Privacy Policy & GDPR

Before we begin
This policy (Privacy Policy) applies to personal
information held by E-pay International Limited as data
controller, as described below. It explains what
information we collect about you, how we’ll use that
information, who we’ll share it with, the circumstances
when we’ll share it and what steps we’ll take to make
sure it stays private and secure. It continues to apply
even if your agreement for payment services agreement
or other products and services with us ends.
This Privacy Policy covers any products or services you
have with us, including Virtual IBAN accounts, debit
cards, payment gateway services and others. Sometimes
we may need to provide you with separate or further
information about specific products and services. This
information will also apply.
Wherever we’ve said ‘you’, ‘your’ or ‘Customer‘, this
means you, any authorised person on your account,
anyone who does your banking or deals with us for you
(e.g. trustees or executors, attorneys under a Power of
Attorney) and other related people (including authorised
signatories, partners, members and trustees). An "User
Account" is an account opened by E-pay International
Limited that allows to view transaction data from the
Customer’s merchant account.
When we say ‘we’, we mean E-pay International Limited
which acts as a data controller in respect of your
personal data.
All of your data that are subject to this Privacy Policy are
controlled and administered by E-Pay International
Limited, registered in the United Kingdom with
registration number: #10086951. E-Pay International LTD
is an Authorised Payment Institution by the Financial
Conduct Authority (FCA) of the United Kingdom, number
802210. E-Pay International Limited listed as a Visa
Merchant Agent operating a PCI DSS Level 1 Certified
Payment Gateway. E-Pay International Limited is VAT
registered, VAT Number: GB310234074.
You need to accept all the provisions in this Policy when
you sign up for the E-pay products and services. If you do
not agree with anything in this Policy, then you may not
register and/or use any of the products or services.

What information we collect
We’ll only collect your information in line with relevant
regulations and law. We may collect it from a range of
sources and it may relate to any of our products or
services you apply for, currently hold or have held in the
past. We may also collect information about you when
you interact with us, e.g. visit our websites, call us or ask
about any of our products and services.
Some of it will come directly from you, e.g. when you
provide ID to open an account. It can also come from
your financial advisor or other sources you’ve asked us to
obtain information from. We might also get some of it
from publicly available sources.
The information we collect may include:
Information that you provide to us, e.g.:
• personal details, e.g. name, previous names, gender,
date and place of birth;
• contact details, e.g. address, email address, landline
and mobile numbers;
• information concerning your identity e.g. photo ID,
passport information, National Insurance number,
National ID card and nationality;
• user login and subscription data, e.g. login credentials
for online banking;
• other information about you that you give us by filling
in forms or by communicating with us, whether face-
to-face, by phone, email, online, or otherwise;
Information we collect or generate about
you, e.g.:
• your financial information and information about
your relationship with us, including the products and
services you hold, the channels you use and your ways
of interacting with us, your payment history,
transactions records, payments into your account and
information concerning complaints and disputes;
• information we use to identify and authenticate you,
e.g. your signature or additional information that we
receive from external sources that we need for
compliance purposes;
• information included in customer documentation,
e.g. a record of advice that we may have given you;
• information about your device or the software you
use, e.g. its IP address, technical specification and
uniquely identifying data;

• cookies and similar technologies we use to recognize
you, remember your preferences and tailor the
content we provide to you – our cookie policy contains
more details about how we use cookies and can be
found at www.monneo.com/cookie-policy;
• risk rating information, e.g., transactional behaviour
and underwriting information;
• investigations data, e.g. due diligence checks,
sanctions and anti-money laundering checks,
external intelligence reports, content and metadata
related to relevant exchanges of information between
and among individuals and/or organisations,
including emails, calls, etc.;
• records of correspondence and other
communications between us, including email, calls
and instant messages;
• information that we need to support our regulatory
obligations, e.g. information about transaction details,
detection of any suspicious and unusual activity and
information about parties connected to you or these
activities.
Information we collect from other sources,
e.g.:
• information you’ve asked us to collect for you, e.g.
information about your accounts or holdings with
other companies including transaction information;
• information from third party providers, e.g.
information that helps us to combat fraud.
How we’ll use your information
We’ll only use your information where we have your
consent or we have another lawful reason for using it.
These reasons include where we:
• need to pursue our legitimate interests;
• need to process the information to enter into or
carry out an agreement we have with you;
• need to process the information to comply with a
legal obligation;
• believe the use of your information as described is in
the public interest, e.g. for the purpose of
preventing or detecting crime;
• need to establish, exercise or defend our legal rights.
The reasons we use your information include to:
• deliver our products and services;

