Privacy Policy

Background

Vowpay Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About Us

Vowpay Limited.

Private Limited Company registered in England under company number 09200297

We are regulated by the Financial Conduct Authority (FCA) and the Information Commissioners Office (ICO).

2. What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3. What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, "the Data Protection Legislation") as 'any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier'.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

4. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

Right	Description
a) The right to be informed	About our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access	The personal data we hold about you. Part 10 will tell you how to do this.
c) The right to rectification	To have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten	i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
e) The right to restrict processing	i.e. prevent the processing of your personal data.
f) The right to object	To us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent	This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability	This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling	We do not generally use your personal data in this way, Part 6 explains more about how we use your personal data, including any automated decision-making or profiling.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner's Office (ICO) or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner's Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.

5. What Personal Data Do Vowpay Collect and How?

We collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any 'special category' or 'sensitive' personal data or personal data relating to children.

Data Collected	How We Collect the Data
Identity Information including: your name, postal address, email address, mobile number, and date of birth, citizenship, and government or national identification numbers.	Through mobile application form and your interactions with Vowpay Limited. Through mobile application or other services we offer (some of which may be managed by third parties on behalf of Vowpay Limited). While providing customer support or consultation, using email, post, call centres or Over The Top i.e. WhatsApp, iMessage, Facebook or SMS. Through the process of maintaining and upgrading our services. Through automated means such as communications protocols, e-mail communications and cookies. Through our mobile applications (some of which may be managed or have functionalities provided by third parties on behalf of Vowpay Limited). Through your use of social media or other public data sources. Through your interest in Vowpay Limited advertisements placed on third party sites.
Contact information including: your name, postal address, email address, mobile number.	As above
Business information including; how you use of our Services, bank and credit information.	As above
Payment information including: e.g. card details, bank account numbers, transaction information, receipts, including your money transfers.	As above
Profile information including; e.g. consents and permissions to contact or marketing choices.	As above
Data from third parties including: e.g. contact information and profile information.	As above
Technical information, including: the host from which you access the Internet, your IP address or device advertising ID, geolocation if enabled, information about your device (such as device properties, settings, applications, storage and usage information), mobile application, the date and time you access our mobile application. We collect personal information on your Vowpay mobile application activities.	As above
Compliance information, including; Anti-money laundering (AML) due diligence information, fraud prevention, identity verification, credit referencing, politically exposed persons (PEP) and sanction screening and checks.	As above

6. How Does Vowpay Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using your personal data. The following table describes how we will use your personal data, and the lawful basis for doing so.

What We Do	What Data We Use	Our Lawful Basis
Vowpay Limited utilises the personal information it collects to: Assist us in providing products and services to you and help you to receive a personalised experience and assist you in carrying out transactions and accessing account information. To recognise you and allow you to sign-in whilst using our services. To perform analytics on understanding our customers, improving their experience; To deliver information specific to your interests. To better understand the effectiveness of our promotional campaigns and whether you acted on our promotional messages; To promote safety, reduce financial risk and combat fraud across our products and services.	Identity Information including: your name, postal address, email address, mobile number, and date of birth, citizenship and government or national identification numbers Contact information including: your name, postal address, email address, mobile number Business information including: how you use of our products and services, bank and credit information Payment information including: e.g. card details, bank account numbers, transaction information, including your money transfers Profile information including: e.g. Consents and permissions to contact or marketing choices Data from third parties including: e.g. contact information, profile information Technical information including: the host from which you access the Internet, your IP address or device advertising ID, geolocation if enabled, information about your device, mobile application, the date and time you access our mobile application Compliance information including: Anti-money laundering (AML) due diligence information, fraud prevention, identity verification, credit referencing, politically exposed persons (PEP) and sanction screening and checks	To provide our products and services to you: This includes using personal information necessary for conducting money transfers, payment services, prepaid cards. We may use this information in the performance of a contract with you or for taking steps to enter into a contract for any of the above or for any other Vowpay Limited products or services. It is thus a precontractual condition to provide personal information failing which we may be unable to provide our products and services to you. For legal and compliance purposes: This includes using personal information to comply with our legal and regulatory obligations to the global financial system in relation to anti-money laundering and counter-terrorist financing; sanctions; detection, prevention and prosecution of fraud and theft, as well as preventing illegitimate or prohibited use of our services or other illegal or wrongful activity. This may also include establishing, exercising, or defending legal rights and claims of Vowpay Limited and others, and monitoring and reporting compliance issues. For legitimate business purposes: This includes using personal information to analyse and improve our products, locations, services, operations, the running of the mobile application and your customer experience, and for measuring marketing return on investment and brand satisfaction. This may include using your information to conduct market research surveys. We may also use your personal information to provide customer services and to help protect the security and integrity of our technology, systems, and services. Based on your consent: We may also use your information on this basis. At the time of entering into a transaction with us you are consensually providing us with your information. This includes consent for receiving marketing communications, or where otherwise required by applicable law. If we request your consent, we will inform you of the intended purposes for which your information will be processed.
We use internet technologies like cookies and web beacons. Vowpay Limited has implemented the capability for the user to manage cookies on our website(s). We will only read or write cookies based on your preference level. (Note: cookies set prior to you changing your preference level are maintained on your computer; to remove them please refer to your browser settings and, if needed, your browser’s “Help” function). If your browser does not support JavaScript, you can find out about the cookies used on our sites and can only manage the use of cookies through your web browser settings. Please note that if you disable all cookies on your browser, this will limit the features of this site and may impact the ability to complete your transaction.	To assist us in providing services to you and help you to receive the best experience using this mobile application; To allow you to navigate the mobile application during your visit without having to re-enter your password; To track activity on our mobile application; To verify your identity when you use our mobile applications, and we may contact your mobile carrier to assist us in verifying your identity; To deliver information specific to your interests. To better understand the effectiveness of our promotional campaigns and whether you acted on our promotional messages; To identify you when you visit the mobile application, to personalise the content of the mobile application for you and to assist you in carrying out transactions and accessing account information.	Same as above

