Privacy Policy

This Privacy Notice (“Notice”) describes how Eqwire UK Limited (“Eqwire”) collects, stores and uses
personal information (“Personal Information”), including information about its customers, contacts,
suppliers and job applicants, as well as about visitors to Eqwire website at www.eqwire.com (“our site”).

In this Notice, we use the terms “we”, “us”, and “our” (and other similar terms) to refer to Eqwire, and “you” and “your” (and other similar terms) to refer to our customers, contacts, suppliers, job applicants
and site visitors.

This Notice is an important document. We recommend that you read it carefully and print and keep a copy for your future reference. When you deal with Eqwire, we will assume you agree to the uses of your Personal Information described in this Notice unless you tell us otherwise in writing.

Eqwire will collect and retain personal information about the customer and each authorised user to
enable Eqwire to deliver the electronic money account, the services linked to it and deal with any
enquiries that the customer may have about it. For data protection purposes, Eqwire UK Limited of 51
Eastcheap, London, England EC3M 1DT is the data controller of the personal information gathered by
Eqwire for such purpose. Eqwire might use a third party in relation to the electronic money account
and all necessary activities relating to the operation of the electronic money account, in which case
that third party provider will be the owner and controller of the personal information they require to collect in order to operate the relevant service. The use of personal information by third-party service
providers will be set out in their privacy policy.

Our data controller registration number is ZA805830. You can check our registration on the Data
Protection Public Register by visiting https://www.ico.org.uk/esdwebpages/search.

If you have any questions about how we collect, store and use Personal Information, then please contact our Data Protection Officer. You can e-mail us at [email protected].

Depending on how you engage with us, we will collect and process the following data about you:

A. Information that you provide voluntarily

• We may monitor or record telephone conversations or other communications between you and us and keep recordings or transcripts of them and, if you contact us, we may keep a record or copy of that correspondence.
• If you are an employee or other staff member of an Eqwire corporate customer, supplier or partner: We will use the personal and/or professional contact details, professional title and if necessary identity documents that we ask you to provide for the purposes of carrying out customer due diligence and KYC checks, managing invoicing and/or payments and corresponding with our corporate customer, supplier and/or partner in connection with the applicable services. We may also keep your contact preferences, such as requests to subscribe to publications that we may circulate from time to time, to receive news about any events we are organising or participating in, or to receive information about Eqwire and the services we provide.
• If you are a website visitor: We will use any information that you provide by filling in forms on our site. This includes information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services. We may also ask you for information when you report a problem with our site.
• If you write to us: We will keep a record of that correspondence.
• If you complete any of our surveys: We will use your responses for research purposes.
• If you are a job applicant: We will use your contact details, copies of your job application, curriculum vitae and covering letter, as well as any references provided, for the purposes of processing your application and for general recruitment and selection purposes.

B. Information that we collect automatically

• If you are an Eqwire customer: You may give us information about you when you register with our platform, by communicating with us by phone, email or otherwise. The information you give us may include your name, address, email address, phone number, date of birth, identity documents, username (or similar identifier), job title and company information. We will automatically collect information about the transactions that you make using your electronic money account, your account number, transaction amount, transaction date, beneficiary name and any details about applicable disputes in connection with our provision of the electronic money account, settlement and client funds safeguarding services in relation to the provision of the electronic money account.
• If you are a website visitor: We will collect, store and use certain, limited information relating to your use of the Eqwire website for the purposes of better understanding the types of visitors who browse our website and improving our website offering. Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our website, including the pages accessed and links clicked. Collecting this information enables us to better understand the visitors who come to our website, where they come from, and what content on our website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our website to our visitors. Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.

С. Information we collect about you from publicly available sources

Information we collect about you from publicly available sources. This may include information available from social media (depending on your settings and the applicable privacy policies), including social media engagement metrics such as numbers of connections, followers and clicks, and information from public resources and registers.

D. Information we receive from other sources

We may receive further information about you if you use any of the services we provide. We work closely with third parties (including, for example, business partners, service providers, identity verification providers) and may receive information about you from them. We may combine information we receive from these other sources with information you give to us and information we collect about you.

