WorldRemit Recipient Privacy Policy
Introduction
At WorldRemit, we are committed to protecting and respecting your privacy, handling your information in an open and transparent manner, and keeping your information secure.
This Privacy Policy ("Policy") explains among other things: what we do with your personal information; what we do to keep it secure; with whom we share your information; your rights in relation to the personal information we hold about you; and who you can contact for more information.
Who we are?
This Mobile App is operated and provided by WorldRemit Ltd ("WorldRemit", "we", "us", "our") having its registered office at 51 Eastcheap, London EC3M 1 DT
United Kingdom. If you reside in a country where we provide our services and are a user of our Mobile Application (“our Mobile Application ("Mobile App")”), we are the responsible authority for the collection, processing and use of your personal information. In this Policy, references to "You" and "Your" are references to a user of our Mobile Application ("Mobile App") and/or of our Mobile Apps.
Definitions
To help clarify our meaning, we have used certain capitalised terms in this Policy. These terms and their meaning are:
“Applicable Laws” means all laws relating or applicable to data protection and privacy in your country of residence. “Supervisory Authority” means where applicable the statutory or regulatory authority established in Your country that is given the responsibility for investigating, regulating and dealing with matters relating to the use of personal information. “Marketing” means any action or advertisement or promotion or marketing material like surveys, vouchers, research and events. This list is not exhaustive. “Sender” means the individual who is the WorldRemit customer that transfers money to you based on your request or at your initiative". “Services” means WorldRemit Money Transfer Service; WorldRemit Digital Money Account; Airtime Top Up; and such other services or products that we may introduce from time to time.
The personal information we collect about you
We may collect, record and use information about You in physical and electronic form and will hold and use this information as set out in this Policy.
The personal information we collect and use may include, amongst other things:
● Your name;
Evidence of your identity (for example passport information);
● Your contact information such as Your email address, postal address and telephone number or any telephone number used to call us;
Unique identifiers such as username and password;
Details of the Sender of your money transfer;
Any requests from You to the Sender for funds or money to be transferred to You, including the purpose(s) and reason(s) for your fund request to the Sender;
Your payment details and other financial data (for example, Your bank or payment method provider’s name and Your account number and sort code); and
● information about Your session in our Mobile app.
We also collect from You information in relation to other people (for example, details of the sender of Your money transfers), where You provide us with such information. In providing this information you confirm to us that you have obtained all necessary permissions from them to the reasonable use of their information for the purposes and in the manner described in this Policy, or are otherwise permitted to give us this information on their behalf. Please also ensure that those other people are aware of this notice and that the provisions of this notice are clearly communicated to them.
How we collect your personal information
Information You give to us when You download and use our Mobile App or use our Services to receive money from the Sender. If You use our services You will need to provide certain information including Your name, address and bank account number , as well as the name and other details of the sender of the money transfers that you are receiving or instructing us to carry out. This information must be complete and accurate, and if not we may have to take additional steps to complete the transaction.
Other information You give to us. This is information about You that You give us by filling in forms on our Mobile app (for example, the ‘contact us’ section) or when you communicate with us by phone, e-mail or otherwise. It includes, for example, information You provide when You register on the Mobile Application for us to contact You, when You inquire about any of our Services, when You sign up to receive notifications, and when You report a problem with our mobile application . The information You give us may include, among other data, Your name and email address.
Social Media. Depending on Your settings or the privacy policies for social media and messaging services such as Facebook, LinkedIn and Instagram, You might give us permission to access information from those accounts or services.
Other Sources. We may receive information about You from other sources, including publicly available databases and combine this data with information we already have about You. This helps us to update, expand and analyse our records and provide services that may be of interest to You.
Information we collect about Youwhen you download our Mobile App:
○ We use In-App "cookies" to help us make our mobile application – and the way You use it is a good experience. In-App Cookies mean that our Mobile App will remember You. They are small text files that transfer to Your device . They improve Mobile App use and speed – for example by automatically filling Your name and address in text fields. Please see our Cookies Policy for further information.
