Privacy policy

Effective Date: 22 April 2020

Last Modified: 30 July 2024

1. Introduction

This privacy notice aims to give you information on how CSL (collectively referred to as ‘’CSL’’, ‘’the Company’’, ‘’we’’, ‘’us’’ in this privacy notice) deals with the data collected or processed during its business operations. This personal data may be obtained through the provision of our services in accordance with our terms and conditions, through our clients and potential client’s use of the website (https://www.currencysolutions.com/) or through other direct communications between us and our clients or potential clients or through third parties.

Reading this privacy notice will help you understand your privacy rights and choices and let you know how we look after your personal data when you visit our website and when you use our services and tell you about your privacy rights and how the law protects you.

The website and our services are not intended for children and we do not knowingly collect data relating to children. By using the services, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will close the account and take reasonable measures to promptly delete such data from our records.

It is important that you read this privacy notice together with our terms and conditions and any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

2. Scope

CSL is the controller and responsible for your personal data.

We have appointed a Data Protection Lead (‘’DPL’’) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPL using the details set out below.

Our full details are:

How to complain:

If you have any concerns about our use of your personal information or believe that we are unlawfully processing your personal information, you can make a complaint to us at privacy@currencysolutions.com or complaints@currencysolutions.com .

You also have the right to make a complaint at any time to the Information Commissioner's Office (‘’ICO’’) which is the United Kingdom’s supervisory authority for data protection issues.

The ICO’s address:

Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

Helpline number: 0303 123 1113

ICO Website: https://www.ico.org.uk

We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us using the details set out in the table above in the first instance.

3 Procedure

3.1. Changes to the privacy notice and your duty to inform us of changes

We may update this privacy notice from time to time to ensure that we stay compliant with relevant laws. This version was last updated in July 2024. Prior versions can be obtained by contacting us. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

It is important that the personal data we hold about you is true, complete, accurate and current. Please keep us informed if your personal data changes during your relationship with us.

3.2. Third-party links

This 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 notice of every website you visit.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO) which is the United Kingdom’s supervisory authority 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 using the details set out in the table above in the first instance.

3.3. The data we collect about you

Personal data or personal information means any information that can be used to identify a living person. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

● Identity Data means first name, maiden name, last name or similar identifier, marital status, title, date of birth and gender.

● Contact Data means residential address, email address and telephone numbers

● Financial Data means bank account details.

● Transaction Data means details about payments to and from you and details of contracts you have entered into.

● Usage Data means information about how you use our website, products and services.

● Marketing and Communications Data means your preferences in receiving marketing from us and your communication preferences.

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.

3.4. Third Party Providers

In order to fulfil certain services, CSL enlists the assistance of third party providers which specialise in certain fields. The aforementioned third parties will collect only the necessary data so that they may fulfil their services. Third party providers abide by CSL’s privacy policy and take measures to ensure that your data is safe at all times.

3.5. 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, execute a payment on your behalf). In this case, we may have to terminate the contract you have with us but we will notify you if this is the case at the time.

4. Controls and Evidence

4.1. How is your personal data collected?

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

• (a) Direct interactions. You may give us your Identity Data, Contact Data, Financial Data and Transaction Data and Marketing and Communications Data by filling in forms or by corresponding with us via our website or by post, phone, email or otherwise.
• (b) Automated technologies or interactions. As you interact with our website, we may automatically collect Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
• (c) Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • (i) Identity Data, Contact Data, Financial Data and Transaction Data from our client who shares your personal data with us so that (a) you can use our services on their behalf; and (b) they can pay money to you (for example, for payment for goods and/or services if you are their supplier);
  • (ii) Usage Data from analytics providers such as Google;
  • (iii) Identity Data, Contact Data and Financial Data from electronic identity verification providers or credit check providers such as SmartSearch based inside the EU; and Veriphy based inside the EU.
  • (iv) Identity Data and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

4.2. How we use your personal data

We will only use your personal data when the law allows us to and we have a valid legal reason to do so. 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; and
• (c) where we need to comply with a legal or regulatory obligation.

Please see paragraph 4.3 (purposes for which we will use your personal data) to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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 using the details set out in paragraph 2.

4.3. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and the lawful bases we rely on for processing this information under the UK General Data Protection Regulation (UK GDPR). We have also identified what our Legitimate Interests are where appropriate.

Note that we may use more than one lawful grounds to process your data, depending on the specific purpose of processing. Please contact us using the details set out in paragraph 2. 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.

4.4 Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can ask us to stop sending you marketing messages at any time.

4.5 Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the CSL group of companies for marketing purposes.

4.6 Opting out

You can ask us or third parties to stop sending you marketing messages at any time.

4.7 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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://www.currencysolutions.co.uk/cookies-policy.

4.8 Change of purpose

We will only use your personal data for the purposes for which we collected or received 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 using the details set out in paragraph 2.

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.

