Alpha Transfers Ltd Privacy’s Policy
Effective date 25/05/2018
Your privacy is very important to us, you rely on us with your sensitive data and information and we take this responsibility very seriously. We will not disclose your personal information with a third part unless it is necessary to comply with the services we provided or where we are legally obliged to do so.
Controller and Processor
MDRN FX Services Limited is a trading name of Alpha Transfers registered at Companies House under the number 06401266 and FCA (Financial Conducted Authority (540997), also registered as a data controller with the UK Information Commissioner’s Office with a registration number 1452366.
The legal bases
The law on data protection sets out a number of different reasons for collecting and processing your personal data, such as:
- Consent: In specific situations, we collect and process your data with your consent. For example, when you tick a box to receive email, newsletters, social media contacts.
- Contractual obligations: In certain circumstances, we need your personal data to comply with the services we provide. For example, if you instruct us to make a payment then we will collect the necessary information to provide the service.
- Legitimate interests: in specific situations, we require your data to pursue our legitimate business interests in a way which might reasonably be expected as part of running our business. We make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
How we collect your personal information
Under GDPR personal information is defined as “any information relating to an identified or identifiable natural person”. Personal data, or personal information means any information about an individual, from which that person can be identified. We collect personal data, or personal information, directly from you, for example when you:
- Visit any of our branches, websites, and complete a form to register with Alpha Transfers;
- Contact us by any means to enquire about us and services we provide;
- Engage with one of our marketing emails or on social media;
- Engage us to provide Financial Services;
- Subscribe to our services;
- Access one of our agents and Group Companies.
Other data controllers (including our clients) may also provide your personal data to us.
We may, also, obtain information about you from publicly available sources and collect website usage information using cookies (see “Cookies” section below).
We collect the following personal information from you
- Contact information such as name, title, email address, mailing address, phone number
- Evidence of your identity (for example passport information)
- Information about your social media profiles made available to us from your interactions with us on social media sites such as Facebook or WhatsApp.
- Unique Identifiers such as user name, account number, password
- Billing information such as a debit/credit card number and billing address
- Date of birth
- Demographic information such as age, education, gender, interests and zip code
We use this information to
- Register you with an account
- Provide the Services as described in our Terms and Conditions:
- Fulfill your Transaction/ (Airtime Top Up) Request
- Send you a confirmation
- Send you requested service information
- Improve your online experience and our website/ service
- Comply with our legal and regulatory obligations
We also maintain records of your transactions and card and bank details where appropriate.
If you wish to change how we use your data, you’ll find details in the ‘Your Rights’ section below. Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
Information Obtained about Third Parties
You may provide us with personal information about others, such as Recipients’ name and identifiers, address, phone number, bank account details or email address. If so, you confirm that you have appropriate authority to do so and to allow us to use that information and we will only use it for the specific reason for which it was provided to us.
If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us via email: firstname.lastname@example.org
Retention period for using your personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, regulatory or reporting requirements. To determine the appropriate retention period for personal data, we consider:
- the amount, nature, and sensitivity of the data;
- the potential risk of harm from unauthorised use or disclosure of the data;
- the purposes for which we process the data; and
- the applicable legal requirements.
Personal data will generally not be held for more than seven years after the end of the relationship/appointment, unless otherwise prescribed by law or regulation.
We do not sell or distribute your personal data for commercial gain. We may process your personal data without your knowledge where this is required or permitted by law.
We will share your personal information with:
- Service Provider such as credit reference agencies to verify your identity or Recipients of the money transferred through the Service.
- Agents/Partners, whom you gave us permission to share your data
We only permit them to process your personal information for specified purposes and in accordance with our instructions where we have your consent to do so and these companies are authorised to use your personal information only as necessary to provide these services.
Where your data may be processed
We may transfer your personal information overseas and to jurisdictions which may offer a level of legal protection to your information which does not meet European legal standards. In such cases, we take steps to protect your information and only make such transfers in compliance with the Data Protection Act 1998.
Cookies and Other Tracking Technologies
Technologies such as: cookies, beacons, tags, scripts or similar technologies are used by Alpha Transfers and our marketing partners, affiliates, or analytics or service providers. These technologies are used in analyzing trends, administering the website, tracking users’ movements around the website and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
Links to Other Web Sites
Social Media Widgets
As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you and site functionality.
When you download and use our Services, we automatically collect information on the type of device you use, operating system version, and system and performance information.
We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
We collect your location-based information for the purpose of [locating a place that you may be searching for in your area]. We will only share this information with our mapping provider for the sole purpose of providing you this service.
We may share your geo-location data with third parties for the purpose of them serving you ads for places (such as restaurants) in your area. If you do not wish to allow us to share your information in this manner, please opt-out by contacting us at email@example.com
You may opt-out of location-based services at any time by editing the setting at the device level or by emailing us at firstname.lastname@example.org
We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.
Your Rights- Correcting and Updating Your Personal Information
Whenever we process data we will ensure that we always keep your personal data rights in high regard and take account of these rights.
Upon request Alpha Transfers will provide you with information about whether we hold any of your personal information. You may request to review, delete or update your personal information to ensure it is accurate, by contacting us at this form. We aim to respond to your request for access within 30 days.
We will retain your information for as long as your account is active or as needed to provide you services, including a record of your Transactions on our website. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at this form. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and will securely delete your information when we no longer have a need to retain it.
In case if you are not satisfied with our response or believe that we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner’s Office (ICO).
The security of your personal information is important to us, we take steps to ensure that it’s treated securely. Our Policies and procedures are in place to safeguard it from loss, misuse and improper disclosure.
When you enter certain information such as a credit card number on our order forms
We Encrypt the transmission of that information using reasonable security measures. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our website, you can contact us at this form.
However, we will also send you service related email announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. You do not have an option to opt out of these emails, which are not promotional in nature.
27, Kilburn Lane,
Phone: +44 (0)20 8960 4140