TransferGo KVKK(Personal Data Protection Law) Enlightenment Text and Privacy Policy

The basics

1. A bit about us

We are TransferGo Ltd.
Our registered office is 1a Old Street Yard White Collar Factory, London EC1Y 8AF, 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

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].

Your rights

Your personal data rights are protected by law. Here’s how we honour those rights.

4. What your rights mean for us

Your right	What it means
You have the right to be told about how we use your data.	That’s what this Privacy Policy is for: to explain exactly how we use your data, in as plain English as possible.
You can ask to see the data we hold about you. You can also ask for details about what data we process and why.	If you make a DSAR (a ‘Data Subject Access Request’), we’ll give you a copy of all your data that we hold. We can’t give you any information which is about other people, linked to an ongoing criminal or fraud investigation, or linked to settlement negotiations with you. We also won’t provide you with any communication we’ve had with our legal advisers.
You can ask us to correct your data if you think it’s wrong.	When you ask us to, we’ll correct incomplete or inaccurate data. We may need to check the accuracy of any new information you give us before we update your file.
You can ask us to delete your data.	You can ask us to delete your personal data if: • there’s no good reason for us to keep using it • you gave us consent to use it but have now withdrawn that consent • you object to us using it • we’ve used it unlawfully • we’re required to delete it by law. We may not always be able to agree to your request. As a firm authorised by the Financial Conduct Authority, we must keep certain customer information for at least five years. If you’ve closed your TransferGo account, we may not be able to delete your entire file because these regulatory responsibilities take priority.
You can object to us processing your data for marketing purposes.	You can tell us to stop using your data for marketing. Simply head to your Settings in your browser or app, click on ‘Privacy’ and adjust your Communication Channels.
You can object to us processing other information (if we’re using it for legitimate interests).	If we’re using your data for ‘legitimate interests’ and you don’t want us to use it, you can object. But if there’s an overriding reason (a legal reason, for instance) for us to use the information, we can decline your request. If you object to us using information which our services depend on, we won’t be able to provide you with our service—so we may have to close your account.
You can ask us to restrict how we use your data	You can ask us to suspend using your data if: • you want us to check if it’s accurate • our use of the information is unlawful but you don’t want us to delete it • we no longer need the information, but you want us to keep holding it for you in connection with a legal claim • you have objected to us using your information (see above), but we need to check whether we have an overriding reason to use it.
You can ask us to transfer your personal data to you.	If we can, and the regulations allow it, we will give you your personal information in a structured, commonly-used, machine-readable format.
You can withdraw your permission.	You can withdraw your consent at any time. Simply change your settings in the TransferGo website or app, or send an email to [email protected]. (Bear in mind: our use of your personal information is lawful from the moment you give your consent up to the moment you withdraw it.)

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.

Our responsibilities

6. Collecting your data

We will collect your personal data when you use:

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.

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.

10. Sharing your information with others

As well as with TransferGo companies (TransferGo Ltd and TransferGo Lithuania), we do sometimes share your information:
• with suppliers
• for legal reasons
• with social media platforms.
Here’s why this might happen.

Type of supplier	Why we share your information
Our IT service providers	So we can provide our online service.
Our banking and financial-services partners and payment networks	So we can transfer your money internationally.
Advertisers	So we can promote our services. (We only provide anonymous information—for instance, ‘76 women over 40 clicked on this advert’.)
Analytics providers and search information providers	So we can improve our website or app.
Customer-service providers, survey providers and developers	So we can provide you with our services.
Communications services providers	So we can send you emails, push notifications and text messages.
Fraud-prevention agencies	So we can check your identity and if you’re eligible to use our products.

Third party ID verification

We partner with ID verification specialists to verify your identity in a secure and expert way. Most of these checks are automated. Sometimes, when the automated process can’t make a decision on its own, it will ask a human to help complete the check. Some verifications can only be performed by humans.

You have the right to request information or object to a decision at any time. Unless a specific legal process prevents us from doing so, we will share that information with you and explain our reasons whenever possible. The final decision regarding verification lies with us, TransferGo, rather than with our third-party providers.

For legal reasons
We also share your data with fraud-prevention agencies to:
• check your identity
• protect against fraud
• keep to anti-money-laundering laws
• confirm that you’re eligible to use our products and services.
If fraud is detected, we may refuse you certain services or close your account.
For more details on how your data will be used by us and these fraud-prevention agencies, please email our Data Protection Officer at [email protected].

We may also need to share your data with other third-party organisations:
• if we have to do so under any law or regulation
• if we sell our business
• in connection with criminal or fraud investigations
• to enforce our rights (and those of customers or others)
• in connection with legal claims.

Social media platforms
When we use social media for marketing, your information may be shared with social media platforms, who may use it to check if you also hold an account with them. If you do, we may ask the advertising partner or social-media provider to:
• use your information to send our adverts to you when we think you might like one of our new products
• not send you our adverts, because you already used the service advertised
• advertise to people with a similar profile to you (eg. if one of our services might appeal to someone with interests similar to yours).

If you want us to stop sharing your personal information for marketing purposes, just let us know: via the TransferGo website or app, or by emailing [email protected].
You can also manage your marketing preferences directly with the social media platforms you’re signed up to.

11. Sending your information outside Europe

As we provide an international service, we may sometimes need to transfer your data outside the European Economic Area (EEA). When we send your payments to banks around the world, we might also send your data along with them. We do this to follow global legal and regulatory requirements, and to provide ongoing support services. We may share your personal data with fraud prevention agencies across and outside Europe. We always do our best to make sure that your data is handled securely and in line with our Privacy Policy and data protection laws. If you would like more information, please contact us through the TransferGo website or app, or email [email protected]

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.

14. Cookies

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.