1. A bit about us
We are TransferGo Ltd. Our registered office is 241 Southwark Bridge Rd, London SE1 6FP, United Kingdom. Our company number is 07914165. We’re registered with the Information Commissioner's Office (ICO), the data protection regulator in the UK, to use personal data. Our registration number is Z316680X. TransferGo Lithuania UAB is an electronic money institution established in the Republic of Lithuania, authorised and regulated by the Bank of Lithuania. Registered address: Palangos str. 4, Vilnius, Lithuania, number of registration 304871705, FI Code 32400. Authorization code: LB000461
2. Our promise
We promise to protect and respect your privacy. We will: ✓ always keep your data safe and private ✓ never sell your data ✓ let you review and manage your privacy settings whenever you like.
3. Why this document matters
Data protection law calls us the 'data controller' of your personal data. This comes with certain responsibilities about how we use that data. We’ve tried to make them as clear as possible in this document. If you have any concerns about how we use your data, please contact our Data Protection Officer at [email protected].
4. What your rights mean for us
5. How to exercise your rights
If you wish to exercise any of these rights, please email us at [email protected]. When you do, we may ask you for proof of ID—we need to make sure it’s you so we can deal with your request securely. If you’re unhappy with how we handle your data, you can complain to your local data protection authority.
6. Collecting your data
We will collect your personal data when you use:
our website at https://www.transfergo.com
the TransferGo app.
This table below explains exactly what, how and when we collect it.
Type of data How we collect it You give us this data when you: • register to use TransferGo • fill in any forms • correspond with us Your name, address, nationality and date of birth. Your email address, phone number and details of the device you use (for example, your phone, computer or tablet). Your username, password and other registration information. Details of your bank account, including the account number, sort code and IBAN. Details of your debit cards and credit cards, including the card number, expiry date and CVV. Identification documents (for example, your passport or international identity card), copies of any documents you have provided for identification purposes, and any other information you provide to prove you are eligible to use our services. Records of our communication, if you contact us or we contact you. Your photo or video, captured during an identity verification session. Whenever you use the TransferGo website or app 1) Technical data, including: - the IP address connecting your computer to the internet - your login data, browser type and version - your time-zone setting - operating system and platform - type of device - unique device identifier (for example, your device's IMEI number, the MAC address of the device's wireless network interface, or the mobile phone number used by the device) - mobile network data - mobile operating system - the type of mobile browser you use, and so on. 2) Data about your visit, including: - the links you've clicked on through and from our site (including date and time) - services you viewed or searched for - page response times - download errors - length of visits to certain pages - page interaction data (such as scrolling and clicks) - methods used to browse away from the page. 3) Data on transactions, including: - the transaction date, time and amount - the currencies and exchange rate used - beneficiary details - the payment method you used. 4) Data stored on your device, including: - contact data from your address book (if you grant us access) - login information - photos, videos or other digital content - check-ins (sometimes, we call this content information). Our app collects this data regularly to stay up to date. We use GPS to track your location (if you have location services switched on in the TransferGo app) We sometimes track your location—to figure out where you’re sending money from, for example. When you submit documents for verification, or make a transaction This can include identity checks, or details of financial transactions.
7. Why we need your data
We can’t use your data without a legal basis (a valid legal reason). That legal basis will be one of the following:
To honour our contract and agreements with you We simply can’t provide our services without certain data about you. To meet our legal obligations Some laws demand that we collect and store certain data about you—laws against money laundering, for instance. For legitimate interests We sometimes collect and use your data, or share it with other organisations. We only do this when there’s a legitimate reason that is reasonable when balanced against your right to privacy—for instance, you’ve asked to use a new card and we have to send your data to the partner that provides the service. You’ve given us your consent You agree to us collecting your data when you use the TransferGo website or app, or when you tick a box that says you’re happy for us to use your personal data in a certain way.
Those are the only grounds we ever have for using your personal data. Read on to find out how we use it.
8. How and when we use your data
We collect your data so we can: • provide our services • protect against fraud • tell you about products and services you might like • maintain our service • enable social interactions • meet our legal obligations We’ll go into more detail about each of these below.
Providing our services For you to use TransferGo, we need to use some of your personal data at various stages. When you apply, we use it to: • check your identity and decide whether or not to approve your application to use TransferGo. This is part of our Know Your Customer (KYC) process and obligations. Once you’re a TransferGo customer, we use it to: • meet our obligations relating to any transactions you make • tell you about our products and services • help us develop new products and services. We also use your data to give you Customer Support, either by phone or by email. We may record these calls and emails, but only to train and monitor our staff so that they give you the best possible support. Protecting against fraud We use your data to check your identity. This is how we protect against fraud, stick to the law and confirm that you’re eligible to use our services. We also use it to understand your financial circumstances and manage fraud risks related to your TransferGo account. Telling you about new products and services that might interest you With your consent, we also use your data to: • inform you about other TransferGo goods and services similar to those you have already used or asked about • analyse our advertising, and make it more relevant to you • process applications for products and services that we offer and decide whether or not to approve them. Remember, you can ask us to stop sending you marketing information by adjusting your privacy settings. Maintaining our service As we keep our service up to date, we use your data to: • manage the TransferGo website and app (including troubleshooting, data analysis, testing, research, statistical and survey purposes) • make sure our website content is presented in the most effective way for you and your device (see the Cookies section for more information) • allow you to use our interactive features • tell you about changes to our services • help keep the TransferGo website and app safe and secure. Enabling social interactions We use your data to enable social interactions or to add extra functions that improve your experience of our product. For instance: we might use your Contacts to let you send money straight to a friend of yours. Meeting our legal obligations There are times when we may need to share some data about you: • with other organisations (for example, fraud-prevention agencies) • to meet our legal obligations or in connection with legal claims • to help detect or prevent crime.
9. Using your data for marketing
When you sign up to TransferGo, we give you the opportunity to opt in to offers and promotions. If you choose to opt in, we then use your data to tailor offers to you, so they’re more likely to interest you. You can opt out again at any time by going to the Settings in your app or browser. You can adjust your preferences, or tell us you don't want to hear from us, at any time. Just use the 'Privacy' section within the Settings section of the TransferGo app or click on the unsubscribe links on any marketing message we send you. We won't pass your details on to any outside organisations for their marketing purposes without your permission.
11. Sending your information outside Europe
12. Protecting your personal data
We store your data on our secure servers. All payment transactions carried out by us or our payment-processing providers are encrypted. Still, it’s important to keep your TransferGo passcode safe. Do not share it with anyone.
13. Storing your information
Anti-money-laundering laws demand that we hold information about you and your transactions for five years. We’re unlikely to hold your personal data for more than five years after you’ve stopped using our service, unless a claim or another legal reason requires us to hold on to it for longer.
15. Keeping you updated
If we change the way we use your personal information, we’ll update this policy. We’ll also let you know by text message, by email, or through the TransferGo website or app.