Moneycorp Inc ("we", "our", "us") is committed to maintaining the highest standards of data protection. We have therefore agreed to comply with the EU-U.S. Privacy Shield (Privacy Shield) regarding the collection, use, retention and deletion of personal data we receive in the United States (U.S.) from the European Economic Area (EEA). For the purposes of this policy, personal data we receive from the European Economic Area will be known as EEA Personal Data.
For purposes of enforcing compliance with the Privacy Shield, Moneycorp Inc. is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
For more information about the Privacy Shield and to view our certification, see the U.S. Department of Commerce Privacy Shield website located at: https://www.privacyshield.gov.
2. Personal Data Collection and Use
Described below are the types of EEA personal data we may receive in the U.S. as well the purposes for which we may use that EEA personal data.
What EEA personal data may Moneycorp Inc. receive?
Moneycorp Inc. may receive any EEA Personal Data that you have:
1. Provided to a Moneycorp Group company over email, telephone, fax, post or online.
2. Provided to a Moneycorp Group Referring Partner located in the EEA, with your consent that you wish to be contacted by Moneycorp Inc.
Examples include your:
- Email address
- Residential address
- Date of Birth
- Telephone Number
- Banking Details
- Identification Documents (e.g. passport)
Why does Moneycorp Inc. process EEA personal Data?
Moneycorp Inc. may process EEA Personal Data for the following purposes:
- Facilitating your order or enquiry
- To complete the delivery of our foreign exchange and international payment services ("Services")
- Training and quality purposes
- To comply with our legal and regulatory obligations
3. Data Transfers to Third Parties
Moneycorp Inc. will only transfer your EEA personal data to:
1. Moneycorp subsidiaries, overseas branches and affiliate companies
- Moneycorp Bank Limited (Gibraltar);
- Moneycorp CFX Limited (UK);
- Moneycorp Financial Risk Management Limited (UK) (including Irish and Spanish branches);
- Moneycorp US Inc. (Data Controller);
- Moneycorp Shared Services Limited (UK);
- Moneycorp S.L.U. (Spain);
- Moneycorp Technologies Limited (Ireland);
- Moneycorp Technologies Limited (UK);
- Moneycorp Banco de Câmbio S.A. (Brazil);
- Rochford Capital Pty Limited (Australia);
- TTT Moneycorp Limited (including French, Irish, Romanian and Spanish branches and UAE and Portugal representative offices) (UK) (Data Controller); and
- TTT Moneycorp Pty Limited (Australia).
The purpose of disclosure will be to facilitate your order or enquiry and/or to complete the delivery of our Services. If we transfer your EEA Personal Data to one of the above named establishments, we will take steps to ensure that your EEA Personal Data is protected with the same level of protection the Privacy Shield requires. Moneycorp US Inc. and TTT Moneycorp Limited are Data Controllers of personal data processed by Moneycorp Inc.
2.Third Party Service Providers
- WNS Global Services (India)
WNS Global Services (WNS) is a provider of outsourcing solutions and performs functions on our behalf in the areas of IT development, IT support, back office, compliance and finance. Moneycorp Inc. may pass your EEA personal data to WNS in order to complete the delivery of our Services.
We have entered into a written agreement with WNS requiring them to provide the same level of protection required by the Privacy Shield Principles.
We will also take reasonable and appropriate steps to ensure that WNS process EEA Personal Data in accordance with our Privacy Shield obligations and to stop and remediate and unauthorized processing.
Under certain circumstances, we will remain liable for the acts of WNS where they are handling EEA Personal Data that we transfer to them in order to perform services on our behalf.
3. Public Authorities
This will only be in response to lawful requests made from public authorities in order to meet national security, public interest or law enforcement requirements.
We will not transfer your EEA personal data to any unaffiliated third party Data Controller, unless we have your explicit consent to do so.
Moneycorp Inc. maintains reasonable and appropriate security measures to protect EEA Personal Data from loss, misuse, unauthorised access, disclosure, alteration, or destruction in accordance with the Privacy Shield.
You may have the right to access the EEA Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome, where it would violate the rights of someone other than the individual requesting access or where we are required to retain the EEA Personal Data by law.
If you would like to request access to, correction, amendment, or deletion of your EEA Personal Data, you can submit a request to the contact information provided below. We may request specific information from you to confirm your identity.
If EEA Peronal Data is to be disclosed to a third party not specified in this Policy or is to be used for a new purpose that is materially different from the purposes for which it was originally collected or subsequently authorised, Moneycorp will provide you with the opportunity to choose whether to have your EEA Personal Data so disclosed or used. Requests to opt out of such disclosures or uses of EEA Personal Data should be sent to firstname.lastname@example.org.
7. Contact Us
You can direct any questions or complaints about the use or disclosure of your EEA Personal Data to us at:
Privacy Shield Officer
We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your EEA Personal Data within 45 days of receiving your complaint.
For any unresolved complaints, Moneycorp has chosen to cooperate with the EU Data Protection Authorities, and comply with the information and advice provided by such authorities. Please visit http://ec.europa.eu/justice/data-protection/bodies/index_en.htm where you can find the relevant DPA contacts for more information and assistance. As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address complaints not resolved by any other means.
7. Changes to this Policy
We reserve the right to amend this Policy from time to time in order to be consistent with the Privacy Shield's requirements.
- Effective Date: 1st January 2018
- Last Modified: 6th March 2020
An entity who (either alone or jointly) determines the purposes, conditions and means of the processing of personal data.
An entity that processes data on behalf of the Data Controller.
|EU Data Protection Authorities
National authorities tasked with the protection of data and privacy as well as enforcement. A complete list of applicable authorities can be found at: http://ec.europa.eu/justice/data-protection/bodies/index_en.htm
|European Economic Area
The European Economic Area combines the countries of the European Union and members countries of the European Trade Association. A complete list of applicable countries can be found at: https://www.gov.uk/eu-eea.
|EEA Personal Data
Personal data Moneycorp Inc. receives from the European Economic Area.
This includes Moneycorp Bank Limited (Gibraltar); Moneycorp CFX Limited (UK); Moneycorp Financial Risk Management Limited (UK) (including Irish and Spanish branches); Moneycorp (Hong Kong) Limited (including UK branch); Moneycorp US Inc. (USA) (Data Controller); Moneycorp Shared Services Limited (UK); Moneycorp S.L.U. (Spain); Moneycorp Technologies Limited (Ireland); Moneycorp Technologies Limited (UK); Moneycorp Banco de Câmbio S.A (Brazil); and TTT Moneycorp Limited (including French, Irish, Romanian and Spanish branches and UAE and Portugal representative offices) (UK) (Data Controller); TTT Moneycorp Pty Limited (Australia); and Rochford Capital Pty Limited (Australia).
Any information that can be used to directly or indirectly identify a living person.
|Process, Processing, Processed.
Any operation or set of operations which are performed on data. This includes collecting, viewing, recording, organising, structuring, storing, using and destroying.
An entity who has referred an individual or company to a Moneycorp Group establishment in order to engage in our services. They are also known as Introducers and include property agents, law firms, financial accountants and banks.
Foreign exchange and international payment products and services provided by Moneycorp Group companies.