This Policy is effective from 25th May 2018
WeSwap.com Limited, (“WeSwap”, “we” or “us”) is committed to preserving and respecting the privacy of all visitors to:
Our Website - www.weswap.com (“Our Site”)
Our Mobile App (“App”), once downloaded onto your mobile device and
Any of our other services available via our site or app (our “Services”)
This policy, in addition to our General Terms of Service is applicable to the usage of the above site, app and services. Please read the following Policy to understand how we use and protect the personal information you provide us, that we collect from you and that we processed and use.
WeSwap is the Data Controller responsible for the safety of your personal information. We are registered as a Data Controller with the Information Commissioners Office (ICO), registration number Z3012766 refers.
Our registered address is:
6 Spectrum House
32-34 Gordon House Road
DATA PROTECTION OFFICER
In order to ensure that our responsibilities to you in relation to your personal data are met, we have an appointed Data Protection Officer (DPO).
Below are some of the important functions of the DPO:
To be WeSwap’s contact point for any relevant supervisory bodies (such as the ICO)
To ensure we comply with relevant Data Protection Laws (including GDPR)
To ensure that all WeSwap staff are trained on Data Protection issues, and that our internal systems and controls are reviewed on a regular basis.
INFORMATION THAT WE COLLECT FROM YOU
When you visit, register or order products or services from Our Site, App or Services, we may collect and process the following personal information:
Information that you provide by filling in forms on Our Site or App at the time of registering to use Our site or App, subscribing to our service, posting material from any social network or online account or requesting further services. This includes name, telephone number, email address, residential address, date of birth, nationality, bank account information, other identification details (e.g. drivers licence or passport numbers) and details of proposed currency swaps. 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, App or Service.
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 your account and transactions with us, through Our Site, App or Services (including the fulfilment of your orders).
Details of your visits to Our Site or App – device advertiser ID for both iOS and Android, 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 and App are presented in the most effective manner for you and for your computer or device.
To carry out our obligations arising from any contracts entered into between you and us (i.e. to help us manage your account).
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 enable transactions you wish to carry out through Our Site, App or Services 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 attribute which partner you may have come to us from
To carry out our legal obligations in relation to anti-fraud, anti-money laundering and other legislation.
To develop new products
To improve or modify our Services and
To conduct aggregate analysis and develop business intelligence enabling us to operate, protect, make informed decisions, and report on the performance of, our business
We may use other data for purposes other than those above, however, we will comply with applicable laws and contractual terms. In some countries (for example, European Economic Area countries), local legislation may require us to treat some or all of this other data as “personal data” under applicable data protection laws. Where this is the case, we will process this only for the same purposes as Personal Data under this policy.
WHO WE SHARE YOUR INFORMATION WITH
WeSwap works closely with third parties in order to help deliver services to you. These third parties are business partners (such as those we partner with to offer additional Services like credit), technical sub-contractors, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies and fraud prevention tools. Information we may collect about you from such parties can include credit search information, information which helps us to verify your identity or information relating to your payment transactions.
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 (with your consent) 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.
Prior to the transmission of your information outside the EEA, we will ensure that adequate measures are in place to ensure the security of your data which are equal to EEA standards 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 or App, 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 or App; 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:
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.
These third parties may change from time to time, however, our current partners are:
IDT Financial Services Limited; Mastercard; Yalamanchili; Stripe; LexisNexis; IDV; Google; Worldpay; Appsflyer; Zendesk; Rackspace Limited, OneSignal, Marketing Cloud, Twilio, Sendgrid and Amazon Web Services.
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
In order to comply with our Anti Money Laundering obligations, WeSwap has implemented a five-year data retention period. This means that WeSwap is required to store your personal data for five years after you have closed your account. This also applies even if you do not complete your application.
ANTI-MONEY LAUNDERING AND COMPLIANCE
All information provided to us must be made 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 or device, including where available your IP address, operating system and browser type, for the prevention of financial crime, 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 reasons outlined above, 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 or device’s hard drive. They help us to improve Our Site or App 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 or App during future visits. They also allow us to monitor website traffic and to personalise the content of the site for you.
For more information on Cookies, Click here to access our Cookies Policy document following this one.
THIRD PARTY LINKS
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.
We have created a Notifications section within your account on our Site and App which aims to provide you with choices regarding the use of your information, particularly for marketing and advertising. This allows you to make certain decisions about your personal information use in relation to marketing emails and push notifications.
Below is an explanation of how we use your information for marketing purposes and how you can 'opt-out' from receiving any marketing communications from us whenever you want.
Promotional Offers from WeSwap
We may use your personal information to decide which products, services and offers may be relevant for you.
We will send you marketing communications if you have registered and/or utilise our Services and, you have not opted out of receiving marketing notifications.
Prior to sharing your personal information with any third parties for marketing or promotional purposes, we will obtain your express consent.
At any time, you can request that we or associated third parties stop sending you marketing messages by adjusting your marketing preferences on the notifications section of your account on our site or App. Alternatively, you can click on the unsubscribe link on any marketing message sent to you.
You have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, however, we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please be aware that we may not always be able to comply with your request of erasure for legal reasons which will you will be advised of at the time of your request. As previously noted above, WeSwap are required to retain certain information for a minimum of 5 years, this requirement supersedes any right to erasure requests under applicable data protection laws.
Object to processing of your personal data. This is in situations where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may be able to show that we have compelling legitimate grounds to process your information which override your rights. Due to regulatory requirements, WeSwap has numerous obligations to process and retain certain personal information for compliance purposes, these requirements supersede any right to objection requests under applicable data protection laws. If you object to the processing of certain personal information, we may not be able to provide you with our services and it is likely we will have to terminate your account.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please be aware that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel your use of our Services but we will notify you if this is the case at the time.
