transactions.
    3. Marketing. If you have agreed that we may do so (whether when you accepted this Privacy Policy or as separately agreed by you), we may use Your Information for direct marketing purposes and to communicate with you in respect of such products or services. You may indicate that you do not wish to receive marketing communications from us at any time by changing your marketing preferences in your customer dashboard (which is accessible via your account on Our Website) or by calling our customer service team at the telephone number set out at Section 9 below.
    4. Analysis. We may use Your Information (in aggregated form) to review, develop and improve, and for statistical research and analysis in relation to, Our Services and money transfer offering.
    5. Telephone call monitoring. We monitor and record our telephone calls with you and may use any transcripts of such calls: as a clear record of your communication, for the purposes of the prevention or detection of money laundering or crime, including fraud, and for the purposes of training and quality control. We typically store such telephone call recordings for a minimum period of 6 months.
  3. SHARING YOUR INFORMATION
    You agree that we have the right to share Your Information as set out in Section 3 and Section 4 of this Privacy Policy.
    1. Our Group.We may share Your Information with other companies within the Euronet Worldwide Inc. group of which we are part (see: www.euronetworldwide.com) and which includes, for the avoidance of doubt, companies operating under the “Ria”, “HiFX” and XE.com Inc. brands (“Our Group”) to enable Our Group to:
      1. assist us in providing Our Services to you and in such cases Our Group may use Your Information in accordance with paragraph 2.1 to 2.3 and 2.5 – 2.6 above; and
      2. store Your Information in databases held by Our Group in the United States of America.
      In addition, if you have agreed that we may do so when you accepted this Privacy Policy or under a separate agreement with us, our affiliate companies operating under the “Ria” brand may use Your Information that is shared with them for direct marketing purposes and to communicate with you in respect of their services.
    2. Your Instructions and transaction. We, or companies in Our Group who assist us in providing Our Services to you, may share certain aspects of Your Information with the person, or persons, acting as the pay-out correspondent agent to enable your transaction to be paid out i.e. to the person(s) who will pay out the payment transaction funds to your chosen beneficiary or to your chosen bank account, as instructed by you (a “Paying Agent”). Such Paying Agents will be able to view and process those parts of Your Information that we provide to them.
    3. Legal and compliance. We may share Your Information with a government body or competent regulatory authority (such as HM Revenue and Customs or the Financial Conduct Authority), with the police or other law enforcement agencies (for example, in connection with criminal prosecutions, money laundering or fraud investigations), or with other persons (which may include other companies) or bodies by order of a court or in connection with legal or regulatory requirements or objectives or for other lawful reasons (including taxation or audit purposes).
    4. Selected third party partners and suppliers. We may share Your Information with certain third-party suppliers who assist us in providing Our Services, including:
      1. Customer due diligence and compliance. We may share Your Information with third party provider(s) of electronic identification verification and checking services, who we have engaged to work with us in connection with our compliance requirements and objectives. Such third-party provider(s) of electronic verification and checking services will undertake verification / checking on and of Your Information and for such purpose(s) may use / process and store Your Information and share Your Information with their selected partners (for example, other identification database providers and / or credit reference or fraud prevention organisations) who may also use / process and store Your Information for such purposes. This may leave a disclosable record of a search against your credit and / or other similar electronic records about you.
      2. Payment providers. We may share Your Information with third party providers of payment services (such as merchant acquiring providers in connection with debit and / or credit card payments) who we have engaged to work with us to enable the provision of Our Service. Such third parties may use / process, store, share (for example, with issuing banks or similar financial institutions) and release Your Information for the purposes of or in connection with the processing of transactions you have requested, compliance (for example, fraud and anti-money laundering) or legal requirements, risk assessment (including as regards finance, IT, insurance and credit risk), anonymisation to facilitate their business analysis and / or the provision of their services.
    5. Debt collection. We may share Your information with credit control or debt collection agencies, for example, if you owe us money and we engage their services to recover it from you.
    6. Business sale or purchase. If we decide we want to sell all or any part of our business or assets and/or there is an offer to buy all or any part of our business or assets we may share Your Information with a prospective or actual purchaser and their advisers.
  4. SHARING, USING AND STORING YOUR INFORMATION OUTSIDE OF THE UK
    1. You agree that when we use and store Your Information as set out in this Privacy Policy it may involve the transfer of Your Information to, and use and storage of Your Information by, persons who work for us or companies in Our Group who are located in countries outside of the United Kingdom, including in the European Economic Area (which comprises the EU member states, Iceland, Lichtenstein and Norway) (the “EEA”) and outside the EEA (including to persons and companies in Our Group located in the United States of America and / or Canada).
    2. You agree that when we share Your Information as set out in this Privacy Policy (for example, with third party provider(s) of customer due diligence services or payment services or to Paying Agents as set out at Section 3) it may involve the transfer of Your Information to, and use and storage of Your Information by, persons which are based outside of the United Kingdom, including in the EEA and outside the EEA (including to persons and companies in the United States of America).
    3. You acknowledge that countries outside the EEA may have different, and in certain cases not as extensive, data and privacy protections as those applicable in the EEA.
  5. BENEFICIARY INFORMATION
    1. In addition to Your Information, when you ask us to provide you Our Service you will also be required to provide us with certain personal information (for example, name address, bank account details and / or identification details) related to your intended beneficiary to enable us to facilitate your requested transfer of funds to such beneficiary via Our Services and our Paying Agent(s). For these purposes, we or companies in Our Group who assist us in providing Our Services to you: (i) will also provide this information to the Paying Agent for the purposes of your requested transfer (and such Paying Agent may be based outside the EEA); (ii) may otherwise use such information as required for the purposes of Our Services; and (iii) may store such information for our compliance requirements and objectives.
    2. You confirm that you have the requisite authority to provide us with the beneficiary’s personal information and accordingly you agree to this paragraph 5.
  6. GENERAL INFORMATION SECURITY
    1. General. We use Your Information only in accordance with this Privacy Policy and will take all steps reasonably necessary to ensure we keep Your Information secure, for example by:
      1. encrypting Our Service available via Our Website with a secure 128-bit Verisign service;
      2. providing you with password protection and a log-in process;
      3. making Our Service available via Our Website automatically log you out after several minutes of non-use;
      4. disabling your access after multiple failed log-in attempts;
      5. maintaining our servers in multiple secure locations and having our online service penetration tested regularly by external experts; and
      6. restricting access to Our Website (or parts thereof) if we deem it reasonably necessary.
    2. The internet. The internet is not a secure environment. While we take reasonable measures to keep Your Information secure, we cannot guarantee online data security. We are not liable to you for any loss of data, injury or harm which occurs to you as a result of the transmission of Your Information over the internet, unless this occurs as a result of our negligence or wilful misconduct or relates to loss that we cannot exclude under applicable law.
    3. Other websites. This Privacy Policy applies to Our Website (i.e. riamoneytransfer.co.uk) only. Our Website may contain links to other web sites, and other web sites, in turn, may contain links to Our Website. We are not liable or otherwise responsible for the privacy policy and cookie policy of such other websites or the practices or content of such other website operators.
    4. Passwords and username. You play an important in protecting Your Information. Please safeguard your username, password and any other information we provide to you in connection with your account, money transfer and/or Our Service. You agree to inform us immediately via the contact details set out at Section 9 if you become aware of any actual or suspected unauthorised access or other security breach.
  7. COOKIES
    1. Cookies are small, often encrypted text files, located in your internet browser and are used by most websites. We may collect such cookies and use them to help personalise your online experience, ensure you can navigate Our Website efficiently and perform certain functions.
    2. You are not obliged to accept cookies that we send to you and you can modify your browser so that it will not accept cookies. You should follow the instructions in your browser (usually located within the "Help", "Tools" or "Edit" facility) to disable cookies. Due to their core role of enhancing or enabling usability or site processes, disabling cookies may prevent you from using certain parts of Our Website and it may also mean that some features on Our Website will not function.
    3. Our Cookie Policy is available by clicking the “Cookies” link on Our Website. You may also wish to visit www.aboutcookies.org or www.allaboutcookies.org both of which contain comprehensive information for a variety of browsers.
  8. YOUR RIGHTS
    1. We are required to handle information which we hold about you that is capable of identifying you (either alone or with any other information we may hold about you) in accordance with the Data Protection Act 1998 (the “Act”), which regulates the use of "personal data" in the United Kingdom.
    2. You have the right under the Act to ask us in writing for details concerning the personal data we hold about you. Your right of access to such personal data can be exercised in accordance with the Act and we may charge you an administration fee for providing you with this information.
    3. You also have a right to ask us not to use your personal data for marketing purposes. You can exercise your right to prevent such processing in accordance with paragraph 2.4 above (i.e. by checking certain / applicable boxes on the forms we use to collect Your Information on Our Website) or by contacting us at 0800 085 5955 or support@riamoneytransfer.co.uk
    4. You can find out more about the Act and your rights by visiting the website of the Information Commissioner at www.ico.gov.uk. The Information Commissioner's Office can also be contacted by telephone on 0303 123 1113.
  9. HOW TO CONTACT US
    1. If you have any questions about our Privacy Policy, Your Information or if you wish to exercise any of your rights, please contact us in writing by telephone at 0800 085 5955, email to support@riamoneytransfer.co.uk, or post to Ria Customer Services, 75 Baker Street, London, W1U 6RE, London.

Euronet Payment Services Limited (“EPS”), trading as Ria, is registered in England (6975932) with its registered office at 6th Floor, Watson House, 54 Baker Street, London, W1U 7BU. EPS is authorised by the Financial Conduct Authority under the Payment Services Regulations 2009 (FRN:504630)