Depending on how you engage with us, we will use your information for the following purposes:

• For communication purposes: We use information and preferences to communicate with our customers, partners and suppliers and to send publications that we may circulate from time to time, news about any events we are organising or participating in, and/or other information about Eqwire and the services that we provide. We will only contact you in accordance with the contact preferences that you have specified (which may include e-mail) and will not send you marketing communications where you have told us you do not wish to receive these. You can specify your contact preferences when registering online to receive communications from us (for example, through the Eqwire website) or by subsequently advising us of your contact preferences using the contact details provided above.
• To provide our services to our customers: We will use Personal Information to provide our services to our customers, for example, opening, administering, operating and providing electronic money accounts (including using mobile phone numbers and email addresses to provide balance updates and transaction alerts in the manner requested by our customers), facilitating settlement and reconciliation of the accounts, carrying out due diligence checks and transaction monitoring for compliance with regulatory obligations and dealing with any customer enquiries.
• To receive services from our suppliers and partners: We will use our suppliers’ and partners’ Personal Information to receive their services from them. Please note that we will assume, unless our suppliers instruct us otherwise in writing, that we may use and disclose their Personal Information in such manner as we believe is reasonably necessary to receive and to review the provision of those services from them.
• To collect our charges or costs in connection with other legal enforcement: We will use Personal Information to agree payment arrangements with you, and to collect our fees and costs owing to us in connection with legal enforcement.
• To manage our supplier relationships: We will use our suppliers Personal Information to agree payment arrangements with our suppliers, and to make payments to them.
• For recruitment and selection purposes: If you apply for a position with Eqwire, we will use your Personal Information to process your job application and for general recruitment and selection purposes. If you are successfully recruited, the Personal Information you provide will be stored on your personnel file.
• For monitoring and quality assurance purposes. We may monitor telephone and e-mail communications between our employees and third parties for the purpose of quality assurance and training or as otherwise permitted by law.
• For website analytics purposes: We may collect, store and use certain, limited information relating to your use of our website for the purposes of better understanding the types of visitors who browse our website and improving our site offering. Other than information you choose to submit voluntarily to receive communications from Eqwire (as described in the “If you are a contact of Eqwire” bullet above), the information we collect about website visitors does not enable any visitor to be individually identified, is processed only in anonymised, aggregated form, and will only be used for website analytics purposes as described in our Cookies Statement.
• In some cases we may also use the personal data we hold about you to comply with our legal obligations, or enter into or perform a contract with you.
• Where we have your consent, we and or our partner may also send you direct marketing communications (for example, by email). You can withdraw this consent at any time as described below.

You have the following data protection rights, subject to certain exemptions and satisfying certain conditions:

• If you wish, to access, correct, update or request deletion of your Personal Information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading above.
• In addition, you can object to the processing of your Personal Information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading above.
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading above.
• Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading above.
• You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
• We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

We may disclose your Personal Information with the following categories of recipients:

• Group companies, business partners, service providers and other affiliated third parties: who provide services to us (for example, electronic money issuance, client funds reconciliation and safeguarding services, or to support the delivery of our website or due diligence services), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.
• To any competent law enforcement body, regulatory, government agency, court or other third party: where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
• To any other person with your consent to the disclosure.

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only

1. Where the processing is in our legitimate interests and not overridden by your rights,
2. Where processing is necessary to fulfil a contract with you (such as your electronic money account contract if applicable),
3. Where processing is necessary to fulfil a contract with partners and suppliers that we work with, or
4. We have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person (e.g. our legal obligation to carry out appropriate customer due diligence and anti-money laundering checks).

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading above.

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Statement.

If Eqwire transfers the Client’s information to a third party in a country outside of the European Economic Area, Eqwire will ensure that the third party agrees to apply the same levels of protection that Eqwire is legally obliged to have in place when Eqwire processes personal data.

We retain Personal Information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.