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This is the privacy notice of VarsoviaFX Ltd (VFX) and in this document, “we”, “our”, or “us” refer to VFX. For the purposes of data protection legislation, the “Data Controller” is VFX.
We are a company registered in England and Wales under company number 8746313. Our registered office is at Suite 2, Alexander House, 7 Oaklands Gate, Northwood HA6 3AA.
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes, then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
When you create an account on our website or otherwise agree to our Terms and Conditions in order to use our money transfer service, a contract is formed between you and us.
In order to carry out our obligations under that contract, we must process the
information you give us. Some of this information may be personal information.
We may use it in order to:
We process this information on the basis that there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance in providing our payment services. If we use it for this purpose, you as an individual will not be personally identifiable.
If you continue to use our services once you have agreed our Terms & Con- ditions, we do not have to seek your consent to use data about you because our contractual relationship is the legal basis for doing so. We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
Through certain actions, when there is no contractual relationship between us (such as when you browse our website or ask us to provide you with more in- formation about our business, including our products and services), you provide your consent to us to process information which may be personal information.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class infor- mation, for example to monitor performance in providing our services.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at bok@varsoviafx. com. However, if you do so, you may not be able to use our website or our ser- vices further.
As a financial institution we are subject to strict regulations governing the keep- ing of records, which require us to maintain a record of you and your transac- tions. We are also subject to the general law, and sometimes we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.
Payment information is never taken by us or transferred to us either through our website or otherwise. At the point of payment, you are transferred from our website to an API of SagePay (or some other reputable payment service provid- er).
Information about your debit card is stored by SagePay in order to make using our service for future transactions easier. This is done when you first use our ser- vice. Complete information about your debit card is not stored on our database.
Only tokens are stored on our secure servers. These are used if you have reg- istered for regular repeat payments, and they store only the last four digits of the debit card.
The reason we do not keep all your payment information is so that we can pro- tect it by:
If we ask you questions about your payment information, we only show the last four digits of the debit card number, so that you can identify the means of pay- ment to which we refer.
The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We briefly set out these rights here, but we would ask that you also read the information provided at www.knowyourprivacyrights.org.
You have the right to request the erasure of your personal data unless we have reasonable grounds to refuse the request. You have the right to request the correction of data inaccuracies; to make an access request for the personal in- formation we hold about you; to be provided with a copy of it electronically in a commonly used format; and/or to request its transfer to another data controller.
You have the right to object to how your personal data is used, as described elsewhere in this Notice. You also have the right to restrict the processing of your information, which you may wish to do (instead of your data being erased) if, for example, it is no longer necessary for us to use it, or if you tell us that the data is incorrect. You also have the right to complain to the Information Commissioner’s Office (the ‘supervisory authority’ in the UK for data protection law) about how your personal information is used.
Access to and removal of your own information
If you wish us to remove personally identifiable information from our website, you may contact us at email@example.com. This may limit the service we can provide to you. We may refuse such a request if we have reason to believe it conflicts with our obligations under anti-money laundering legislation or is oth- erwise made to frustrate law enforcement.
When we receive any request to access, edit or delete personal identifiable infor- mation, we shall first take reasonable steps to verify your identity before grant- ing you access or otherwise taking any action. This is important to safeguard your information.
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business
We do not keep any personally identifiable information associated with your message, such as your name or email address, unless we already have a con- tractual relationship with you as our customer.
When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
Use of information we collect through automated systems when you visit our website
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address, length of visit and number of pages viewed. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website, how we perform in providing content to you, and to improve our website’s usability. We may also use it to detect fraud.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
We will not provide your personal information to any third parties for the pur- poses of direct marketing without your explicit permission. We may send you by email or text message information which we may think will be of interest to you. We will only do this if you have explicitly consented.
In addition to the disclosure reasonably necessary for the purposes explained in this Notice, we may disclose information about you:
To assist in combating fraud, we may collect and store information about you from third party sources such as government agencies, credit rating agencies and other providers of public information, in order to verify your identity and the information you supply to us.
Our website is hosted in the United Kingdom.
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly data obtained within the UK or any other country could be pro- cessed outside the European Union.
For example, some of the software our website uses may have been developed in the United States of America. For this reason we ensure that our contracts with data processors include transfer clauses in line with the data protection requirements of the GDPR.
We do not provide our services to children, nor do we market to children. You may use our money transfer services only if you are 18 or over.
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt all the information which you provide to us.
Whenever information is transferred between us, you can check that it is done using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
We take all reasonable precautions to prevent the misuse, loss, destruction or alteration of your personal information, or the unlawful processing of it. You should ensure that you keep secret the security information which we provide to you, and take all reasonable precautions to prevent its unauthorised or fraud- ulent use.
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
Varsovia FX LTD is registered in England and Wales (company number 08746313).Authorised Payment Institution regulated by FCA (Ref. No. 767993). HMRC Money Laundering Regulations Number: XHML00000154681.Registered office: 3rd Floor, 207 Regent Street, London, W1B 3HHHead Office: The Atrium, 1 Harefield Road, Uxbridge UB8 1EX.
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