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Effective From: 7 January 2025
This document, together with any documents referred to in it (Privacy Policy), constitutes the Privacy Policy upon which ACE Money Transfer Limited, with a registered address set out at https://acemoneytransfer.com/contact-us, provides the Services and is applicable to customers using our services from the following countries:
ACE Money Transfer Limited (“ACE”, “we”, “us”, “our”) of 13-18 City Quay, Dublin, D02 Ireland, with registration number 703066, is the controller of your personal information.
“Personal information” means information that is about you or from which we can identify you directly or indirectly. This Privacy Notice describes how we deal with your personal information. We are the controller of this information under relevant data protection laws because in the context of our business relationship with you we decide how and why it is processed in the ways explained in this Privacy Notice.
We can be contacted at any time including if you have queries about this Privacy Notice or wish to exercise any of the rights mentioned in it. Our contact details can be found at the end of this notice.
This Privacy Notice will include information about specified third parties with whom we need to share your data with. Please read the privacy notices of relevant third parties on their website carefully and contact those organisations if you have questions (their details are in their notices).
This Privacy Notice may be updated from time to time. You should check this webpage regularly so that you can read the up-to-date version.
We may collect certain personal information, also known as personal data, which refers to any information that relates to an identified or identifiable individual, which (either on its own or when combined with other information we hold about you) allows us to identify you as an individual. We outline below examples of the personal information that we may process in connection with all our products and services.
This includes:
o Transactional Details, including:
We will generally collect your personal information from you directly when you sign up to use our Services, e.g. when you provide us with personal details including your name and email address. If you are introduced to us by another member of ACE group of companies, a broker or other intermediary, we will obtain some personal information about you indirectly from them when they introduce you to us.
In addition, we obtain your personal information from other sources such as Fraud Prevention Agencies, and other organisations to assist in prevention and detection of crime, police and law enforcement agencies.
Some of the personal information obtained to verify your account will have originated from publicly accessible sources. In particular, the information will draw on court decisions, bankruptcy registers and the electoral register (also known as the electoral roll).
At your request, where you provide us with information about third parties, e.g. recipients of transfers, we will also collect personal information in relation to those people (“Receiver Information”). By providing us with such information you confirm that you have obtained any necessary permissions from such persons to the reasonable use of the Receiver Information for such purposes in accordance with this notice or are otherwise permitted to give to us the Receiver Information on their behalf. Please ensure that those other people are aware of this notice and that the provisions of this notice are clearly communicated to them.
We will only use your personal information when the law allows us to do so. Most commonly we use your personal information in the following purposes:
Transactional Purposes We need to collect your personal information to process your transactions. To do so we require you and your beneficiaries bank account details or full name and address. Without the Receiver Information we would not be able to fulfil your transactions.
Regulatory Purposes As a regulated institution, ACE must comply with the applicable money laundering, terrorist financing and data protection obligations, such as the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (as amended) and other regulations and guidelines enforced by the Central Bank of Ireland. As a result, ACE (and its partners) must conduct Know Your Customer (“KYC”) and Customer Due Diligence (“CDD”) checks to comply with legal and regulatory obligations. Any personal information obtained for the purposes of preventing money laundering or terrorist financing is only used for that purpose. There may be occasions where use of the data is permitted under another enactment. All of this helps us keep our service safe and secure.
Marketing Purposes We may process your personal information to provide you with certain types of marketing communications that we believe will be relevant and of interest to you. This helps us to provide a more personalised service. We will always endeavour to make these communications relevant and un-intrusive, and you are able to opt out of our marketing communications at any time.
Analytical Purposes We may collect and analyse data such as website or Mobile App visit logs, on our own or by using the services of third parties, in order to improve the quality of our service.
