CompareFX

Privacy Policy

CompareFX – Privacy Policy

Welcome to the Privacy Policy of CompareFX (we, us or similar). We respect your privacy and are committed to protecting your personal data. This privacy policy (which we will refer to as the policy) will inform you as to how we look after your personal data when you use our website (however you access it) or communicate with us, and will tell you about your privacy rights and how the law protects you.

This policy should be read alongside the CompareFX Terms of Business, which explain how we provide our services, and the arrangements and relationships between you, us and the third party providers of foreign exchange and international payment transactions which we may make you aware of from time to time (third-party providers).

1. Important information and who we are

Purpose of this privacy policy

This policy aims to give you information on how we collect and process your personal data through your use of our website, including any data you may provide when you set up an account, provide information about your requirements or communicate with us in respect of our services.

Our website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this policy together with any other privacy policy 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 policy supplements other notices and privacy policies and is not intended to override them.

Controller

CompareFX Limited, a limited company registered in England and Wales under company number 16716488, is the controller of personal data collected in connection with our website and services, and references in this policy to we or us refer to this company.

If you have any questions about this policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

If you have any questions about this policy or our privacy practices, please contact us by email at: giles@comparefx.co.uk.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (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.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in February 2024.

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.

Third-party links

Our 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 our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data which has been processed in such a way that it cannot be linked to any individual (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you (and about other individuals whose personal data you provide to us) which we have grouped together as follows:

  • Identity Data includes billing address, delivery address, email address and telephone numbers.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes your bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • 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 this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may 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.

We 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.

If you fail to provide personal data

Where 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) or able to facilitate your contracts with other users of our website.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us. This includes personal data you provide when you:
    • create an account on our website;
    • ask us to list a request;
    • make a proposal to fulfil a request;
    • request marketing to be sent to you;
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from analytics providers (such as Google).
    • Transaction Data from the third-party providers of foreign exchange and international transfer services.
    • Identity and Contact Data from data brokers or aggregators.
    • Identity and Contact Data from publicly available sources such as the Electoral Register.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to use your personal data to perform the contract we are about to enter into or have entered into with you, or to facilitate arrangements between requesters and travellers using our website.
  • 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 (see below for more information on what is meant by the term legitimate interests).
  • Where we need to use your personal data to comply with a legal obligation that we are subject to.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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.

Generally, 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.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us: We may use your Identity, Contact, Technical, Usage 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 products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or have used our services and you have not opted out of receiving that marketing.

Third-party marketing: We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out: You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Cookies: You 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 our website may become inaccessible or not function properly.

5. Disclosures of your personal data

We may share your personal data with the parties set out below:

  • Other users of our website, to the extent required for the posting and fulfilment of requests, and for the provision of feedback and user reviews.
  • Our third-party providers of foreign exchange and international transfer services.
  • Third parties providing IT, hosting and administration services to us (acting as processors of your personal data strictly on the basis of our instructions) – as at the date of the latest update to this policy, these include our database system called "Notion", which operates in accordance with the Privacy Policy published at https://www.notion.so/security.
  • Our professional advisers (acting as processors or independent controllers) including lawyers, bankers, auditors and insurers who provide services to us.
  • 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.

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. International transfers

The nature of our website necessitates the international transfer of personal data relating to our users.

We are a UK business, and whenever we transfer your personal data internationally, we ensure a similar degree of protection is afforded to it as would be afforded in the UK.

7. Data security

We 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.

8. Data retention

We 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.

9. Your legal rights

Under certain circumstances, data protection laws give you the right to:

  • Request access to your personal data (commonly known as a "data subject access request").
  • Request correction of the personal data that we hold about you.
  • Request erasure of your personal data.
  • Object to processing of your personal data where we are relying on a legitimate interest.
  • Request restriction of processing of your personal data.
  • Request the transfer of your personal data to you or to a third party.
  • Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us.

This privacy policy was last updated in February 2024.

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