Privacy Policy

This document sets out rules on which Easysend collects, analyses and process personal data of its users accordingly to EU General Data Protection Regulation 2016/679, together with all other applicable legislation relating to data and/ or privacy protection.

Effective from: 25-05-2018

 

Data controller

Easysend Limited, being an owner of websites: www.easysend.plwww.easysend.eu and www.przelewydopolski.co.uk is responsible for processing and managing its customer personal data. Therefore the registered data controller is Easysend Limited, 5B Edgewater Business Park, Belfast, BT3 9JQ, registration number: Z2973216.

Type of personal data we collect and process

The information we collect and process about you include (among others):

  • Identification information – name, date of birth, photo, address, email, telephone number, nationality. Some of this information might be disclosed when logging on via social media profile.

  • Identification information in a form of document – photocopies or scans of government identifiers (e.g. your ID, passport, driving licence etc.), documents confirming your address (utility bills, bank statements etc.).

  • Login credentials – to our service.

  • Information about transactions you make: your transaction history - transaction dates, types and amounts, payment methods, beneficiaries’ details, purpose of your transfers, any reference you may add to your transfer.

  • Financial information – bank account details, debit card details (tokenized), source of funds information.

  • Other information, e.g. recorded phone calls, history of correspondence with you, your opinion on our service etc.

  • Social media information – when you choose to use your social media profile in registration process or when you share your post with us etc.

  • Technical data regarding your visit on our website, including: log history (IP address, User Agent data, date stamp), page interaction information, incoming source, e.g. referrals.

We also collect and process information on other people provided by you. These are e.g. your beneficiaries details and/ or the list of people (their emails) who you want to recommend our services to, when you participate in our referral programme. By providing these information to us you confirm that you have obtained necessary permission to share such data with us.

How we collect personal and other data?

Easysend collects personal data depending on the type of service used.

You give us information when you:

  • register to use our service (online or at our agent location),

  • fill out our money transfer form (online or at our agent location),

  • are updating your profile online,

  • contact us (send emails to us, call our call centre, use our chat facility or contact form on our website) or when Easysend contacts you.

We obtain information from other sources:

  • from publicly available databases, from third-party reference sources, as a result of identity verification processes,

  • from cookies – when you browse our website,

  • from social media widgets – installed on our website,

  • in a form of log details – when you log in to our service.

The purpose of data processing

We use Personal Data in order to conduct our day-to-day business activity including:

  • providing money remittance services and all activities related to that process,

  • communicating with you,

  • administering, improving and personalizing our service,

  • complying with the legal obligations by Easysend, e.g. processing identity checks,

  • anti-fraud detection and prevention,

  • performing all kind of research, analysis and statistics,

  • direct marketing,

  • sending newsletter.

Legal basis for data processing
  • agreement on the provision of services (indicated as the basis in Article 6 (1) (b) of the GDPR);

  • legal obligation imposed on Easysend (indicated as the basis in Article 6 (1) (c) of the GDPR);

  • your consent (indicated as the basis in Article 6 (1) (a) of the GDPR);

  • our legitimate interests (indicated as the basis in Article 6 (1) (f) of the GDPR), which are: 

    • fraud detection and prevention,

    • direct marketing (excluding newsletter),

    • pursuing of claims,

    • running secure service online,

    • business performance reporting,

    • troubleshooting,

    • improving our online service so it better fits our customer expectations,

    • preparing and sending essential communication,

    • to receive your feedback on our service.

Data sharing

We might share your personal data with third parties for the following purposes:

  • To enforce contract with you – to provide you with service you required or to protect the rights, property or safety of Easysend or the service we provide,

  • To comply with the legal obligations,

  • In the case of sale of business or its part,

  • For the purpose of processing transaction that is conducted by third party service providers,

  • For the purpose of ongoing investigation or on request of the relevant law enforcement agencies. We might also report any activity we find suspected to law enforcement agencies and exchange information with other firms or relevant agencies in order to prevent our service from illegal activity being conducted while in use,

  • When we cooperate with service providers who carry out business support functions for us, e.g. technical support, call centre support, marketing, administrative support etc.- only to extent that it is necessary to provide such service.

Based on above purposes, we are currently using the following categories of data processors:

  • agents,

  • contractors and third party entities who provide ongoing services on our behalf, such as customer services support, IT support processes, sales and marketing processes,

  • hosting service provider,

  • troubleshooting tool service providers,

  • identity verification tool service providers (more information can be found here: https://www.transunion.co.uk/legal-information/bureau-privacy-notice),

  • law enforcement agencies,

  • card payment processing service providers,

  • communication tools service providers,

  • online services optimisation tools service providers,

  • banks and other payment services providers – for the purpose of executing your remittance transactions – when we receive a payment from you as well as when we send or make available your funds to the recipient,

  • project management tools service providers,

  • newsletter tool service provider,

  • social media service providers,

  • legal and regulatory advisors.

Marketing/ Behavioural Targeting/ Re-targeting

We are using third party service providers for remarketing purposes, that is for displaying our advertising on their and their affiliates websites. They use different kind of technologies, including cookies, to present you with a marketing content that suits your interest. When you visit our website it automatically places third parties cookies into your browser. This allows to track your online behaviour, e.g. that you visited our website in the past. This, as well as your behavioural and demographic profile (which might be your browsing history and habits, location, age, gender etc.) is then used to display you our ads when you browse Internet. We also use our customer details, like email addresses, to match them within our third party services providers network to display them personalised marketing content.

