Effective From: November 19, 2019
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.
You will see at the end of this privacy notice that we mention the privacy notices of relevant third parties. We do need to share these with you. Please read them 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 https://acemoneytransfer.com/privacy-policy this webpage regularly so that you can read the up to date version. We may send you an updated copy (depending on whether we are required to do that or not).
We may collect certain personal information which (either on its own or when combined with other information we hold about you) allows us to identify you as an individual and which is about you. We set out below personal information that we generally process in connection with all our products and services.
We will generally collect your personal information from you directly. If you are introduced to us by 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). We confirm that the third parties used to verify information include:
We recommend that you check the privacy policies on the websites of each of these organisations and contact those organisations if you have any questions (their details are in their policies).
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 in order to process your transactions. To do so we require you and your receivers 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 Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. 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 communication 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 object to marketing communication from us at any time.Analytical Purposes
We may collect and analyse data such as website or app visit logs, on our own or by using 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:
We may also, from time to time, ask you for your consent for other 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 other legal grounds. However, for processing that is based on your consent, you have the right to revoke that at any time.
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:
Much of what we do with your personal information is not based on your consent, instead it is based on other legal grounds. 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 the UK but sometimes your personal information may be transferred outside the UK or the European Economic Area. If it is processed within Europe or other parts of the European Economic Area (EEA) then it is protected by European data protection standards. Some countries outside the EEA do have adequate protection for personal information under laws that apply to us. We will 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 brokers.
We share your personal information within the ACE Group. This will involve transferring your personal data to our central office function, based in Pakistan. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.
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:
All information you provide to us is stored on our secure servers. Our servers are hosted in the United States and the information is encrypted.
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 currency.
For more information about suitable safeguards and (as relevant) how to obtain a copy of them or to find out where they have been made available you can contact us using the details above.
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.
DO YOU HAVE TO PROVIDE YOUR PERSONAL INFORMATION TO US?
We are unable to provide you with products and services or to process your application without having personal information about you. Your personal information is required before you can open an account with us, or it is required during the life of that contract, or it is required by laws that apply to us.
In cases where providing some personal information is optional, we will make this clear. For instance, we will say in application forms, in branch or on our website if alternative (such as work) telephone number 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. In particular, where we are required by the Financial Conduct Authority’s regulatory regime to record certain 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 (and they are listed in the section about legal grounds 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 up to 10 years, in accordance with local regulations as applicable, following the termination of our relationship in case of:
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. The right of data portability is only relevant from May 2018.
You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/
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 data controller in its own right, 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 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 receiver 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 in their own right. 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 privacy notices.
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 particular interests or behaviours to those of our customers.
You can contact ACE:
By post: Piccadilly House, 49 Piccadilly, Manchester, M1 2AP
Via our website: https://acemoneytransfer.com/
You can also contact our Data Protection Officer if you have any questions about this notice, would like further information about the points raised or to exercise any of your rights. Contact details for our Data Protection Officer are: