www.currencyfair.com, (the “Website”) is owned and operated by CurrencyFair Limited (“CurrencyFair”). We comply with the Data Protection Acts 1998 and 2003 (Ireland) as well as the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011, The Privacy Act 1988 (Cth) (Australia) and the Australian Privacy Principles (together “Data Protection Rules”).
When used in this policy, “personal data” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, the possession of the data controller, i.e. CurrencyFair.
This Privacy Statement sets out the basis, on which any personal data you provide to us, we collect from you through our Website, applications and services, or our operating partners is processed by us.
Statement of Data Protection and Privacy
Personal Data is any information about you and may include your name and address, date of birth, bank account details, and any other information you may provide.
- We are committed to and comply with all relevant Data Protection Rules of the jurisdictions within which we operate.
- We will ensure that your personal data can be used only by authorised personnel for legally authorised purposes.
- We will only use personal data in our possession for its intended specific and authorised purpose.
- Your personal data may be transferred to contracted third parties, e.g. banks and other firms external to us or within our group for the purposes of providing our services to you or to comply with legislation.
- Your personal data will be retained and maintained in accordance with applicable Data Protection Rules.
- Upon written request, we will amend the personal data we hold if factually incorrect, and provide you with a copy of any personal data held by us.
- All our employees are trained in applicable Data Protection Rules and will act with due care and diligence when handling personal data.
The information we receive and collect from prospects and customers is strictly related to our customers and the services we offer, provide and execute. The information we collect may include financial and other information. We understand that such information is sensitive and take appropriate steps to protect the confidentiality and security of all information collected by us in accordance with this Privacy Statement.
When you complete and submit a form on our Website, send us an e-mail, send us a letter, or contact us by telephone to solicit information about our services or us in general, we may store the inquiries and their contents.
Information you submit via an inquiry is collected only with your knowledge and active participation, and may be used by us to respond to your inquiries, to contact you, to inform you of services of ours or our partners that we think may be of interest to you.
Should you subscribe to receive marketing information from us, you may choose to stop doing so at any time by following the unsubscribe instructions included in any email you receive or you can contact us via our Help and Support page. If at any time, you wish to re-subscribe to our marketing lists you should also contact us..
We will send you information about product changes or enhancements from time to time. You may not unsubscribe from these as they may contain important information relevant to your account with us, e.g. changes to our bank details.
In accordance with the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 and 2013, as amended, the Payment Services Directive, and other jurisdictional anti-money laundering laws and regulations, we may share personal information about you with third parties such as other companies within the CurrencyFair Group, our clearing banks, and 3rd party service providers or software applications, in order to process your transactions, verify your identity and protect against fraud, money laundering and terrorist financing. We may also share your personal details with certain regulatory bodies, as is required by law. The data we collect from you is stored in the European Economic Area (“EEA”) but may be transferred to and stored at a destination outside of the EEA. Staff operating outside of the EEA may also process your personal data. By submitting your personal data to us, you agree to this transfer, storing and processing.
Right of Access, Rectification and Erasure
Under the Data Protection Rules, you have a right to seek access to information that we hold about you. You also have the right to ask us to correct information about you that is inaccurate, incomplete or out of date.
To obtain a copy of your personal information you should write to us at the address stated below, quoting reference “Data Access Request”, along with a payment to CurrencyFair Limited for €6.35 or contacting us via our Help and Support page. We will ordinarily provide you with a printout of the relevant personal information from our current databases, or with photocopies of records that are held only on current paper files. Your request will be dealt with as soon as possible and in any event within 40 days.
You also have the right, in certain circumstances to request that we delete your personal information. Any such request should be made in writing to us. Please see the note on Retention below.
IP Address and Device Data
When you visit our Website, we collect your IP address and other information such as the domain and host from which you access the internet, the browser, browser version, and the operating system. We do so in order to administer our services and optimise our Website for you and to diagnose problems with our Website. We also use the information to assist in the fight against fraudulent or malevolent use and to ensure a better user experience. We may also employ location services to determine your approximate location.
Telephone Call Recording
You consent to the electronic recording of all telephone conversations, initiated by us or initiated by you, and the utilisation of such recordings as evidence by either you or CurrencyFair in any dispute or anticipated dispute between you or CurrencyFair, or any third party associated with the call, or in relation to any dealings between you and CurrencyFair.
We must comply with a number of statutory and regulatory requirements in relation to the retention of data. Therefore, your personal data will be retained for a period of no less than seven years following the closure of your account with us, or seven years from the date of the last transaction, whichever is the later.
We take our security responsibilities very seriously at CurrencyFair, and employ the most appropriate physical and technical measures, including staff training and we review these measures regularly.
We take appropriate measures to ensure confidentiality of all information, both paper and electronic required for the operation of our business. We take appropriate steps to protect data stored or transmitted against accidental or unlawful destruction, accidental loss or alteration, and unauthorised or unlawful storage, processing, access or disclosure.
Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while CurrencyFair will take all reasonable steps to protect your Personal Data, the nature of the Internet is such that CurrencyFair cannot guarantee or warrant the security of any information you transmit to us while using CurrencyFair online. Any information that you do provide to CurrencyFair is at your own risk.
Please read our Security Statement for more detailed information.
CurrencyFair takes all complaints seriously, and will investigate all complaints. For details of how CurrencyFair deals with complaints generally, please refer to our Complaints Policy, available at http://www.currencyfair.com/trust/complaints-procedure/.
If you believe there has been a breach of the Data Protection Rules, or if you have any other concerns about CurrencyFair’s handling of your personal information, please contact our customer services team in the first instance. Our customer services staff will be pleased to help and complaints can often be resolved at this early stage. If your concerns cannot be resolved at the first point of contact, the matter should be referred to CurrencyFair’s Client Services Manager (contact details below). At this stage, CurrencyFair will ask you to set out your complaint in writing providing as much detail as you can so that the Client Services Manager can fully investigate your complaint.
If for some reason, we are unable to resolve your complaint to your satisfaction, you have the right to bring this to the attention of the relevant authority.
Australian Customers – Office of the Australian Information Commissioner (OAIC)
OAIC is a government agency which oversees the relevant Act and related legislation, and investigates complaints about handling of personal information under the Act. OAIC will in many cases only investigate cases once CurrencyFair has been given the opportunity to resolve your complaint internally. You may lodge your complaint with OAIC by sending the necessary documents and information to: Australian Information Commissioner, GPO Box 5218, Sydney, NSW 2001, Australia.
All Other Customers – Data Protection Commissioner (DPC)
The Data Protection Commissioner is responsible for upholding the rights of individuals as set out in the Acts, and enforcing the obligations upon data controllers. The Commissioner is appointed by Government and is independent in the exercise of his or her functions. Individuals who feel their rights are being infringed can complain to the Commissioner, who will investigate the matter, and take whatever steps may be necessary to resolve it. You may lodge your complaint with the DPC by sending the necessary information to: Canal House, Station Road, Portarlington, Co. Laois, Ireland.
If you have any questions or concerns about this Privacy Statement or the collection, use or handling of your personal information, you may contact the Client Services Team or the Client Services Manager on +353 (0) 1 246 1127 or via our Help and Support page.
You may also write to us at CurrencyFair Limited, Colm House, 91 Pembroke Road, Ballsbridge, Dublin 4, Ireland.
Changes to this Privacy Statement
We continue to review our controls and processes to ensure that they are effective in meeting our commitments and obligations to our customers. We reserve the right to change this Privacy Statement without notice at any time and from time to time, including as needed to comply with the laws and regulations of the jurisdictions within which we operate. Your continued use of our services will constitute acceptance of those changes.