If you do not wish your information to be used in such way you may opt-out from using advertising cookies. It can be done through your browser settings. Instruction how to do that can be found:

Marketing communication preferences

We need your clear consent to provide you with marketing communication via variety of electronic communication channels. You can choose this option if you want to receive special offers, promotional codes and other promotional materials directly from Easysend with a use of your email address and phone number (via text messages or phone calls).

In order to record your marketing preferences Easysend created a useful tool, which is available for registered users only.

Transferring data outside EEA

Some of the service providers we use are established outside EU. Therefore your personal data might be transferred outside the EU as well. Due to provide necessary level of protection most of our service providers are members of Privacy Shield Framework program (Google, Facebook, Microsoft, Mailchimp) or we use appropriate clauses in our agreements with our partners that are compliant with decision of European Commission 2010/87/EU on standard contractual clauses for the transfer of personal data to processors established in third countries – http://eur-lex.europa.eu/legal-content/en/TXT/PDF/?uri=CELEX%3A32010D0087&from=en.

Storage and security of personal data

We store personal data on servers which are located in European Union. We implement the highest level of security standards to protect it as well as to comply with relevant regulatory on this matter.

All the activities conducted through our online Service are performed using encrypted connections that use HTTPS and TLS (Evaluation) protocols. Data transmitted in this way is not visible to other Internet users. Nevertheless you should always follow essential rules for online security. For more details please visit: https://www.getsafeonline.org/protecting-your-computer/safe-internet-use.

To have an access to our online service, our users are asked to set up their own password. Being our user, you are responsible for keeping all your login details secure and you should not disclose it to any of the third parties. We store your password, encrypted, on our secure servers.

For security purposes, Easysend has established processes to restrict an access to personal data of its users to its employees. It means, that only some of our employees and only when there is an actual business need for it, can access and process your personal information. To better protect your data and whenever it is possible we have implemented pseudonymisation of personal data and encryption.

We are also very much taking into account security procedures used by our service providers. They must follow all procedures and comply with all relevant regulation which are within their area of service.

Data retention

Personal data gathered by Easysend for the purpose of AML/CTF regulatory requirements need to be stored by us for the period of 5 (five) years after the end of the business relationship with the customer or after the date of an occasional transaction.

Personal data gathered by us for the purpose of executing contract with you are processed as long as they are needed for correct contract execution and after contract is terminated for the period needed to secure pursuing of claims.

Personal data processed by Easysend based on your explicit consent will be used as long as you will not revoke your consent.

Personal data processed by Easysend based on our business legitimate interest – as long as you will not object.

Your rights

Easysend will not use its users personal details in any other way than stated in this document without sending information or obtaining your consent.

You should give your consent to receive marketing offers from Easysend. If you do not wish to receive such correspondence, then you should withdraw your consent. You can do that by choosing relevant option in your user settings on our website. Additionally, every marketing email sent to our users gives an opportunity to opt-out from receiving such correspondence in the future.

By using our service you agree to use your personal data as descripted in this Privacy Policy. At any time you may withdraw your consent by contacting us (see Contact page on our website).

In the case, when Easysend user will provide us with a personal information on a third party, it is necessary to have this third party consent.

Data subject rights

EU General Data Protection Regulation (GDPR) gives you the following rights towards your data that is processed by us:

  • The right to be informed

  • The right of access

  • The right to rectification

  • The right to erasure

  • The right to restrict processing

  • The right to data portability

  • The right to object

If you would like to execute one of your rights please contact Easysend on compliance@easysend.pl. We have one month to respond to your request. Please bare in mind that, as a financial institution and in order to comply with AML/CTF regulatory requirements Easysend is obligated to retain your personal data, as well as all your transaction details and any other additional documents, for required period of time (please see: Data retention section above). This is for the purpose of preventing, detecting and investigating possible money laundering and terrorist financing. Those requirements overrule the GDPR requirements.

We have a right to decline a data subject request to execute its right of access or charge a reasonable fee for fulfilling such request if it is excessive or manifestly unfounded.

If you think that your GDPR right has been compromised you have the right to lodge a complaint to the authority – the Information Commissioner’s Office in the United Kingdom – for further details please visit: https://ico.org.uk/global/contact-us/. You might also contact any national data protection supervisory authority within EU or EFTA countries if you are based outside United Kingdom - http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

It is important for us, the data we collect and hold on our users are accurate and up to date. Therefore we have set up processes and tools to help our users maintain their personal details. You can update your details directly through our website (after log on) or you can contact us by phone or email (see Contact page on our website).

Profiling, segmentation and automated decision making

We use profiling and segmentation of our customers based on, e.g. country of living, language they have chosen, or products they use the most, solely to personalize marketing communication or to increase their user experience when using our services. Currently we do not use automated decision making tools or processes on our users and customers. Also, our profiling and segmentation do not cause legal effects on the customers.

We might however use profiling for the purpose of fraud prevention. It might then cause legal effects on our customers, but we are legally obligated to prevent fraudulent use of our services by the Anti-Money Laundering Regulations.

Cookies

We use cookies. More details on how we do it can be found in our Cookies Policy.

Changes to this Policy

Easysend reserves the right to change this Manual at any time. All changes will be published on this website along with effective from date. In some circumstances, Easysend might inform its users on the upcoming changes by email. Please visit this website frequently to view the latest version of Privacy Policy.

Contact

If you wish to talk to us about this Privacy Policy, please contact us.