WeSwap.com Limited, a company registered in England and Wales under company number 07189664 and having its registered office at Unit 6, Spectrum House, 32-34 Gordon House Road, London, NW5 1LP, UK (“WeSwap”) is committed to preserving and respecting the privacy of all visitors to www.weswap.com (“Our Site”). Please read the following Policy to understand how we use and protect the information that you provide to us.
For the purposes of the Data Protection Act 1998 (the Act), the data controller is WeSwap.
By registering, using, placing an order or arranging a currency swap on this site, you consent to the collection, use and transfer of your information under the terms of this Policy.
INFORMATION THAT WE COLLECT FROM YOU
- When you visit, register or order products or services from Our Site you may be asked to provide certain information about yourself including your name, contact details, bank account information and details of proposed currency swaps.
- We may collect and process the following data about you:
- Information that you provide by filling in forms on Our Site. This includes information provided at the time of registering to use Our site, subscribing to our service, posting material or requesting further services. We may also ask you for information when you enter a competition or promotion sponsored by us, and when you report a problem with Our Site. As part of the registration process we may utilise the services of one or more third parties, including credit reference agencies, to confirm your identity and conduct anti-money laundering (AML) and anti-fraud checks. We will ask you to provide us with information and documents for this process.
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of transactions you wish to carry out through Our Site and of the fulfilment of your orders.
- Details of your visits to Our Site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
USE OF YOUR INFORMATION
- We use information held about you in the following ways:
- To ensure that content from Our Site is presented in the most effective manner for you and for your computer.
- To provide you with information on WeSwap promotions which we feel may interest you. If you do not want to receive marketing communications or promotional correspondence from WeSwap, please contact us at email@example.com.
- To carry out our obligations arising from any contracts entered into between you and us.
- To help further transactions you wish to carry out through Our Site and of the fulfilment of your orders.
- To allow you to participate in interactive features of our service, when you choose to do so.
- To notify you about changes to our service.
- To carry out our legal obligations in relation to anti-fraud, anti-money laundering and other legislation.
- We may also use your data, or permit selected third parties to use your data (with your consent), to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by post or telephone.
- If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale to you (with your consent).
- If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
- If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box when applying for an account and subscribing to our service.
- We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, people aged between 18 and 30 travelling to Spain).
- We may also make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
WHERE WE STORE YOUR PERSONAL DATA
- The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your request, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
- All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using Secure Server technology indicated by the green padlock in the address bar.
- As part of our initial registration process you will be given or asked to create a password. Should you wish to transact on Our Site, for example by placing and matching currency trades, and manage your account you will be asked to complete a more detailed registration procedure. Where we have given you (or where you have chosen) a password which enables you to access certain parts of Our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
- Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
DISCLOSURE OF YOUR INFORMATION
- We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
- We will disclose your personal information to:
They will also share transaction details with the card schemes (e.g. MasterCard)
- our banking partner with whom you have your on-line account (or e-wallet account) so that they can maintain and service your e-wallet account and issue you with a pre-paid currency card linked to your e-wallet account; and
- our technology partners so that they can authorise and manage card transactions against your e-wallet account.
- We may also utilise the services of third parties, including credit reference agencies, to conduct checks and help us verify your identity and the identity of any other card holder. This allows us to comply with “know your customer”, anti-money laundering and other legal requirements which are aimed at detecting and preventing financial crime.
- We may also disclose your personal information to third parties:
- If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If WeSwap or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation. This includes exchanging information with law enforcement bodies and regulatory authorities for the purposes of complying with anti-money laundering and prevention of terrorism requirements and fraud protection. You should be aware that we are required to report any suspicious transactions to the authorities.
- In order to enforce or apply our Terms of Service and Terms of Website Use, this Policy, the IDT Terms and Conditions and other agreements.
- To protect the rights, property, or safety of WeSwap, our customers, or others.
RETENTION OF YOUR INFORMATION
WeSwap is bound by the Money Laundering Regulations 2009 and therefore uses a five-year retention period. This means that WeSwap is required to store Your personal data for five years, even if You do not complete your application.
ANTI-MONEY LAUNDERING AND COMPLIANCE
You should assume all information provided to us is available to law enforcement bodies and regulatory authorities in both the country of origin of the funds, and the destination country of the funds.
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
- For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve Our Site and to deliver a better and more personalised service. Some of the cookies we use are essential for the site to operate. Cookies make it easier for you to log on to and use Our Site during future visits. They also allow us to monitor website traffic and to personalise the content of the site for you.
- A “session cookie” is used to enable you to leave and re-enter Our Site without re-entering your password. Our web server will record the pages you visit within Our Site.
- We use persistent cookies to compile relevant user data that assists with business development and third party cookies for website usage analysis.
ACCESSING AND UPDATING
You are entitled to see the information held about you and you may ask us to make any necessary changes to ensure that it is accurate and kept up to date. If you wish to do this, please contact us. We are entitled by law to charge a fee of £10 to meet our costs in providing you with details of the information we hold about you.
- You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
- Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
CHANGES TO OUR POLICY
Any future changes to this Policy will be posted to the site and, where appropriate, through e-mail notification.
All comments, queries and requests relating to our use of your information are welcomed and should be addressed to email@example.com or by writing to the Privacy Team at WeSwap.com Limited, 6 Spectrum House, 32-34 Gordon House Road, London NW5 1LP, UK, attention of Simon Sacerdoti.