○ We also automatically collect information on the type of device You use, operating system version, and system and performance information. With your consent, we may send You push notifications from time-to-time in order to update You about 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;
○ If enabled, we may 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 with this service. Your geo-location data may be shared with third parties. You may opt-out of location-based services at any time by editing the setting at the device level or by emailing us at dataprivacy@zepz.io; and
○ may use mobile analytics software to allow us to better understand the functionality of our Mobile Software on Your device. This software may record information such as how often You use the Mobile App, the events that occur within it, aggregated usage, performance data, and where the Mobile App was downloaded from. We do not link the information we store within the analytics software to any personal information You submit within the Mobile App.
How we use your personal information
Our primary purpose in collecting user information is to provide You with a safe, smooth, efficient, and customised experience and to provide the services Your Sender has requested from us. We may also use the information that You have provided to ensure that the content on our mobile application is presented in the most effective manner for You and Your device.
We use Your information for the following specific purposes:
● to carry out our obligations arising from any money transfer transaction between Your Sender and You or from applicable law, and to provide You with the Services in accordance with the terms of use of our Mobile App and with this Policy;
● to ask for your consent to process your personal information for a specific purpose that we communicate with you. When you consent to our processing of your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your information for that purpose;
● to send You confirmations or other notifications;
● to notify You about temporary or permanent changes to our services or other service-related messages;
● to prevent fraud, money laundering, and any other illegal activity in order to protect the security of our customers, WorldRemit Group, and others;
● to fulfill any legal obligation to collect, process and share your information;
● to ensure that content from our Mobile App is presented in the most effective manner for You and for Your device;
● to promote our business;
● to administer our Mobile App and for internal operations, including troubleshooting, data analysis, profiling and segmentation analysis, testing, research, statistical and survey purposes;
● as part of our efforts to keep our Mobile App and our services safe and secure;
● to measure or understand the effectiveness of advertising we may serve to You and others, and to deliver relevant advertising to You in accordance with Applicable Laws;
● to make suggestions and recommendations to You about services that may interest You in accordance with Applicable Laws;
● to train, monitor and assess the effectiveness of the manner in which we provide the Services to You;
● to consider and investigate any concerns or complaints you may have please contact us at dataprivacy@zepz.io.
Lawful Processing
Our legal reasons and the bases of Our use of Your personal information are:
● You have given us your consent;
● It is required to comply with our legal obligations; and
It is in our legitimate interests to do so, provided your rights do not override those interests.
Direct Marketing
Where permitted by Applicable Laws, we may use the contact details You provided to send you in app marketing communications or other communication formats about similar products or services in other cases, we may ask for Your consent to send You marketing communications about products or services offered by us, Sendwave or other companies within the WorldRemit Group.
We might share your personal information with
Your personal information is very important to us. However there are circumstances where it is necessary for us to share your information for legitimate business or legal purposes (including operating our Mobile App, and providing services to you). In addition, we may disclose your personal information to:
● Our affiliates - we share your information with our affiliates and other companies within the WorldRemit group of companies.
● Third party processors which include people with whom we do business or who provides services to us. If we engage a third party processor to process your information, the Processor will be subject to binding contractual obligations to: only use the personal information in accordance with our prior written instructions; and use measures to protect the confidentiality and security of the personal information, together with any additional requirements. We may disclose data to provide our services, to respond to legal requirements, enforce our policies, liaise with judicial or regulatory authorities where required under applicable law, and protect our rights and property.
● Fraud Prevention Agencies - Where we have a good reason to suspect fraud, money laundering, counter terrorist financing or any other illegal activity, we can upon request or where legally obliged share your personal information with crime prevention agencies and other third parties for the purpose of detecting, preventing or reporting crime or for actual or suspected breach of any applicable law or regulation. These third parties may include business partners and companies that provide services to us, law enforcement bodies, regulatory and supervisory authorities, providers of fraud prevention and detection services. Please note, we may suspend activity on your account or any transaction, refuse access to your account or cancel any transaction you may want to make, if we think there is a risk of any illegal activity.