In addition, we may share your personal data with third parties when it is necessary for the fulfilment of the service or to comply with applicable laws. We set out below some purposes for which we may share your personal information with third parties:
Data protection laws require us to explain what legal grounds justify our processing of your personal information (this includes sharing it with other organisations). For some processing more than one legal ground may be relevant (except where we rely on a consent). Here are the legal grounds that are relevant to us:
We process the following personal data:
for the purposes of:
for the purposes of:
We process the following personal data:
for the purposes of:
We may also, from time to time, ask you for your consent for other processing purposes, which we will explain to you at the time. Much of what we do with your personal data is not based on your consent and is instead based on the above legal grounds. However, for processing that is based on your consent, you have the right to revoke that at any time.
For processing that is based on your consent, you have the right to take back that consent for future processing at any time. You can do this by contacting us using the details below. The consequence might be that we cannot send you some marketing communications (but this outcome will be relevant only in cases where we rely on explicit consent).
We are based in Ireland but sometimes your personal information may be transferred outside Ireland and the European Economic Area. If it is processed within the EU or other parts of the European Economic Area (EEA) then it is protected by EU data protection standards. Some countries outside the EEA do have adequate protection for personal information under laws that apply to us. Where possible, we will also make sure that suitable safeguards are in place before we transfer your personal information to countries outside the EEA which do not have adequate protection under laws that apply to us.
From time to time, your personal information may be transferred to, stored in or accessed from a destination outside the EEA. It may also be processed by staff operating outside of the EEA who work for us, or one of our partners.
Our service facilitates the transfer of currency to jurisdictions across the globe. The recipient pay-out partner will request information to verify the identity of the sender. Your personal information will therefore be transferred to the jurisdiction to which you choose to transfer the money and to which you have explicitly consented for your personal data to be transferred.
Therefore, to provide you the services and complete the transaction, we may transfer your personal data to a destination outside of the EEA, where appropriate safeguards may not be in place. In those circumstances we will only transfer your personal data with your explicit consent, as your personal data may be at a heightened risk if transferred to a destination which does not have appropriate safeguards in place to protect it.
Whenever we transfer your personal data out of the EEA for other purposes aside from facilitating a money transfer you have requested (in other words in circumstances when you have not provided explicit consent), we ensure a similar degree of protection to EU data protection standards is afforded to it by ensuring at least one of the following safeguards is implemented:
All information you provide to us is stored on our secure servers. Our servers are hosted in the Ireland and the information is encrypted.
Unfortunately, transmission of information via the internet cannot be considered completely secure. We do our utmost to protect your personal information, however we cannot guarantee the security of those transfers. Any transmission of your personal information is at your own risk.
Once we have received your personal information, we will use strict procedures and security controls to try to prevent unauthorised access.
You should tell us without delay so that we can update our records.
Without personal information about you, we are unable to offer you products and services or proceed with your application. Before opening an account with us, your personal information is necessary. It is also required during the contract's duration and for compliance with relevant legal obligations. If we do not receive this information, this may impact our ability to continue dealing with you in compliance with our obligations and internal policies.
In cases where providing some personal information is optional, we will make this clear. For example, we will specify in the application form, or on our website if an alternative telephone number or contact details can be left blank.
In this section monitoring means any listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person face to face meetings and other communications.
We may monitor where permitted by law and we will do this where the law requires it. Where we are required by the regulatory regime to record certain company telephone lines or in person meetings (as relevant) we will do so.
Some of our monitoring may be to comply with regulatory rules, self-regulatory practices or procedures relevant to our business, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures, to have a record of what we have discussed with you and actions agreed with you, to protect you and to provide security for you (such as in relation to fraud risks on your account) and for quality control and staff training purposes.
Some of our monitoring may check for obscene or profane content in communications.
We may conduct short term carefully controlled monitoring of your activities on your account(s) where this is necessary for our legitimate interests or to comply with our legal obligations. For instance, where we suspect fraud, money laundering or other crimes.
Email exchanges, web chat, telephone calls and in person meetings between us and you in connection with your application and/or your account(s) may be recorded to make sure that we have a record of what has been discussed and what your instructions are. We may also record these types of calls for the quality control and staff training purposes.
