PRIVACY POLICY

The following provides detail about Cashpot Limited‟s Privacy Policy. We are committed to protecting your personal information from unauthorised access, use and disclosure. We use the personal information that we collect from you to process requests or orders, identify personal preference and match your needs with relevant products and services.

Customer Privacy Policy

Our Information

The „Data Controller* is Cashpot Limited. Our Trading office, is No 5 Harbour Exchange Square,Harbour Exchange Square,Canary Wharf,LONDON E14 9GE, which is registered with the Registrar of Companies in England and Wales as a

limited liability company.

In this document, „Cashpot Limited‟, „we‟, and „us‟ refers to Cashpot Limited and „you‟ refers to our customers and website.

Privacy Statement

This privacy statement sets out our current policies and demonstrates our commitment to your privacy. We are obliged to inform you that any personal information we have about you has a high level of protection against any unauthorised or accidental disclosure, access or deletion. We have strict security procedures covering the storage and disclosure of your information to prevent unauthorised access to comply with the General Data Protection Regulation (GDPR). Cashpot Limited will only process personal data for the purpose it was collected for. If we intend to process data other than for specified use, we will contact you before undertaking further processing.

In this Privacy Policy, Your information is sometimes called "personal data". We may also sometimes collectively refer to handling, collecting, protecting and storing Your personal data as "processing" such personal data.

In this Privacy Policy the term "Data Protection Legislation" means the EU General Data Protection Regulation 2016/679; together with all other applicable legislation relating to privacy or data protection.

Personal Information We Collect

Cashpot Limited may obtain the following personal information about an individual:

  1. We can collect identity data which may include your title, first name, last name, maiden name, phone number and date of birth.
  1. Your contact information such as Your email address and telephone number (or any telephone number used to call our office/customer services)
  1. Your demographic information such as age, education, gender, and interests
  1. Evidence of Your identity (for example passport, Driving licence or other Government issued photo ID)
  1. unique identifiers such as username, account number and password
  1. Your payment details or other financial data, e.g.: Your bank or payment method provider‟s name, or your account number, sort code and billing address
  1. Cashpot Limited does not collect any sensitive data about its customers. Sensitive data refers to data that includes details about race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data.

We also collect from You information in relation to other people (e.g.: details of the beneficiary/recipients of Your money transfers), where You provide us with such information. By providing us with such information you confirm that you have obtained any necessary permission from such persons to the reasonable use of their information for such purposes in accordance with this notice, or are otherwise permitted to give us this information on their behalf. Please also ensure that those other people are aware of this notice and that the provisions of this notice are clearly communicated to them.

Source of Information (Collection of Information)

Cashpot Limited can collect personal data through a variety of sources:

  1. Information You give to us when You use our services. If You use our services You will need to provide certain information including Your name, address, contact number and other details along with remittance amount, as well as the name and other details the recipients of the money transfers that you instruct us to carry out.
  1. Other information You give to us. This is information about You that You give us by filling in forms (e.g.: the „contact us‟ section) or by corresponding with us by phone, e-mail or otherwise. It includes, for example, information You provide when You register with us to contact You.
  1. Social Media. Depending on Your settings or the privacy policies for social media and messaging services such as Facebook, You might give us permission to access information from those accounts or services.
  1. Other Sources. We may receive information about You from other sources, including publicly available databases and combine this data with information we already have about You. This

helps us to update, expand and analyse our records and provide services that may be of interest

to You.

Use of Information

Our primary purpose in collecting user information is to provide You with a safe, smooth, efficient, and customised experience and to provide the services You have requested from us. We may also use the information that You have provided to ensure that the content on our site is presented in the most effective manner for You.

We process personal information for the following reasons to:

  1. Manage our relationship with our customers.
  1. Deliver products and services.
  1. Make and manage customer payments.
  1. Manage fees, charges, interest and debt recovery.
  1. Detect, investigate and prevent financial crime.
  1. Comply with the laws and regulations that apply to Cashpot Limited.
  1. Respond to complaints and in seeking to resolve them.
  1. Ensure that it carries out its business in an effective and efficient manner.

Legal Basis of Processing

Cashpot Limited applies the following legal basis in its processing of personal data:

  1. When it has obtained clear consent from the Data Subject for a specific purpose i.e. Marketing.
  1. When it takes specific steps to enter into a contract or performs its contractual obligations such as providing services to its customers.
  1. When it performs its legal or statutory obligations such as reporting to regulators or sanction screening.
  1. Cashpot Limited does not rely on legitimate interest as a lawful basis for processing personal data under the GDPR.