• carry out your instructions, e.g. to fulfil a payment
request;
• manage our relationship with you, including (unless
you tell us otherwise) telling you about products and
services we think may be relevant for you;
• understand how you use your accounts and services;
• prevent or detect crime including fraud and financial
crime, e.g. financing for terrorism and human
trafficking;
• ensure security and business continuity;
• manage risk;
• provide online banking and other online product
platforms;
• improve our products and services, including
through analysing how you use them;
• protect our legal rights and comply with our legal
obligations;
• correspond with solicitors, surveyors, conveyancers
and third-party intermediaries;
• undertake system or product development and
planning, insurance, audit and administrative
purposes.
Further details of how we’ll use your information can be
found in the Appendix below.
How we make decisions about you
We may use automated systems to help us make
decisions, e.g. when you apply for products and services,
to carry out fraud and money laundering checks. We may
use technology that helps us identify the level of risk
involved in customer or account activity, e.g. for fraud or
financial crime reasons, or to identify if someone else is
using your card without your permission.
You may have a right to certain information about how
we make these decisions. You may also have a right to
request human intervention and to challenge the
decision. More details can be found in the ‘Your rights’
section below.
Tracking or recording what you say or do
To help keep you and your money safe, we may record
details of your interactions with us. We may record and
keep track of conversations you have with us including
phone calls, face-to-face meetings, letters, emails, and
any other kinds of communication. We may use these
recordings to check your instructions to us, assess,
analyse and improve our service, train our people,

manage risk or to prevent and detect fraud and other
crimes. We may also capture additional information
about these interactions, e.g. telephone numbers that
you call us from and information about the devices or
software that you use. Our websites, and other digital
products may track and record your interactions with
them.
Compliance with laws and regulatory
compliance obligations
We’ll use your information to meet our compliance
obligations, to comply with other laws and regulations
and to share with regulators and other authorities that E-
pay is subject to. This may include using it to help detect
or prevent crime (including terrorism financing, money
laundering and other financial crimes). We’ll only do this
on the basis that it’s needed to comply with a legal
obligation, it’s in our legitimate interests and that of
others, or to prevent or detect unlawful acts.
Who we might share your
information with
We may share your information with others where lawful
to do so including where we or they:
• need to in order to provide you with products or
services you’ve requested, e.g. fulfilling a payment
request;
• need to in order to administer your claim;
• have a public or legal duty to do so, e.g. to assist
with detecting and preventing fraud, tax evasion and
financial crime;
• need to in connection with regulatory reporting,
litigation or asserting or defending legal rights and
interests;
• have a legitimate business reason for doing so, e.g.
to manage risk, verify your identity, enable another
company to provide you with services you’ve
requested, or assess your suitability for products and
services;
• have asked you for your permission to share it, and
you’ve agreed.
We may share your information for these purposes with
others including:
• people you make payments to and receive payments
from;

• your beneficiaries, intermediaries, correspondent
and agent banks, clearing houses and clearing or
settlement systems;
• other financial institutions, tax authorities, payment
service providers and debt recovery agents;
• any entity that has an interest in the products or
services that we provide to you, including if they
take on the risk related to them;
• any people or companies where required in
connection with potential or actual corporate
restructuring, merger, acquisition or takeover,
including any transfer or potential transfer of any of
our rights or duties under our agreement with you;
• law enforcement, government, courts, dispute
resolution bodies, our regulators, auditors and any
party appointed or requested by our regulators to
carry out investigations or audits of our activities;
• other parties involved in any disputes, including
disputed transactions;
• fraud prevention agencies who’ll also use it to detect
and prevent fraud and other financial crime and to
verify your identity;
• anyone who provides instructions or operates any of
your accounts on your behalf, e.g. Power of
Attorney, solicitors, intermediaries, etc;
• anybody else that we’ve been instructed to share
your information with by either you, or anybody else
who provides instructions or operates any of your
accounts on your behalf;
• our card processing supplier(s) to carry out fraud
and risk checks, process your payments, issue and
manage your card.
How long we’ll keep your
information
Your personal and business information are stored as
long as it is necessary to duly perform E-pay services to
you and other obligations resulting from the binding
agreements and as long as it is required by the applicable
law.
This enables us to comply with legal and regulatory
requirements or use it where we need to for our
legitimate purposes such as managing your account and
dealing with any disputes or concerns that may arise.
If we don’t need to retain information for any longer, we
may destroy, delete or anonymise it.