● Public Agencies - We release accounts or other personal information when we consider it appropriate to comply with the law, to enforce our Terms and Conditions and any other agreement to protect the rights, property, or safety of WorldRemit, our employees, customers, our business partners and the public. In these circumstances, we will only provide them with the information they require to perform their function.
● Research companies - We may share personal information in a secure way to allow research companies and feedback providers to contact you directly on our behalf to get your opinions on or refuse to take part in the research or surveys.
Please check these policies before You submit any data to these websites.
Transfer and storing of your personal information
Due to the international nature of our business, we may need to transfer your personal information to other WorldRemit entities, to other third parties as noted in the “Who we might share your information with” section of this policy. For this reason, we may transfer your personal information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. By submitting your personal information, you agree to this transfer, storing and processing.
We will take all reasonably necessary steps to ensure your information is treated securely. We also ensure we have standard contractual clauses or binding corporate rules in place with third parties when we share information outside the European Economic Area.
How we keep your personal information secure
We have implemented appropriate technical and organisational security measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with Applicable law.
How long will we keep your personal information for
We will only keep the information we collect about You for as long as required for the purposes set out above, or as required to comply with any legal or regulatory obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.
The period for which we will retain information about You will vary depending on the type of information and the purposes that we use it for. Generally, unless applicable law or our legal and regulatory obligations require a longer retention period, we will keep your personal information within this Mobile App for no longer than 2 years after the last money transfer transaction you receive from a Sender.
Your Rights
Subject to Applicable Laws, you may have a number of rights regarding our processing of your relevant personal information, including:
● the right not to provide your personal information to us (however, please note that we may be unable to provide you with the full benefit of our Mobile App, or our services, if you do not provide us with your personal information);
● the right to request access to your personal information, together with information regarding the nature, Processing and disclosure of those personal information;
● the right to request for the correction of any inaccuracies in your personal information;
● the right to request for the erasure of your personal information. This is also known as the right to be forgotten. We will keep a note of your name if you ask for your personal information to be erased;
● the right that we restrict our use of your personal information;
● the right to have certain personal information transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
● where we use your personal information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of your personal information in reliance upon any other available legal basis); and
● the right to lodge complaints with a Supervisory Authority regarding the use of your personal information by us or on our behalf. If you wish to make a complaint, please contact us and we will provide you with the details of the Supervisory Authority in your country of residence.
We may require proof of your identity before we can give effect to these rights. You should also be aware that some of these rights are qualified and not absolute; therefore exemptions or limitations may apply. For example, we can refuse to provide information if fulfilling your request would reveal the personal information about another person, or if you request that we delete information which we are required to retain by law, have compelling legitimate interests to keep, or need access to fulfill our legal obligations.
You can contact us at dataprivacy@zepz.io if you want to enforce any of these rights. We will comply with our legal obligations as regards Your rights as a data subject.
The quickest and easiest way to make a data subject request is to contact us directly to exercise your rights by emailing dataprivacy@zepz.io. We will endeavor to respond within a reasonable period and in any event within one month (three months for complex or numerous requests), in compliance with Data Protection Legislation.
Automated decision making and profiling
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, except if: (i) the automated decision-making is required or authorised by law; (ii) is necessary for entering into or performing the contract; or (iii) is based on your individual explicit written consent.
Cookies and similar technologies
When you use our Mobile App we may place In-App Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with Applicable Laws. We use Cookies to record information about your device, and, in some cases, your preferences and browsing habits. We may use your personal information through Cookies and similar technologies, in accordance with our Cookie Policy.
Changes to our privacy policy
We will amend or revise this Policy regularly and at any time without notice to reflect changes in our processing of personal information, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make to the terms of this Policy.
Contact us
Questions, comments and requests regarding your personal information and our Policy are welcome and should be sent to dataprivacy@zepz.io or you can send it by post addressed to the:
Data Protection Officer:
WorldRemit Ltd
51 Eastcheap, London EC3M 1 DT
United Kingdom
You may also use these contact details if You wish to make a complaint to us relating to Your privacy.
If You have any concerns about our use of Your information, You also have the right to make a complaint to your Data Protection Authority. Please contact us on dataprivacy@zepz.io to request for details of the Data Protection Authority for your country.