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Privacy Policy

 

1. Introduction

At Clarico Pay Ltd, protecting your personal information is of paramount importance. This Privacy Policy explains how we handle your personal data when you use our transfer services. It outlines what data we collect, how we use it, and your rights regarding your information. We are committed to complying with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

 

2. Who We Are

Clarico Pay Ltd, is a payment services provider incorporated in the United Kingdom. We are registered under registration number 07263512 and are authorised and regulated by the Financial Conduct Authority (FCA) with registration 527149. 

 

3. Information We Collect and How We Use It

When you interact with At Clarico Pay Ltd  we collect and process various types of information to provide you with a secure and efficient service, comply with legal obligations, and enhance your overall experience. The types of information we collect include:

 

What Information We Collect:

  • Personal identification information, including your name, contact details (such as phone number and email address), date of birth, and government-issued identification..
  • Details of the payment cards you use to make transfers, including card numbers, expiration dates, and security codes.
  • Details about the card-to-card transfers you initiate, such as transaction amounts, dates, frequencies, and recipient card details. 
  • Information about the device you use to access our services, including IP address, browser type, and operating system. 

– We use cookies and similar tracking technologies, such as web beacons, to collect information about your interaction with our website and services. For detailed information on our use of cookies and how you can manage your preferences, please refer to our Cookies Policy.

– In certain cases, we may request and collect images of your identification documents, such as your ID card or passport, utility bills, or other documents necessary for verification purposes

– We may collect information about your employment status and occupation when it is relevant for verifying your identity or assessing the risk profile associated with your transactions.

– If you contact us, either proactively or in response to a request from us, we may collect and retain the content of the communication, as well as any metadata associated with it. This can include details such as the date and time of your communication, the method used (e.g., email, chat, phone), and any information provided within the communication.

– When you participate in our surveys, contests, or promotions, we may collect additional information that you provide. This may include responses to survey questions, details related to contest entries, and any other information relevant to your participation in these activities.

 

  • As part of our commitment to regulatory compliance, we may collect additional information for identity verification and Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) purposes. This may include additional documentation or information required to meet our legal obligations.

 

How We Use Your Information:

Your personal data is used for the following purposes:

  • We use your information to facilitate and manage card-to-card transfers, ensuring transactions are processed accurately and securely. This includes verifying card details, authorising payments, and delivering funds to the recipient’s card.
  • To comply with legal and regulatory requirements, including AML and CTF regulations, we use your personal information to verify your identity. This may involve using third-party services for identity verification, conducting checks against sanctions lists, and assessing transaction risk to prevent fraudulent or illegal activities.
  • We monitor transactions to detect and prevent fraud, money laundering, and other suspicious activities. This involves analysing transaction patterns, identifying unusual or high-risk behaviour, and taking necessary actions, such as flagging transactions for further review or contacting you for verification.
  • Your information helps us improve our services and provide a more personalised experience. We use usage data and feedback to optimise our platform, enhance security measures, and introduce new features that meet your needs.
  • We use your contact information to communicate with you about your account, transactions, and any changes to our services. This includes sending transaction confirmations, alerts, and customer support responses. We may also use this data to notify you about updates to our policies or services.
  • We may use and share your information as required to comply with legal obligations, including reporting suspicious activities to regulatory authorities.
  • We may may use aggregated and anonymised data for internal analysis and research purposes. This helps us understand transaction trends, improve our service offerings, and develop strategies for risk management and compliance.

 

Retention of Your Information:

We retain your personal data only as long as necessary to fulfill the purposes for which it was collected, including meeting our legal, regulatory, and reporting obligations. Typically, we retain transaction records and related information for seven years to comply with relevant requirements. After this period, we securely delete or anonymise the data in accordance with our data retention policy.





4. Legal Basis for Processing Your Data

We process your personal data in accordance with UK data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Our processing activities are based on the following legal grounds:

  • Processing your personal information is necessary for the performance of the contract we have with you. 
  • We are required by law to collect and process certain data to comply with regulatory requirements, including Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations. This includes verifying your identity, conducting due diligence, and monitoring transactions to detect and prevent illicit activities.
  • We may process your data to further our legitimate interests, provided that your rights and interests do not override these. Our legitimate interests include improving and personalising our services, enhancing the security of our platform, preventing fraud, and protecting the integrity of our financial services. In all cases, we ensure that our legitimate interests are balanced against your privacy rights.




5. Sharing Your Information

We share your information only when necessary:

  • To comply with legal and regulatory obligations, including reporting suspicious activities.
  • We use third-party providers for identity verification, payment processing, and other services. These providers are contractually bound to handle your data securely and only for the purposes specified by us.
  • In the event of legal, audit, or compliance requirements, we may share your data with our legal and professional advisors.

 

6. International Data Transfers

While we primarily process and store your data within the UK, there may be occasions where data needs to be transferred outside the UK. In such cases, we ensure that appropriate safeguards, such as standard contractual clauses, are in place to protect your data.

 

7. Data Security

Clarico Pay Ltd, implements security measures to protect your personal data from unauthorized access, disclosure, or destruction. These measures include encryption, secure data storage, and access controls. We regularly review and update our security practices to ensure the highest level of data protection.

 

8. Data Retention

We retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including complying with legal and regulatory obligations. Typically, we retain your data for seven years from the date of your last transaction. After this period, we securely delete or anonymize your data.

 

9. Your Rights

You have several rights regarding your personal information, including:

  • You can request access to the personal data we hold about you.
  • You can request corrections to any inaccurate or incomplete data.
  • You have the right to request that we delete your personal information, subject to our compliance with legal obligations.
  • You can ask us to restrict the processing of your data under certain conditions.
  • You can request a copy of your data in a structured, commonly used format.
  • You have the right to object to the processing of your data under specific circumstances.

To exercise these rights, please contact us using the information provided in the “Contact Us” section.

 

10. Changes to This Privacy Policy

We may revise this Privacy Policy from time to time to reflect changes in our practices or regulatory requirements. Any updates will be posted on this page, and where appropriate, we will notify you by email or through our services.

 

11. Complaints

If you are not satisfied with our handling of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection issues. More information can be found on their website at www.ico.org.uk.