Your rights
You have a number of rights in relation to the
information that we hold about you. These rights
include:
• the right to access information we hold about you
and to obtain information about how we process it;
• in some circumstances, the right to withdraw your
consent to our processing of your information, which
you can do at any time. We may continue to process
your information if we have another legitimate
reason for doing so;
• in some circumstances, the right to receive certain
information you have provided to us in an electronic
format and/or request that we transmit it to a third
party;
• the right to request that we rectify your information
if it’s inaccurate or incomplete;
• in some circumstances, the right to request that we
erase your information. We may continue to retain
your information if we’re entitled or required to
retain it;
• the right to object to, and to request that we
restrict, our processing of your information in some
circumstances. Again, there may be situations where
you object to, or ask us to restrict, our processing of
your information but we’re entitled to continue
processing your information and/or to refuse that
request.
You can exercise your rights by contacting us using the
details set out in the ‘More details about your
information’ section below. You also have a right to
complain to the UK Information Commissioner’s Office by
visiting ico.org.uk, or to the data protection regulator in
the country where you live or work.
Fraud and Money Laundering
Fraud Prevention Agencies
We’ll carry out checks with fraud prevention agencies for
the purposes of preventing fraud and money laundering,
and to verify your identity before we provide products
and services to you. These checks require us to process
personal information about you.
The personal information you provide or which we’ve
collected from you, or received from third parties, will be

used to carry out these checks in order to prevent fraud
and money laundering, and to verify your identity.
We’ll process personal information such as your name,
address, date of birth, contact details, financial
information, and device identifiers e.g. IP address.
We and fraud prevention agencies may also enable law
enforcement agencies to access and use your personal
data to detect, investigate and prevent crime.
We process your personal data on the basis that we have
a legitimate interest in preventing fraud and money
laundering and to verify your identity. This enables us to
protect our business and to comply with laws that apply
to us. This processing is also a contractual requirement of
any of our products or services you use.
Fraud prevention agencies can hold your personal data
for different periods of time. If they’re concerned about
a possible fraud or money laundering risk, your data can
be held by them for up to six years.
Consequences of Processing
If we, or a fraud prevention agency, have reason to
believe there’s a fraud or money laundering risk, we may
refuse to provide the services you’ve requested. We may
also stop providing existing products and services to you.
A record of any fraud or money laundering risk will be
retained by the fraud prevention agencies, and may
result in others refusing to provide services to you.
To find out more about our Fraud Prevention Agencies
and how they manage your information, please visit each
agency directly:
World-check One Thomson Reuters;
Comply Advantage.
What we need from you
You’re responsible for making sure the information you
give us is accurate and up to date, and you must tell us if
anything changes as soon as possible. If you provide
information for another, you’ll need to direct them to
this policy.
How we keep your information
secure

We have implemented a wide range of measures in order
to ensure the security and confidentiality of your data.
These include physical, electronic and administrative
safeguards such as firewalls, data encryption, SSL and
other up-to-date technologies.
We enforce physical access controls to our buildings and
files. In addition, only those employees who require
personal information regarding our Customers to fulfill
their employee’s obligations gain access to such
information.
We comply with applicable Payment Card Industry Data
Security Standards (we obtained a PCI certificate) and
endeavor to comply with all such rules at all times.
Pursuant to such rules and regulations we are required to
undergo periodic third-party assessments and periodic
network scans to ensure that, among others, we have
installed and maintain a firewall configuration to protect
data; encrypt transmission of cardholder data and other
sensitive information across public networks; do not use
vendor-supplied defaults for system passwords and other
security parameters; use and regularly update anti-virus
software; develop and maintain secure systems and
applications; restrict access to data to those with a
business need-to-know; track and monitor all access to
network resources and cardholder data; regularly test
our security systems and processes; assign a unique ID to
each person with computer access; restrict physical
access to cardholder data.
It is extremely important that you do not disclose your
account password to anyone. E-pay has designed internal
security processes that encrypt Customer’s password to
protect it from being divulged or accessed by anyone
other than you. Neither E-pay employees nor any of its
contractors can obtain or access your password. Neither
E-pay nor its contractors will ever ask you for your
password via mail, email, telephone or in any other
unsolicited manner. It is your responsibility to keep in
secret your unique password and account information at
all times.
We cannot guarantee the security of your data while it is
being transmitted over the Internet and through servers
that are out of our control. We do our best to protect
your personal information but we cannot ensure or
warrant the security of any information you transmit to
our website or services. Therefore, if you make any data
transmissions over the Internet, you are doing it at your

own risk. Once we receive the data transmission, we
make our best efforts to ensure its security and privacy
on our systems.
More details about your
information
If you have questions or concerns regarding this Privacy
Policy, please do not hesitate to contact us either by
using this link www.monneo.com/contact, an email:
compliance@monneo.com or writing to us at:
E-Pay International LTD., address: 47 Red Lion Street,
London, WC1R 4PF, United Kingdom
This Privacy Policy may be updated from time to time
and the most recent version can be found at
www.monneo.com/privacy-policy.

This policy was last updated in June 2019

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