With your permission and as permitted by law, we may use your personal data for marketing purposes, which may include contacting you by using email, post, call centres or Over The Top i.e. WhatsApp, iMessage, Facebook or SMS with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

Automated decision-making

We do not generally use your personal data in any automated decision-making or profiling.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

7. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data	How Long We Keep It
Identity Information including: your name, postal address, email address, mobile number, and date of birth, citizenship, and government or national identification numbers.	Vowpay Limited will keep personal data for five years following the completion of the transaction or from the end of the business relationship. Personal information will be destroyed after the five years has expired unless: Vowpay is required to retain it under statutory obligation, (e.g. tax purposes) or Vowpay is required to retain it for legal proceedings, (e.g. civil or criminal proceedings) or You have consented to the retention for example: by agreeing to this in our terms and conditions.
Contact information including: your name, postal address, email address, mobile number.	As above
Business information including; how you use of our Services, bank and credit information.	As above
Payment information including: e.g. card details, bank account numbers, transaction information, receipts, including your money transfers.	As above
Profile information including; e.g. consents and permissions to contact or marketing choices.	As above
Data from third parties including: e.g., contact information, profile information.	As above
Technical information, including: the host from which you access the Internet, your IP address or device advertising ID, geolocation if enabled, information about your device (such as device properties, settings, applications, storage and usage information), mobile application, the date and time you access our mobile application. We collect personal information on your Vowpay mobile application activities.	As above
Compliance information, including; Anti-money laundering (AML) due diligence information, fraud prevention, identity verification, credit referencing, politically exposed persons (PEP) and sanction screening and checks.	As above

Your personal information will be retained in accordance with statutory periods contained in regulations applicable to financial transactions including those in anti-money laundering, anti-terrorist financing and other laws applicable to us. Otherwise, we will retain your information only if necessary for the specific purposes it was collected, or to resolve any query you may raise. We will typically keep your information for no longer than the purpose(s) for which it was obtained, unless we have a legal obligation to keep it for a longer period or retention is advisable for Vowpay Limited's legal position (for example, regarding applicable statutes of limitations, litigation or regulatory investigations).

We are thus mandated by law to keep your information over a range of 5 to 10 years in our various jurisdictions after a given transaction, unless we have a legal obligation to keep it for a longer period.

8. How and Where Do Vowpay Store or Transfer My Personal Data?

We may store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.

AND

We may store some of your personal data within the European Economic Area (the "EEA"). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.

AND

We may store some or all of your personal data in countries outside of the UK. These are known as "third countries". We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

AND

We may store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner's Office.

AND

We may use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner's Office.

Please contact us using the details below in Part 11 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner's Office, where we are legally required to do so;

We may transfer your information to parties in countries outside the EEA, as required by applicable law, regulatory authorities, law enforcement and government agencies. Additionally, when you send or receive money to or from another country, we will also be required to share some of your personal information with that country as required or permitted by law. We may transfer certain personal information about you to our processing units in countries outside the EEA and process it to fulfil our legal and compliance obligations which apply to the services we provide. We also store certain personal information we collect based on your marketing choices.

Personal information transferred outside the EEA to countries that the European Commission has not found to provide adequate protection will be protected by appropriate contractual clauses or other approved mechanisms, as required by data protection legislation.

9. Does Vowpay Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:

1. If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
2. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
3. We may share your personal data with other companies in our group of companies for the provision of products and services to you.
4. We may sometimes contract with third parties to supply products and services.

For any of the purposes listed in this statement, Vowpay Limited may disclose applicable personal information including, but not limited to, your name, contact information, national identification number, customer ID number, address, transaction patterns and bank account information to the following types of organisations or parties:

• Vowpay Limited (parent entity) group of companies and its affiliates;
• Required local PSD licensing entities relevant to a transaction;
• Our agents (if any) or business partners who facilitate the money transfer transaction or specific payment services you have requested;
• Service providers, payments processors, banking partners and data processors contracted to provide business and customer services;
• Customer services, based on your consent where applicable, including marketing, advertising and customer satisfaction and market research on our behalf;
• Service providers and data processors contracted to help us validate the accuracy of the information provided by you, and to authenticate your identity and manage risks related to security, fraud and identity.
• Third parties that you have authorised to access your account and/or your account information in order to perform services for you, such as account information service providers and payment initiation service providers.

We may transmit personal information we possess as required or permitted by applicable laws and regulations, to regulatory and financial authorities, law enforcement bodies, courts, governments or government agencies, to meet compliance and legal obligations or to assert or defend the rights and interests of Vowpay Limited or others.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party's obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.

10. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a "subject access request".

There is not normally any charge for a subject access request. If your request is 'manifestly unfounded or excessive' (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request usually within 48 hours and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request.

You will be kept fully informed of our progress.

11. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

12. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available via our website. This Privacy Notice was last updated on 25 December, 2024.