Welcome to the privacy policy (the “Privacy Policy”) of Expedez Financial Services Ltd, a company incorporated and registered in England and Wales with company number 11350027, whose registered office address is at Citibase London, Unit 112 Millbank Tower, 1st Floor, 21-24 Millbank, London, England, SW1P 4QP (“Expedez”). Expedez is registered with the Financial Conduct Authority as a small payment institution with firm reference number 824379.
Expedez respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website at https://expedez.com/ (the “Website”), regardless of where you visit it from, or when your personal data is otherwise collected through our provision of services, and tell you about your privacy rights and how the law protects you.
This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the Privacy Policy here. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.
- 1. Important information and who we are
- 2. The data we collect about you
- 3. How is your personal data collected?
- 4. How we use your personal data
- 5. Disclosures of your personal data
- 6. International transfers
- 7. Data security
- 8. Data retention
- 9. Your legal rights
- 10. Glossary
- 1.1Purpose of this privacy policy
- (a)This Privacy Policy aims to give you information on how Expedez collects and processes your personal data through your use of the website (including any data you may provide through the website) and through our provision of services.
- (b)The Website is not intended for children and we do not knowingly collect data relating to children.
- (c)It is important that you read this privacy policy together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other privacy notices or fair processing policies and is not intended to override them.
- 1.2Controller
- (a)Expedez is the controller and responsible for your personal data.
- (b)We have appointed a data protection officer (the “DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about the privacy policy, including any requests to exercise your legal rights, please contact the DPO by:
- (i)writing to “Data protection officer” at our registered office address (specified in the Introduction section of the privacy policy); or
- (ii)emailing [email protected]
- (c)You have the right to make a complaint at any time to the information commissioner's Office (the “ICO”), the regulator for data protection issues in the United Kingdom (the “UK”) (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.
- 1.3Changes to the privacy policy and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
- 1.4Third-party links
The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Website, we encourage you to read the privacy policy of every website you visit.
- 2.1Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
- 2.2We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- (a)“Identity Data” includes first name, [maiden name,] last name, [marital status,] [title,] date of birth, gender and voice.
- (b)“Contact Data” includes billing address, [residential address,] email address and telephone numbers.
- (c)“Financial Data” includes bank account and payment card details.
- (d)“Transaction Data” includes details about payments to and from you and other details of services you have purchased from us.
- (e)“Technical Data” includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website.
- (f)“Profile Data” includes your username and password[, transactions made by you through us, your interests, preferences, feedback and survey responses].
- (g)“Usage Data” includes information about how you use the website and services.
- (h)[“Marketing and communications data” includes your preferences in receiving marketing from us and our third parties and your communication preferences.]
- 2.3We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
- 2.4We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
- 2.5Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
- 3.1We use different methods to collect data from and about you including through:
- (a)Direct interactions. You may give us, either in your individual capacity or through your employer with whom we have a contract, your Identity Data, Contact Data and/or Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you, either in your individual capacity or through your employer with whom we have a contract:
- (i)apply for our services;
- (ii)create an account on the website;
- (ii)subscribe to our service or publications;
- (iv)request marketing to be sent to you;
- (v)enter a competition, promotion or survey; or
- (vi)give us feedback or contact us.
- (b)Automated technologies or interactions. As you interact with the Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy (the “Cookie Policy”) for further details.
- (c)Third parties or publicly available sources. We may receive personal data about you from various third parties such as analytics providers, sanction screening providers, credit reference agencies, customer due diligence providers, third parties with your consent, advertising networks, search information providers, providers of technical and payment services, data brokers or aggregators as well as personal data from publicly available sources such as Companies House and HM Land Registry. Please contact us to find out more about the various third parties and public sources from which we may receive personal data about you.
- 4.1We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- (a)where we need to perform the contract we are about to enter into or have entered into with you.
- (b)where it is necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- (c)where we need to comply with a legal or regulatory obligation.
- 4.2Please contact us to find out more about the types of lawful basis that we will rely on to process your personal data.
- 4.3Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
- 4.4Purposes for which we will use your personal data
- (a)We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our Legitimate Interests are where appropriate.