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 Procedures Supporting this Procedure

5.1 Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4.3 (purposes for which we will use your personal data) above.

(a) External Third Parties as set out in paragraph 6 (Glossary).

(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 notice.

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.

5.2 International transfers

Some of our External Third Parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• (a) we will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• (b) where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• (c) where we use providers based in the US, we may transfer data to them if they are part of the privacy shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
• (d) where it is not possible to put the above arrangements in place, where necessary in order for us to comply with our contractual obligations to you where you have provided us and we have accepted payment instructions.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

5.3 Data security

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal data we process and 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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and the Financial Conduct Authority (‘’FCA’’) of a breach where we are legally required to do so.

5.4 Data retention

5.4.1 How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To 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 requirements.

By law we have to keep basic information (including Identity Data, Contact Data, Financial Data and Transaction Data) about our clients, their directors, partners and ultimate beneficial owners and beneficiaries for five years after they cease being clients for the purpose of compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.

5.4.2 Data Destruction and Disposal

In some circumstances you can ask us to delete your data: see paragraph below for further information.

Data are managed and disposed of in a manner appropriate to the sensitivity of the information they contain. Before an official document is destroyed, written approval is given by the director or a senior officer of the Company.

When a document is destroyed, appropriate care is taken to ensure that all personal and confidential information contained therein is permanently and securely destroyed and can never be restored.

The destruction of hard copy personal data and confidential financial records is conducted by shredding. Non-confidential records may be destroyed by recycling. The destruction of electronic records is coordinated with the Head of IT & Head of Product Development. In some circumstances we may 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.

Information we hold which is controlled by third-parties will be deleted in accordance with the agreement in place with that third party.

Information under our control which is held by third parties on our behalf must be destroyed in line with the Company’s data retention policy unless the agreement in place with that third-party states they have the right to retain the data. The contracts in place with third parties will include provisions requiring the deletion and destruction of information to make sure that unnecessary data is always deleted securely. Where the destruction is carried out by third parties, written verification of this destruction is obtained from the third party.

5.4.3 Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

• (a) Request to access: (commonly known as a "data subject access request"). You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information with. There are some exemptions which means you may not receive all the information you ask for.

• (b) Right to rectification: 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. To exercise your right you should inform the Company that you are challenging the accuracy of your data and want it corrected. You should: a) state clearly what you believe is inaccurate or incomplete, b) explain how the Company should correct it, and c) where available, provide evidence of the inaccuracies.

• (c) Right to erasure: You have the right to ask us to erase your personal Information in certain circumstances. You can exercise this right 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 for erasure.

• (d) Right to object to processing: You have the right to object to the processing of your personal information at any time. This means that you can stop or prevent the Company from using your data. However, it only applies in certain circumstances, and they may not need to stop if the Company can give strong and legitimate reasons to continue using your data. An example of when you can exercise this right is when we are processing your personal data for direct marketing purposes. If you object, the organisation cannot refuse your objection and must stop using your data for direct marketing purposes. However, this does not automatically mean that the organisation needs to erase all your personal information. The Company may put you on a ‘suppression list’.

• (e) Request restriction of processing: You have the right to ask us to restrict the processing of your personal Information in certain circumstances. You can ask the Company to temporarily limit the use of your data when we are considering: a) a challenge you have made to the accuracy of your data, or b) an objection you have made to the use of your data. You may also ask the Company to limit the use of your data rather than delete it if: a) the Company processed your data unlawfully but you do not want it deleted, or b) the Company no longer needs your data but you want the Company to keep it in order to create, exercise or defend legal claims. If the Company believes that a request is, as the law states, “manifestly unfounded or excessive”,the Company can: a) request a reasonable fee to deal with the request, or b) refuse to deal with the request. In either case we will need to tell you and justify our decision.

• (f) Right to data portability: You have the right to ask that we transfer the personal Information you gave to us to another organisation, or to you, in certain circumstances. 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. The Company must do this if the transfer is, as the regulation says, ‘’technically feasible’’.

• (g) Right to withdraw consent: You have the right to 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 products or services to you. We will advise you if this is the case at the time. If you wish for a third party to act on your behalf and withdraw consent, you will need to demonstrate to the Company that the third party has the authority from you to do so.

If you wish to exercise any of the rights set out above, please contact us using the details set out in paragraph 2. You can request to exercise any of your rights above verbally or in writing. If you make a request, we have one month to respond to you

You 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 may refuse to comply with your request in these circumstances.

5.4.4 What we may need from you

We 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.

5.4.5 Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may 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.

6. Glossary

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.

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.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

External Third Parties means:

• (a) other payment service providers and intermediaries which we send money to complete a payment to comply with the Regulation (EU) 2015/847 on information accompanying transfers of funds (revised wire transfer regulation)
• (b) professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom and outside UK who provide consultancy, banking, legal, insurance and accounting services; and other jurisdictions where necessary in specific circumstances.
• (c) the FCA and HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.