Privacy Policy

Your privacy is very important to us. This notice (“Privacy Notice”) is provided by BeAccount Limited, a company incorporated in England and Wales (company number: 12600349) with its head office at “One Canada Square, Canary Wharf, London, England, E14 5AB” (hereinafter referred to in this Agreement as “BeAccount”, “the Firm”). The Firm is an Electronic Money Institution (“EMI”) and are authorised by the Financial Conduct Authority under the Electronic Money Regulations 2011 (“EMR 2011”) (register reference: 937539) for the issuing of electronic money (“we” or “us”) and sets out our policies with respect to the collection, sharing and use of personal information.

CONTROLLER

 BeAccount is the controller and responsible for your personal data.

CONTACT DETAILS

 In case You have any questions regarding Your data processing by BeAccount, please kindly contact our Data Protection Officer at: privacy@staging.payine.com

 

How we collect information about you

 We may collect personal data about you through:

  • information provided directly to us by you, or another person on your behalf, through our website, by email or post, or in person;
  • information that we obtain in relation to any transactions between you and us;
  • recording and monitoring of telephone conversations and electronic communications with you as described below; or
  • the use of Internet “cookies” (an information collecting device from a web server), as described further below.

We may also, in some circumstances, receive personal information about you from third parties, such as service providers or trading counterparties, regulatory or law enforcement agencies, credit reference agencies and agencies conducting background checks. Personal information may also be obtained from publicly accessible sources of information, such as public databases, industry associations, social media, and online professional networks.

 

Why we collect information about you

 We may collect and use your personal information for the purposes of administering the relationship between us, marketing our products and services to you or the businesses with which you are associated, monitoring, and analysing our activities, and complying with applicable legal or regulatory requirements.

We will use one of the permitted grounds under the applicable law to process your information. Such grounds include instances where you have given your consent and cases where your consent is not required under applicable law, such as where we are required to comply with a legal obligation, or where we or a third party determine that is necessary for our legitimate interests to collect and use your personal information.

The legitimate interests to collect your personal information may include any of the purposes identified above and any other purpose where we or a third party have determined that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose. You have the right to object to the use of your personal data for direct marketing purposes.

 

Change of Purpose

 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, only where this is required or permitted by law.

 

What are the consequences of failing to provide your personal information?

As a regulated financial services firm, we are subject to legal and regulatory obligations that may require us to collect and store your personal information, such as the requirements to comply with the applicable law on the prevention of financial crime, tax and regulatory reporting, or the rules on recording and monitoring of communications (as described below).

We may also need to collect and use your personal information for the purposes of entering into or performance of a contractual arrangement between us.

A refusal to provide us with personal information may, depending on the purpose for which your personal information is required, have various consequences such as us being unable to communicate with you, the termination of any service or other contractual arrangement between us, or, where we have a reasonable suspicion of illegal activity, we may be required to make a report to regulatory or enforcement agencies.

 

Promotional offers from us

 You will receive marketing communications from us by post, email or phone (including text messages) with offers and promotions if you sign up to our services and, in each case, you have not opted out of receiving that marketing.

We may use the information we have collected about you in order to tailor our offers and promotions to you.

 

Third-party marketing

 We will not share your personal data with any company or organization outside the BeAccount group of companies for their marketing purposes without your permission.

 

Opting out

You can ask us or third parties to stop sending you marketing messages at any time [by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or] by Contacting us at any time].

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of [a product/service purchase, warranty registration, product/service experience or other transactions].

 

The types of personal data we may collect and use

The categories of personal data we may collect will depend on the nature of our relationship with you and the purpose of which information is being collected. Such personal data may include names, residential addresses or other contact details, signature, nationality, date and place of birth, national insurance or other tax identification number, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, criminal and administrative offences, authentication data, transaction data, usage data, marketing and communications data, source of funds details, or other sensitive information, such as certain special categories of personal data contained in relevant documents or materials (including, in some circumstances, information about a person’s ethnic origin, religious beliefs, or health).

 

Do we use automated decision-making processes?

 No

 

Do we share your personal information with third parties?

 We may (to the extent relevant to the purpose for which we collect your information), share your personal data with third parties, such as:

  • our affiliates or other entities that are part of our group or with our clients;
  • any person to whom we have a right or obligation to disclose personal data, or where we determine that disclosure is necessary to protect or defend our rights or property, including with regulators, courts of law, governmental, regulatory or law enforcement agencies;
  • our internet, IT, telecommunications and other service providers, including legal advisers, accountants, payroll administrators, insurance and employee benefits providers and administrators;
  • service providers and trading counterparties to our clients, including placement agents or distributors, brokers, banks, trading venues, clearing houses, custodians, corporate services providers, administrators of our funds, and providers of customer relationship management tools;
  • credit reference agencies and other third parties conducting background checks in the context of employment or client, counterparty, or investment due diligence;
  • any person, as directed by you; or
  • any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or

Transfers of personal information to countries outside of the European Economic Area (EEA)

Due to the international nature of our business, your personal data may be transferred to countries outside of the EEA, such as to jurisdictions where we or our clients conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the EU General Data Protection Regulation or other data protection rules applicable to us (collectively, “Data Protection Law”). In these circumstances, we take steps to ensure that the recipient agrees to keep your information confidential and that it is held securely in accordance with the requirements of Data Protection Law, such as by requesting appropriate contractual undertakings in our legal agreements with service providers.

