We at Pure FX are committed to ensuring that we manage your personal data professionally and in compliance with all applicable data protection laws, including the General Data Protection Regulations (“GDPRs”) applicable from 25th May 2018.
What is this policy about?
What is my personal data?
Your personal data is any information relating to you if you are a natural person. It includes things like your name, address, telephone number and email. It can also include things like your date of birth, relationships and financial information, such as your credit history. It does not include information about companies.
What is processing?
Processing means just about anything we do with the personal data which we have about you, including collecting, recording, using, storing or sharing it with others. For example, we process personal data so we can answer your queries and provide you with our products and services. We might get this information from you or we might get it from others.
ABOUT PURE FX
We are Pure FX Limited.
We are authorised as a payment institution and regulated by the Financial Conduct Authority (FCA) for the purposes of providing payment services. We are registered with HM Revenue & Customs (HMRC) as a money services business.
Where you provide us with your personal data, such as where you have a query, ask for an exchange rate quote, register with us or ask us to perform a transaction for you, we will be responsible to you as a “controller” in accordance with data protection law.
WHAT PERSONAL DATA ARE WE PROCESSING?
The sort of personal data which we collect might include:
Where we deal with enquiries from or provide products and services to a business, we may collect similar information but only that which relates to natural persons (such as that information relating to any director, partner, trustee or shareholder of, or any named contact or authorised person at, the business but not any other information) is considered personal data.
WHAT PROCESSING ARE WE DOING AND WHY?
We may process personal data:
so we can take pre-contract steps at your request or perform our contract with you, including
to comply with a legal obligation on us or perform a task in the public interest, including
for our legitimate interests or those of a third party, including
We may also further process your personal data for any purpose compatible with the above, including:
We may record texts, emails or telephone calls, including for training purposes, customer service, quality control, performance improvement, to verify any comments you or any of our dealers may make during any conversation, for regulatory purposes and for the purposes of fraud or crime prevention and detection.
We have CCTV in operation on site and, should you visit our premises, it is possible that images of you may be recorded.
If you have been referred to us by one of our affiliates (such as an estate agent who you are dealing with abroad and who you have asked to contact us on your behalf or where you have contacted us directly via their website) we may use your personal data to make initial contact with you. In such circumstances and for such purposes, we may only be a processor under data protection law and the affiliate will be the controller according to data protection law applicable in their own jurisdiction. Should you have any query concerning our handling of your personal data we collect in these circumstances, please contact the affiliate directly.
Consent is also a lawful basis for our processing of personal data and so, sometimes, we may ask for your permission (called “consent” in the legislation) to process your personal data.
Where this is the case, we will make this clear together with how we might use your personal data should you allow us to do so. If, at the time we ask for it, you choose not to provide us with the requested information or do not consent, then we will not use it in that way.
Even if you do give us permission to use it in that way, you can always withdraw your consent to us doing so at any time. This does not affect the lawfulness of our previous same use of that information with your permission but we will then stop using it in that way.
You can contact us at any time on email@example.com, +44 (0) 1494 671800, or Pure FX, McBride House, 32 Penn Road, Beaconsfield, Bucks, HP9 2FY, to tell us you wish to withdraw your consent. We may also provide you with other ways for you to withdraw your consent to make it easier for you, such as by an unsubscribe button or other electronic means to alter your preferences.
Please note that if you choose not to give us permission or if you withdraw your consent, this may affect service quality and performance. We may also have to stop providing you with certain services.
Provision of “optional” information
On our website, we may indicate where the provision of any information by you is optional.
If this is the case, it is up to you whether you want to provide us with this information. If you choose not to provide us with optional information this may affect service quality and performance.
If you do provide us with it, we rely on our legitimate interests to process this information rather than your consent. This may be to help us to better understand you, provide you with a better service, or to assist us with our risk assessment or compliance processes.
If you choose not to provide us with information in a “required” field, then we may not be able to respond to your request or provide you with the products or services concerned.
We may carry out direct marketing to you about our products and services. If we do, this is on the basis of our legitimate interests and you have the right to object to our further use of your information for direct marketing by us at any time. If you object then we will then stop doing so.
You can contact us at any time on firstname.lastname@example.org, +44 (0) 1494 671800, or Pure FX, McBride House, 32 Penn Road, Beaconsfield, Bucks, HP9 2FY, to tell us you wish to object. We may also provide you with other ways for you to object to make it easier for you, such as by an unsubscribe button or other electronic means to alter your preferences.