Request the transfer of your personal data to you or to a third party. We will provide you with your personal information in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. Please be aware that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. Please be aware, if you withdraw your consent, we may not be able to provide our Services to you and we will advise you of this following receipt of your request.
Should you wish to access any of your rights, please contact us at Support@weswap.com
DATA SUBJECT ACCESS REQUESTS (DSAR)
Should you wish to make a DSAR, please contact Support@weswap.com outlining what data you are requesting, and the reason for your request. You will not have to pay a fee, however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO OUR POLICY
Any future changes to this Policy will be posted to the site and, where appropriate, through e-mail or push notification.
All comments, queries and requests relating to our use of your information are welcomed and should be addressed to firstname.lastname@example.org or by writing to the Data Protection Officer at WeSwap.com Limited, 6 Spectrum House, 32-34 Gordon House Road, London NW5 1LP, United Kingdom
You should be aware that when you access or use our content, products and services, 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 perform various different functions, and the purpose of this policy is to give you a clearer understanding of:
What cookies are
WHAT ARE COOKIES?
Cookies are used by our websites to improve your online experience and to ensure that relevant content and functions are delivered and used more effectively.
We use both session cookies and persistent cookies to perform various functions across our sites.
Session cookies are downloaded to your device temporarily for the period that you browse a particular website; these cookies might allow you to navigate between pages more efficiently or enable websites to remember the preferences you select. Persistent cookies can be used to help websites remember you as a returning visitor or ensure the online adverts you receive are more relevant to you.
When you visit our websites, Cookies will be placed on your device in two ways. Cookies placed by WeSwap, as the site operator, are called "first party" Cookies. Cookies may also be placed on your device by a party other than WeSwap, such cookies are known as "third party” cookies. Examples of the uses of third party cookies include collecting information about browser habits and providing tailored content to you.
While there are many different uses for first and third party cookies, the cookies used by us all fall into one of the following four main categories of cookies:
Strictly Necessary Cookies
Third Party Marketing / Targeting Cookies
Set out below is more information on these categories of cookies, including their purpose and whether these cookies collect personal data:
Strictly Necessary Cookies
These cookies are strictly necessary to enable you to navigate our website and provide you with a more personalised service. They are used to provide content to you, as a user, and to provide products and services that you have requested.
Such cookies are essential to help your device download or stream information so that you can navigate around our websites and use its features.
Here are some examples of strictly necessary cookies:
To position information on your device or screen so that you can see and use our websites;
To keep you logged in when you use our website so you are not required to log in every time you visit; and
Remember the language.
These cookies do not remember your preferences or username beyond your current visit.
Yes some of these cookies do collect your personal data in order to function. They may collect the following types of personal data:
Identify you as being logged in our websites
These cookies are used to recognise you when you return to our website and allow us to remember the choices you make and to enable us to provide improved features. They also enhance the functionality of our website by storing your preferences. Functional cookies record information about choices you've made (such as language preference) and allow us to provide more personal features.
Here are some examples of the uses of performance cookies:
To remember your preferences and settings such as language, location and marketing preferences, since your last visit;
Some of these cookies do collect your personal data, to enable us to provide the services as outlined above.
These cookies are used to collect information on website usage. Such cookies are used to provide aggregated statistics on visitors to our websites. These statistics are used for internal purposes to help us to analyse and improve the performance of our websites, providing a better user experience.
Here are some examples of the uses of performance cookies:
To provide statistics on how our websites are used;
To see how effective our adverts are; and
To assess errors within the user experience.
Additionally, we use a number of tools to assess cookie information at an aggregate level to carry out analytical functions on our site including, Google Analytics and VWO.
While these cookies do not identify you personally while you are not logged in, they will collect your browser information and anonymised data, for the purposes outlined above.
In certain cases, some of these cookies are managed by third parties such as Google Analytics. These third parties are not capable of using these cookies for any purpose other than those outlined above and they are unable to identify with these cookies.
Third Party Marketing/Targeting Cookies
These cookies are used to deliver WeSwap advertisements relevant to you, based upon your activity on our website.
They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign.
These cookies record your visit to our website, the pages you have visited and the actions you have taken. We will use this information to make our website and the advertising displayed more relevant to you. We may also share this information with third parties for this purpose and to measure the effectiveness of an advertising campaign.
Targeting cookies are also used to:
Collect information about browser habits to target website content and to target advertising;
Link to social media networks who may use this information about your visit to target advertising to you;
To provide advertisers with information on your visit so that they can present you with adverts that you may be interested in;
Deliver content and marketing communications tailored to your interests based on information from your visit;
To perform site retargeting. A retargeting pixel (a tiny unit of code) on our webpage leaves a cookie in the user’s browser, which causes our adverts to be displayed or to not be displayed to you when you visit certain websites within the retargeting network (e.g. Google Display Network); and
To perform search retargeting, which allows our adverts to be displayed on third party webpages, based upon your previous web search activities.
These cookies are placed by third party advertising networks with our permission.
You can amend your browser settings to block some or all cookies. To do this, follow the instructions provided by your preferred web browser. For your ease of reference we have provided the links below which provide instructions on how to remove and delete cookies for some of the more common web browsers. Please be aware that if you block cookies from the websites, some or all the website's functions may not perform as intended:
Mobile phone users may have to refer to their handset manual for details on how to block cookies using their mobile browser. For more information about online behavioural advertising cookies and opt-out controls, please go to http://www.youronlinechoices.eu/.