 

For how long do we keep your personal information?

 We will generally keep personal information about you for as long as necessary in relation to the purpose for which it was collected, or for such longer period if required under applicable law or necessary for the purposes of our other legitimate interests.

The applicable retention period will depend on various factors, such as any legal obligation to which we or our service providers are subject as well as on whether you decide to exercise your right to request the deletion of your information from our systems. As a minimum, information about you will be retained for the entire duration of any business relationship we may have with you, and for a minimum period of five years after the termination of any such relationship.

We will, from time to time, review the purpose for which we have collected information about you and decide whether to retain it, update it, or securely delete it, if the information is no longer required.

 

What are your rights?

 You have certain rights under Data Protection Law in respect of the personal data we hold about you and which you may exercise. These rights are:

  • to request access to your information;
  • to request rectification of inaccurate or incomplete information;
  • to request erasure of your information (a “right to be forgotten”);
  • to restrict the processing of your information in certain circumstances;
  • to object to our use of your information, such as where we have considered such use to be necessary for our legitimate interests (e.g. in the case of direct marketing activities);
  • where relevant, to request the portability of your information;
  • where you have given consent to the processing of your data, to withdraw your consent; and
  • to lodge a complaint with the competent supervisory

 

How to contact us

 If you have any questions about this Privacy Notice or requests with regards to the personal data we hold about you, you may contact us at: support@ayine.com

 

Complaining to ICO

 You have the right to complain to the Information Commissioner’s Office (ICO). Further information is available from the ICO’s website.

 

Use of cookies

 We may send text files (e.g., “cookies” or other cached files) or images to your web browser to store information on your computer. Such text files and images are used for technical convenience to store information on your computer. For instance, we may use a session cookie to store form information that you have entered so that you do not have to enter such information again. We may use information stored in such text files and images to customise your experience on this website and to monitor use of this website. You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. If you block cookies, you may not be able to access certain parts of this website. You can disable cookies from your computer system by following the instructions on your browser or at

 

Recording and monitoring of communications

 We may record and monitor telephone conversations and electronic communications with you for the purposes of:

  • ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances;
  • ensuring compliance with our regulatory obligations; or
  • detecting and preventing the commission of financial

Copies of recordings will be stored for a period of five years, or such other longer period as we may determine from time to time.

 

Changes to the privacy and cookies policy and your duty to inform us of changes

 The Company reserves the right to change this Policy from time to time with immediate effect and we will post an appropriate notification. In such a case, we make the most recent version of this Policy available on our website www.payine.com, informing you accordingly by displaying the update version and the relevant date of update.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

How we collect information about you

 We may collect personal data about you through:

  • information provided directly to us by you, or another person on your behalf, through our website, by email or post, or in person;
  • information that we obtain in relation to any transactions between you and us;
  • recording and monitoring of telephone conversations and electronic communications with you as described below; or
  • the use of Internet “cookies” (an information collecting device from a web server), as described further below.

We may also, in some circumstances, receive personal information about you from third parties, such as service providers or trading counterparties, regulatory or law enforcement agencies, credit reference agencies and agencies conducting background checks. Personal information may also be obtained from publicly accessible sources of information, such as public databases, industry associations, social media, and online professional networks.

 

Why we collect information about you

 We may collect and use your personal information for the purposes of administering the relationship between us, marketing our products and services to you or the businesses with which you are associated, monitoring, and analysing our activities, and complying with applicable legal or regulatory requirements.

We will use one of the permitted grounds under the applicable law to process your information. Such grounds include instances where you have given your consent and cases where your consent is not required under applicable law, such as where we are required to comply with a legal obligation, or where we or a third party determine that is necessary for our legitimate interests to collect and use your personal information.

The legitimate interests to collect your personal information may include any of the purposes identified above and any other purpose where we or a third party have determined that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose. You have the right to object to the use of your personal data for direct marketing purposes.

 

What are the consequences of failing to provide your personal information?

As a regulated financial services firm, we are subject to legal and regulatory obligations that may require us to collect and store your personal information, such as the requirements to comply with the applicable law on prevention of financial crime, tax and regulatory reporting, or the rules on recording and monitoring of communications (as described below).

We may also need to collect and use your personal information for the purposes of entering into or performance of a contractual arrangement between us.

A refusal to provide us with personal information may, depending on the purpose for which your personal information is required, have various consequences such as us being unable to communicate with you, the termination of any service or other contractual arrangement between us, or, where we have a reasonable suspicion of illegal activity, we may be required to make a report to regulatory or enforcement agencies.

 

The types of personal data we may collect and use

 The categories of personal data we may collect will depend on the nature of our relationship with you and the purpose of which information is being collected. Such personal data may include names, residential addresses or other contact details, signature, nationality, date and place of birth, national insurance or other tax identification number, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, criminal and administrative offences, source of funds details, or other sensitive information, such as certain special categories of personal data contained in relevant documents or materials (including, in some circumstances, information about a person’s ethnic origin, religious beliefs, or health).

 

Do we use automated decision-making processes?

No

 

Do we share your personal information with third parties?

 We may (to the extent relevant to the purpose for which we collect your information), share your personal data with third parties, such as:

  • our affiliates or other entities that are part of our group or with our clients;
  • any person to whom we have a right or obligation to disclose personal data, or where we determine that disclosure is necessary to protect or defend our rights or property, including with regulators, courts of law, governmental, regulatory or law enforcement agencies;
  • our internet, IT, telecommunications and other service providers, including legal advisers, accountants, payroll administrators, insurance and employee benefits providers and administrators;
  • service providers and trading counterparties to our clients, including placement agents or distributors, brokers, banks, trading venues, clearing houses, custodians, corporate services providers, administrators of our funds, and providers of customer relationship management tools;
  • credit reference agencies and other third parties conducting background checks in the context of employment or client, counterparty, or investment due diligence;
  • any person, as directed by you; or
  • any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or

 

Transfers of personal information to countries outside of the European Economic Area (EEA)

 Due to the international nature of our business, your personal data may be transferred to countries outside of the EEA, such as to jurisdictions where we or our clients conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the EU General Data Protection Regulation or other data protection rules applicable to us (collectively, “Data Protection Law”). In these circumstances, we take steps to ensure that the recipient agrees to keep your information confidential and that it is held securely in accordance with the requirements of Data Protection Law, such as by requesting appropriate contractual undertakings in our legal agreements with service providers.

 

For how long do we keep your personal information?

We will generally keep personal information about you for as long as necessary in relation to the purpose for which it was collected, or for such longer period if required under applicable law or necessary for the purposes of our other legitimate interests.

The applicable retention period will depend on various factors, such as any legal obligation to which we or our service providers are subject as well as on whether you decide to exercise your right to request the deletion of your information from our systems. As a minimum, information about you will be retained for the entire duration of any business relationship we may have with you, and for a minimum period of five years after the termination of any such relationship.

We will, from time to time, review the purpose for which we have collected information about you and decide whether to retain it, update it, or securely delete it, if the information is no longer required.

 

What are your rights?

 You have certain rights under Data Protection Law in respect of the personal data we hold about you and which you may exercise. These rights are:

  • to request access to your information;
  • to request rectification of inaccurate or incomplete information;
  • to request erasure of your information (a “right to be forgotten”);
  • to restrict the processing of your information in certain circumstances;
  • to object to our use of your information, such as where we have considered such use to be necessary for our legitimate interests (e.g. in the case of direct marketing activities);
  • where relevant, to request the portability of your information;
  • where you have given consent to the processing of your data, to withdraw your consent; and
  • to lodge a complaint with the competent supervisory

 

How to contact us

 If you have any questions about this Privacy Notice or requests with regards to the personal data we hold about you, you may contact our Compliance Officer at BeAccount Ltd at “105 Sumatra Road, Office 6 NW6 1PL United Kingdom

 

Complaining to ICO

 You have the right to complain to the Information Commissioner’s Office (ICO). Further information is available from the ICO’s website.

 

Use of cookies

We may send text files (e.g., “cookies” or other cached files) or images to your web browser to store information on your computer. Such text files and images are used for technical convenience to store information on your computer. For instance, we may use a session cookie to store form information that you have entered so that you do not have to enter such information again. We may use information stored in such text files and images to customise your experience on this website and to monitor use of this website. You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. If you block cookies, you may not be able to access certain parts of this website. You can disable cookies from your computer system by following the instructions on your browser or at www.allaboutcookies.org.

 

Recording and monitoring of communications

 We may record and monitor telephone conversations and electronic communications with you for the purposes of:

  • ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances;
  • ensuring compliance with our regulatory obligations; or
  • detecting and preventing the commission of financial

Copies of recordings will be stored for a period of five years, or such other longer period as we may determine from time to time.

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