Data Privacy Policy

This is your guide to how personal data is managed by AX Remit

BACKGROUND:

Ax Remit, the trading name of Ariana Exchange Limited, understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.axremit.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

  1.Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account” means an account required to access and/or use certain areas and features of Our Site;

“Cookie”  means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;

“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and

“We/Us/Our”    means Ariana Exchange, a limited company registered in England under company number 05716065, whose registered address and main trading address is 136 The Broadway Southall, Middx, UB1 1QN.

  2.Information About Us

2.1 Our Site is owned and operated by Ariana Exchange Limited, a limited company registered in England under company number 05716065, whose registered address 136 The Broadway Southall, Middx, UB1 1QN and whose main trading address is 136 The Broadway Southall, Middx, UB1 1QN.

2.1 Our Compliance Officer can be contacted by email at compliance@axremit.com, by telephone on 020 8606 9000, or by post at 136 The Broadway Southall, Middx, UB1 1QN

2.3 We are regulated by The Financial Conduct Authority (FCA).

2.4 We are MSB registered by the HMRC under MLR 2001

  3.What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4.Your Rights

4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

4.1.1 The right to be informed about Our collection and use of personal data;

4.1.2 The right of access to the personal data We hold about you (see section 12);

4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);

4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);

4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;

4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.1.7 The right to object to Us using your personal data for particular purposes; and

4.1.8 Rights with respect to automated decision making and profiling.

4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

4.3. For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

  5.What Data Do We Collect?

We may collect and process the following personal information about you

Type of Data       Description         Examples of how we use it

Contact for Customers

Who you are

Your address

How to contact you

Email address

Personal Details

Date of Birth

Gender

ID reference number

Visual image and personal appearance

Financial Details

Residential address

Analysis and profiling

Transactional Details

Bank details

Purpose of remittance

Amount

Beneficiary name

Beneficiary account details

Cash pay-out

Jurisdiction countries covered

Currencies

Placing remittance instructions

Making sure our products and services are fit for purpose

AML transaction monitoring

Anti-fraud purposes

Documentary Data and National Identifiers

Details about you that are stored in documents like:

Your passport

Driving licence

Residential address

Utility bills confirming your address

Open Data and Public Records

Electoral register

Other information about you that is openly available on the internet

Policy administration

Contractual

Account opening details

KYC on our customers

Handling complaints and compliance issues

6.How Do We Use Your Data?

6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.

6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

6.2.1 Providing and managing your Account;

6.2.2 Providing and managing your access to Our Site;

6.2.3 Personalising and tailoring your experience on Our Site;

6.2.4 Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);]

6.2.5 Personalising and tailoring Our products and services for you;

6.2.6 Replying to emails from you;

6.2.7 Supplying you with emails that you may unsubscribe or opt-out at any time by the unsubscribe link;

6.2.8 Market research;

6.2.9 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

6.3 With your permission We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news and offers on Our products AND We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.

6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

6.5.1 We have a legal obligation to retain your files for a period of 5 years from the date you closed your account with Us.;

  7.How and Where Do We Store Your Data?

7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

7.2 Your data will only be stored in the UK.

7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.

7.4 Steps We take to secure and protect your data include:

7.4.1 storing securely in the firm’s electronic infrastructure in accordance with the firm’s security statement. This policy includes requirements for restricting access to the firm’s data (including Personal Data) from external parties by means such as encryption and password protection.

8.Do We Share Your Data?

8.1 Subject to section 8.2, We will not share any of your data with any third parties for any purposes.

8.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.

8.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

8.4 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:

8.5 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.]

  9.What Happens If Our Business Changes Hands?

9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.

9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. When contacted you will not, however, be given the choice to have your data deleted or withheld from the new owner or controller.

  10.How Can You Control Your Data?

10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).

10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

  11.Your Right to Withhold Information

11.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data

11.2 You may restrict Our use of Cookies. For more information, see section 13 and Our Cookie Policy https://www.axremit.com/cookies/.

  12.How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable, and We will provide any and all information in response to your request free of charge. Please contact Us for more details at info@axremit.com or using the contact details below in section 14.

  13.Our Use of Cookies

Like many websites, our websites use cookies. Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. The data we collected is aggregated in its nature and is not specific to any one visitor. This helps us to improve our website and deliver a better service. For information about our use of cookies, please view our Cookies Policy.

  14.Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at info@axremit.com, by telephone on 020 8843 0011, or by post at 136 The Broadway Southall, Middx, UB1 1QN. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).

  15.Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.