Please note that if you choose to object to direct marketing, this may affect service quality and performance. We may also have to stop providing you with certain services.
We do not pass on any personal data to third parties for the purposes of any direct marketing by them.
Special category personal data
We will not normally process data which the GDPRs describe as “special category” personal data but if we do, we will process it based on your consent, for the establishment, exercise or defence of legal claims or for reasons of substantial public interest on the basis of EU or other law applicable in the United Kingdom.
STORING PERSONAL DATA
We use the following criteria to determine how long we retain personal data:
We retain personal data
Third parties with whom we share personal data will adopt their own criteria.
HOW WE SHARE PERSONAL DATA
Who do we share personal data with?
We may share personal data with:
Sharing outside of the EEA (“European Economic Area”)
We need to let you know if we intend to share your personal data outside of the EEA (or “European Economic Area”, which is all the member states of the European Union, together with Norway, Iceland and Lichtenstein). This is because, while some countries may have adequate protections in place for the protection of personal data, other countries do not.
In most cases your personal data is processed by us or our third party services providers on our behalf in the United Kingdom or the EEA but in certain circumstances we or they will transfer personal data to countries outside of the EEA. In each such case, we will ensure that either the destination country meets the requirements of adequacy laid down in the legislation and by the European Commission or that other appropriate safeguards are put in place, such as by means of a detailed contract between us and the entity based in that destination country or storing its data there.
For example, some of the third party service providers we use to help us to provide you with our products and services use servers which are based in the US. All of them operate through businesses that are signatories to the US Privacy Shield, which is a system that is EU approved and meets the adequacy requirements laid down in the legislation and by the European Commission. Further detail concerning the US Privacy Shield can be found here www.privacyshield.gov and concerning adequacy can be found here https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
Where you instruct us to share your personal data with people who you have asked us to deal with, or who you already know, or who already know you, wherever they are based, this will be on the basis of your consent and we will not normally make any further enquiry concerning them or take any further steps to ensure that your personal data is protected.
Rights of request
If you are the “data subject” (which means the natural person to whom the personal data relates – you do not have these rights in relation to any personal data concerning anyone else) you have the following rights of request relating to your personal data:
Please note that we may not be able to do exactly what you have asked or there may be other steps which you or we need to take before we are able to, or can determine whether we can, meet your request. Generally, we will respond to your request either with the action we have taken, or explaining why we will not be be taking action, within one month of the receipt of your request. However, sometimes we may have to extend that period and, if this is the case, we will let you know.
You can ask us to stop any direct marketing to you at any time. Where we send any direct marketing to you by email we will make sure that a way to unsubscribe or change your marketing preferences is included in the email. Alternatively, you can contact us at any time on email@example.com, +44 (0) 1494 671800, or Pure FX, McBride House, 32 Penn Road, Beaconsfield, Bucks, HP9 2FY.
You can withdraw your consent where we have relied upon your permission to perform any processing at any time. You can contact us at any time on firstname.lastname@example.org, +44 (0) 1494 671800, or Pure FX, McBride House, 32 Penn Road, Beaconsfield, Bucks, HP9 2FY, to tell us you wish to withdraw your consent. We may also provide you with other ways for you to withdraw your consent to make it easier for you, such as by an unsubscribe button or other electronic means to alter your preferences.
You always have the right to complain to the Office of the Information Commissioner, which is the supervisory authority in relation to data protection law and its enforcement in the United Kingdom. You may also be entitled to seek compensation in certain circumstances where a breach of the legal requirements for the protection of personal data has occurred.
Further details concerning the ICO, its powers and your rights, including your right and how to bring a complaint to the ICO, can be found here ICO.
WHAT ABOUT COOKIES?
A cookie is a small text file which is placed onto your computer (or other electronic device) when you visit our website. You can set your browser not to accept cookies, however some of our website features may not function as a result. We have a separate Cookies Policy which goes into more detail. You can find this here: https://www.purefx.co.uk/cookie-policy/
WHERE CAN I FIND OUT MORE?
You can also visit the ICO website at ICO.
Further detail concerning the US Privacy Shield can be found here www.privacyshield.gov and concerning adequacy can be found here https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
Last updated [25 May 2018]