- (b)Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of Legitimate Interest |
|---|
| To register you or your employer as a new customer | (a) Identity Data (b) Contact Data | Performance of a contract with you or your employer |
| To deliver services to you or your employer, including: (a) Administering the user account held with us; (b) Managing payments, fees and charges; (c) Processing transactions; (d) Collecting and recovering money owed to us; and (e) Providing customer support | (a) Identity Data (b) Contact Data (c) Financial Data (d) Transaction Data (e) Marketing and Communications Data | (a) Performance of a contract with you or your employer (b) Necessary for our Legitimate Interests (to recover debts due to us and to review whether quality standards are being met) |
| To prevent and detect crime, including fraud, through means such as the following: (a) Carrying out customer due diligence; (b) Screening for financial and other sanctions or embargoes; and (c) Gathering and providing information required by or relating to investigations by regulatory bodies | (a) Identity Data (b) Contact Data (c) Financial Data (d) Transaction Data | (a) Performance of a contract with you or your employer (b) Necessary to comply with a legal or regulatory obligation (c) Necessary for our Legitimate Interests (to prevent us from any damage caused by crime) |
| To manage our relationship with you or your employer which will include: (a) Notifying you or your employer about changes to our terms or Privacy Policy; and (b) Asking you to leave a review or take a survey | (a) Identity Data (b) Contact Data (c) Profile Data (d) Marketing and Communications Data | (a) Performance of a contract with you or your employer (b) Necessary to comply with a legal or regulatory obligation (c) Necessary for our Legitimate Interests (to keep our records updated and to study how customers use our services) |
| To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | a) Identity Data (b) Contact Data (c) Technical Data | (a) Necessary for our Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal or regulatory obligation |
| To deliver relevant Website content and advertisements to you or your employer and measure or understand the effectiveness of the advertising we serve to you or your employer | (a) Identity Data (b) Contact Data (c) Profile Data (d) Usage Data (e) Marketing and Communications Data (f) Technical Data | Necessary for our Legitimate Interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve the Website, services, marketing, customer relationships and experiences | (a) Technical Data (b) Usage Data | Necessary for our Legitimate Interests (to define types of customers for our services, to keep the Website updated and relevant, to develop our business and to inform our marketing strategy) |
| services that may be of interest to you or your employer | (c) Technical Data (d) Usage Data (e) Profile Data (f) Marketing and Communications Data | services and grow our business) |
- 4.5Promotional offers from us
- (a)We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
- (b)We may use your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
- (c)You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
- 4.6We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
- 4.7Opting out
- (a)You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
- (b)Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service held with us or other transactions.
- 4.8You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
- 4.9Change of purpose
- (a)We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
- (b)If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
- (c)Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- 5.1We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 4.4 above.
- (a)External Third Parties as set out in the paragraph 10.2 below.
- (b)Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
- (c)We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
- 6.1Some of our external third parties may be based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
- 6.2Whenever we transfer your personal data out of the UK, we ensure a sufficiently similar degree of protection is afforded to it by ensuring such transfer only takes place under one of the following conditions:
- (a)we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data;
- (b)we participate in a valid cross-border transfer mechanism under UK data protection legislation, so that we can ensure that appropriate safeguards are in place to ensure an adequate level of protection with respect to the privacy rights of individuals; or
- (c)the transfer otherwise complies with UK data protection legislation.
- 6.3Please contact us if you want further information on the specific condition relied on by us when transferring your personal data out of the UK.
- 7.1We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
- 7.2We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- 8.1We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
- 8.2To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
- 8.3By law, we have to keep basic information about our customers (including Contact Data, Identity Data, Financial Data and Transaction Data) for six years from the end of the company financial year in which they cease being customers for tax purposes.
- 8.4In some circumstances you can ask us to delete your data, see paragraph 9 below for further information.
- 8.5In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
- 9.1Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- (a)Request access to your personal data.
- (b)Request correction of your personal data.
- (c)Request erasure of your personal data.
- (d)Object to processing of your personal data.
- (e)Request restriction of processing your personal data.
- (f)Request transfer of your personal data.
- (g)Right to withdraw consent.
- 9.2If you wish to exercise any of the rights set out in paragraph 9.1 above, please contact us.
- 9.3You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
- 9.4We 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.
- 9.5We try to respond to all legitimate requests within one month. Occasionally, it could 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.
- 10.1Lawful Basis
- (a)“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our Legitimate Interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our Legitimate Interests against any potential impact on you in respect of specific activities by contacting us.
- (b)“Performance of Contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- (c)“Comply with a legal obligation” means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
- 10.2External Third Parties
- (a)Service providers acting as processors based in the UK, including providers of IT and system administration services and digital marketing services.
- (b)Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- (c)Tax authorities, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
- 10.3Your Legal Rights
You have the right to:- (a)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 and to check that we are lawfully processing it.
- (b)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, though we may need to verify the accuracy of the new data you provide to us.
- (c)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. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- (d)Object to processing of your personal data 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 data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- (e)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:
- (i)If you want us to establish the data’s accuracy.
- (ii)Where our use of the data is unlawful but you do not want us to erase it.
- (iii)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.
- (iv)You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- (f)Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note 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.
- (g)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. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