Disclosure of Information

Cashpot Limited may decide to share personal information with other external organisations. This is essential in the delivery of its services, to conduct its business and to comply with all regulations. Also where:

  1. We can share personal information to authorities that can include HMRC, FCA, Government agencies and other regulators based in the United Kingdom.
  1. Other relevant jurisdictions which may require reporting in certain circumstances.
  1. Professional advisers including accountants and auditors who provide consultancy, legal and accounting services.
  1. Companies that provide us with the identity verification of customers.
  1. Credit reference and fraud prevention agencies.
  1. Financial Service companies that help us to prevent, detect and report fraudulent and criminal activities.
  1. Companies that provide us with information about immigration status.
  1. Agents and paying out partners that provides business to Cashpot Limited.
  1. Banks and other financial services companies that provide payment or remittances services.
  1. Companies that provide marketing services to Cashpot Limited.

Sending data outside the EEA

Personal data about individuals can be transferred to locations outside the European Economic Area (EEA). When this is done, Cashpot Limited ensures that this transfer is lawful. We also make every effort to ensure that there is an appropriate level of protection and safeguards in place, in accordance with the GDPR.

Data Subject Rights

Data Subjects have certain rights in relation to their personal data:

  1. The right to access and rectify the information “Cashpot Limited” holds about them.
  1. The right to erase or restrict processing.
  1. The right to object to processing.
  1. The right to data portability.

Data Subjects can exercise their rights by contacting the DPO by email at support@afripay.co.uk or in writing to: The Trading office, No 5 Harbour Exchange Square,Harbour Exchange Square,Canary Wharf,LONDON E14 9GE

When you choose to exercise your rights, it may delay or prevent Cashpot Limited from performing its contractual and legal obligations. It could also mean that Cashpot Limited will need to cancel a service that it may have with you. Cashpot Limited may still be able to process personal data if it has a lawful basis of doing so.

Request a copy of Personal Information

You have the right to request a copy of the personal information that Cashpot Limited holds. To do so, please either email your request at support@afripay.co.uk or write to The Trading office, No 5 Harbour Exchange Square,Harbour Exchange Square,Canary Wharf,LONDON E14 9GE.

Cashpot Limited will not ask for a fee to access personal data. However, it may charge a reasonable fee if the request is clearly unfounded, repetitive or excessive. Alternatively, Cashpot Limited can refuse to comply with a request in such circumstances.

Cashpot Limited can request specific information to help confirm an identity and to ensure the right to access personal data. We may also contact you to ask for further information in relation to your request to speed up our response. Cashpot Limited will ensure that it provides the information in the commonly used electronic or written format.

Cashpot Limited reserves the right to withhold information if it has any adverse effects on the rights and freedoms of other Data Subjects. This means that disclosing that information can be against the public or business interest.

Cashpot Limited aims to respond to all legitimate requests within one month. Occasionally it may take an additional two months if the request is particularly complex or multiple requests have been made. In this case, Cashpot Limited will notify you and explain why such an extension is necessary.

Withdraw Consent

You have the right to withdraw consent for something you have consented to earlier such as Marketing. This can be achieved in the following ways:

  1. Using the Contact Us Form, through the website Cashpot Money Transfer

 

  1. Telephoning our Main Contact Center on +44(0) 208 692 2085.
  1. Unsubscribe from any promotional messages that you have opted in for.
  1. By visiting our office.
  1. In writing to; The Trading office, No 5 Harbour Exchange Square,Harbour Exchange Square,Canary Wharf,LONDON E14 9GE.

Please allow 10 working days for the systems update and Cashpot Limited‟s records to reflect the request to change your preferences.

Complaints

Data subjects can report a concern on the Information Commissioners Office website at ico.org.uk or call their helpline on 0303 123 1113.

Accuracy

You need to ensure that you provide Cashpot Limited with accurate and relevant information as well as informing us of any changes. Cashpot Limited reports, as part of its legal obligations, to the regulatory authority based on the information provided.

If inaccurate information is provided, Cashpot Limited may not be able to provide services to the data subject.

Automated Decision Making

Cashpot Limited, in its processes, does not rely on automated decision making and profiling.

Retention of Information

Cashpot Limited will retain personal information in line with its Data Retention Policy. Cashpot Limited will only retain personal data for as long as necessary to fulfill the purposes it was collected for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, it considers the amount, nature, and sensitivity of the personal data. If the personal information in no longer needed, Cashpot Limited may destroy or delete it.

Third Party Sites and Social Media

Please note that this Privacy Statement does not extend to third party service providers. Any social media post/comments and any public reviews you send to us such as Facebook, will be shared under the terms of the relevant platform and could be made public. We do not control these platforms and are not responsible for this kind of sharing.

*The Data Controller is a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.

**The Data subject means an individual who is the subject of personal data. In other words, the data subject is the individual whom particular personal data is about.


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