Privacy Policy

Our Privacy Policy

Before we begin

This policy (Privacy Policy) applies to personal information held by Monneo 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 Monneo Limited that allows to view transaction data from the Customer’s merchant account.

When we say ‘we’, we mean Monneo 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 Monneo Limited, registered in the United Kingdom with registration number: #10086951. Monneo LTD is an Authorised Payment Institution by the Financial Conduct Authority (FCA) of the United Kingdom, number 802210. Monneo Limited listed as a Visa Merchant Agent operating a PCI DSS Level 1 Certified Payment Gateway. Monneo Limited is VAT registered, VAT Number: GB310234074.

You need to accept all the provisions in this Policy when you sign up for the Monneo 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.:

 

Information we collect or generate about you, e.g.:

 

Information we collect from other sources, e.g.:

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:

 

The reasons we use your information include to:

 

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 Monneo 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:

 

We may share your information for these purposes with others including:

How long we will keep your information

Your personal and business information are stored as long as it is necessary to duly perform Monneo 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:

 

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. Monneo has designed internal security processes that encrypt Customer’s password to protect it from being divulged or accessed by anyone other than you. Neither Monneo employees nor any of its contractors can obtain or access your password. Neither Monneo 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: [email protected] or writing to us at:

Monneo 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 February 2021

 

Appendix – How we process your information

Monneo uses the information received from you or otherwise collected only in the scope that is necessary to operate, maintain, improve and provide Monneo products and services and all of the functions available on our websites and to allow us to duly perform our obligations resulting from binding agreements, in particular those regarding assisting in executing payment transactions. We also analyze all of the said information to determine the trends and preferences of our Customers, improve our websites and services, inclusive of creating new features and functionality.

We’ll use your information for purposes including: