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Privacy Policy

We ask that you read this website privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

This website privacy policy is divided into the following sections:

  • Who we are
  • Our website
  • Our collection and use of your personal information
  • Transfer of your information out of the EEA
  • Cookies and similar technologies
  • Marketing
  • Your rights
  • Keeping your personal information secure
  • How to complain
  • Changes to this website privacy policy
  • How to contact us
  • Do you need extra help?

Who we are

This website is operated by Commonwealth Eurotransfers. We are an International Bank.

We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

Our website

This privacy policy relates to your use of our website.

Throughout our website we may link to other websites owned and operated by certain trusted third parties. These other third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third-party websites, please consult their privacy policies as appropriate.

Our collection and use of your personal information

We collect personal information about you when you access our website, register with us, contact us, send us feedback, use our services via our website, post material to our website and compete customer surveys via our website.

 

We may also collect personal information about you from other sources.

 

The personal information we collect about you depends on the particular activities carried out through our website. This information includes:

  • your name, address and contact details
  • date of birth
  • bank account and payment details
  • details of any feedback you give us by phone, email, post or via social media
  • information about the services we provide to you
  • your account details, such as username, login details

 

We use this personal information to:

  • create and manage your account with us
  • verify your identity
  • provide services to you
  • customise our website and its content to your particular preferences
  • notify you of any changes to our website or to our services that may affect you
  • prevent, detect and manage any illegal and fraudulent activity
  • resolve disputes that may occur
  • target advertisements, newsletter and service updates
  • improve our services

This website is not intended for use by children and we do not knowingly collect or use personal information relating to children.

Our legal basis for processing your personal information

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.

 

The legal bases we may rely on include:

  • consent: where you have given us clear consent for us to process your personal information for a specific purpose
  • contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
  • legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)
  • public task: where our use of your personal information is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law
  • legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information, which overrides our legitimate interests)

Further information—the personal information we collect, when and how we use it

For further details on when we collect personal information, what we collect as well as how we use it, please read the following sections:

 

What we use your personal information for Our reasons
To provide products AND/OR services to you For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or us For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity To comply with our legal and regulatory obligations.
Ensuring business policies are adhered to, eg policies covering security and internet use For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information

To comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you

To comply with our legal and regulatory obligations

Updating and enhancing customer records For the performance of our contract with you or to take steps at your request before entering into a contract

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products

Statutory returns To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our services and those of selected third parties to:

—existing and former customers;

—third parties who have previously expressed an interest in our services;

—third parties with whom we have had no previous dealings.

For our legitimate interests or those of a third party, ie to promote our business to existing and former customers
Credit reference checks via external credit reference agencies For our legitimate interests or those of a third party, ie to ensure our customers are likely to be able to pay for our products and services.
External audits and quality checks, eg for ISO or in People accreditation and the audit of our accounts For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards

To comply with our legal and regulatory obligations

Who we share your personal information with

We routinely share personal information with:

  • companies within our group
  • third parties we use to help deliver our products AND/OR services to you, eg payment service providers, warehouses and delivery companies;
  • other third parties we use to help us run our business, eg marketing agencies or website hosts;
  • third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
  • credit reference agencies; and
  • our correspondent banking partners

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always We will not share your personal information with any other third party.

Where your personal information is held

Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs,(see below: ‘Transferring your personal information out of the EEA’.).

How long your personal information will be kept

We will keep your personal information while you have an account with us or we are providing products AND/OR services to you. Thereafter, we will keep your personal information for as long as is necessary:

to respond to any questions, complaints or claims made by you or on your behalf;

to show that we treated you fairly;

to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

Transferring your personal information out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), eg:

with our offices outside the EEA;

with your and our service providers located outside the EEA;

if you are based outside the EEA;

where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and UK data protection law.

Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.

If you would like further information, please contact us.

Your rights

You have the following rights, which you can exercise free of charge:

Access The right to be provided with a copy of your personal information (the right of access)
Rectification The right to require us to correct any mistakes in your personal information
To be forgotten The right to require us to delete your personal information—in certain situations
Restriction of processing The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data
Data portability The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object The right to object:

—at any time to your personal information being processed for direct marketing (including profiling);

—in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.

Not to be subject to automated individual decision making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

complete a data subject request form; or

email, call or write to us see below: ‘How to contact us’; and

let us have enough information to identify you (eg your full name, address and order number);

let us have proof of your identity and address (a copy of your driving licence or passport and a recent

utility or credit card bill); and

let us know what right you want to exercise and the information to which your request relates.

Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do

How to complain

We hope that we can resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy notice was published on September 2019.

We may change this privacy notice from time to time.

How to contact us

Please contact us by post, email or telephone via the information provided on our website if you have any questions about this privacy policy or the information, we hold about you.

Do you need extra help?

If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).