This section is relevant where we make decisions about you using only technology, and where none of our employees or any other individuals have been involved in the process. For instance, in relation to transactions, triggers and events such account opening anniversaries and maturity dates. We may do this to decide what marketing communications are suitable for you, to analyse statistics and assess lending and insurance risks.
We can do this activity based on our legitimate interests (see ‘what are the legal grounds for our processing of your personal information’ where they are listed above) only where the profiling and other automated decision making does not have a legal or other significant effect on you. In all other cases, we can do this activity only where it is necessary for entering into or performing the relevant contract, is authorised by laws that apply to us, or is based on your explicit consent. In those cases, you have the right to obtain human intervention to contest the decision (see ‘rights in relation to automated decision making which has a legal effect or otherwise significantly affects you’ below). Profiling for direct marketing can mean there is a separate right to object (see ‘rights to object’ below).
Unless we explain otherwise to you, we will hold your personal information for the duration of any contract you have with us, for as long as you keep using our Mobile App and website, for the duration of any complaint handling procedure relating to you or for such a period of time as is necessary to comply with our obligations under applicable law and, if relevant, to deal with any subsequent claim or dispute that might arise in connection with your relationship with us. Your personal data will be retained in accordance with our records retention policy.
If you would like further information about our data retention practices, please contact us.
We may retain your contact information collected for the purposes of sending you marketing communications in accordance with this policy for as long as you do not unsubscribe from receiving the data from us.
Here is a list of the rights that all individuals have under data protection laws. They do not apply in all circumstances. If you wish to exercise any of them, we will explain at that time if they are engaged or not.
You have the right to complain to the Irish Data Protection Commission which enforces data protection laws: https://www.dataprotection.ie/.
In addition, you have the right, at any time, to object to processing of personal data for direct marketing purposes.
If you wish to exercise any of these rights against the Credit Reference Agencies or any other intermediary who is a data controller, you should contact them separately.
Your personal information may be converted into statistical or aggregated data which cannot be used to re-identify you. It may then be used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described in this Privacy Notice.
We will only share anonymised and encrypted data with third parties. We may also provide our partners with anonymous aggregated data about our customers for marketing and analytical purposes, to help optimise our marketing communications.
We may use your home address, phone numbers, email address and social media (e.g. Facebook, Google and message facilities in other platforms to contact you to send you communications about offers or promotions that we believe are relevant for you based on your previous use. We will only do this if we have a legal ground which allows it under data protection laws – see above for our legal ground for marketing. You can opt out of our marketing at any time by contacting us (details of which can be found at the end of this notice) or by following the instructions on how to do that in the marketing email or other communication.
We have mentioned that we share your personal information with beneficiary banks, partners who help us to complete your transactions and Credit Reference Agencies. They require us to pass on to your information about how they will use your personal information to perform their services or functions as data controllers. These notices are separate to our own.
In addition, when you log into your account via Facebook, Google, YouTube, Instagram, Twitter or LinkedIn your data will be processed by these policies and as such your personal information will also be subject to these third-party Data Collection Policies.
In circumstances where you use your Facebook or Google login credentials to create and/or log in to your account your personal information may be processed by Facebook or Google marketing tools. These tools identify individuals with reference to their interests or behaviours to those of our customers.
ACE may change this Privacy Notice from time to time. All changes to this Privacy Notice are effective when they are posted on this page. When we change the policy in a material manner, we will let you know via email and/or a notice on our website. The date of the most recent update is displayed at the top of the page.
Any dispute or claim arising in connection with this Privacy Notice will be considered in relation to the English version only.
You can contact ACE:
Via our website: https://acemoneytransfer.com/
Via email : privacy@acemoneytransfer.com
You can also contact our Data Protection Officer if you have any questions about this policy, would like further information about the points raised or to exercise any of your rights. Contact details for our Data Protection Officer are:
Cyber Data Law Solicitors
privacy@acemoneytransfer.com