Privacy Policy

Information you provide us when you use our Services or contact our team:

• Details such as your name, residential address, date of birth, telephone number, mobile number, email address, occupation, bank account details, details in your identification documentation (e.g. passport, social security number or other tax identification number), utility bill, and/or driving licence, visa and copies of any other documents you provide to prove your age or identity so we can satisfy our ‘Know Your Customer’ checks.

• If you have a Moneycorp account online, log-in credentials such as your username, password, passcode and security question answers.

• To comply with Anti-money laundering (AML) and Countering the Financing of Terrorism (CTF) legislation, assess creditworthiness, and process payments and transactions we may collect financial information such as credit or debit card numbers, credit information or reports or tax information.

• When you book transactions with us, we need to collect information about the other parties involved in the transaction, including beneficiary name, account number, address (“Beneficiary Details”), the source of the funds, the reason for the transaction and the devices and payment methods used to complete transactions. – Note: by providing this information to Moneycorp, you agree to have obtained the payee’s consent to their personal data being processed by Moneycorp in its capacity as a Processor. This is necessary for us to make a payment to them and you confirm that you know they agree or that you are otherwise allowed to give us this information and will inform them of the contents of this Privacy Policy.

• If you are using our services on behalf of a business entity, we need to collate information about the business including the organisational structure of the company and individuals involved in the business including their name, address, job title of signatory, email, phone, Identity documents of signatory, proof of bank account details and similar details of other authorised personnel. We may also collect entity formation documents or other corporate records such as company registration details etc. 

Moneycorp is required under AML/ CTF Laws to collect Personal Data of individuals who ultimately own or control corporate clients, directly or indirectly (“Beneficial Owners”) – This is to ensure that they have authority to act on behalf of the business entity and provide that information. Such information may include the Beneficial Owner’s name, date of birth, title, mailing address, phone number, email address, nationality, occupation and social security number or other tax identification number. You confirm that you know the Beneficial Owners agree or that you are otherwise allowed to give us this information and will inform the Beneficial Owners of the contents of this Privacy Policy. 

• To the extent permitted by applicable law, we may obtain, in the course of providing you with the services you request, background check reports from public records of criminal convictions and arrest records. Some jurisdictions require us to obtain your consent. Where you refuse to provide consent, we may be unable to provide services to you.

• We may collect any other Personal Data you provide to us when you update your account information, respond to surveys, post to third party community forums hosted by Moneycorp and third parties, participate in contests or promotions, or use any other feature of our products or services.

Information we collect about you when you use our Services or contact our team:

• Details of the transactions you carry out when using our Services, including geographic location from which the transaction originates.
• Your image(s) in photo (for example, where required as part of our Know-Your-Customer (“KYC”) checks, to verify your identity where you upload a photo to your Moneycorp account and any photographs from ID’s such as a driving licence or passport).
• Information about other people (such as a joint account holder, your spouse or family) when we ask you to give us this information to enable us to comply with our obligations under KYCAML/CTF legislation and to assist with fraud monitoring.
• Personal Data derived from money transfers, payments, membership programmes including friend and family referrals, previous use of its service history and/or marketing choices generated or collected in virtue of the relationship between Moneycorp and you.
• When you access our services or products via our online channels, we collect website behaviour and store user data for session statistics (pages visited, clicks, referral sources, etc.), approximate geolocation, browser, device information, server logs, which may include information such as IP address, access times and dates, pages viewed
• We may obtain information about the devices you use to access our website - through, for example, Google Analytics which may include details of the device used (mobile, desktop, tablet), the brand of the device (iPhone, Galaxy, etc.), the OS, and the browser used

We will update the information we hold on you as and when you provide it to us during our communications with you. However, wherever possible, you should advise us if information we hold on you needs updating or is no longer accurate. 

Moneycorp will collect your Personal Data from you when it is reasonable or practicable to do so, or is authorised by applicable laws.

We collect Personal Data and other information from you when you:

• Visit any of our websites or download and install the Moneycorp app;
• Complete an application or form, register for a Moneycorp user account and make international payments online, over the telephone, by post or in person; 
• Submit to our verification procedures, apply for additional account features or services or conduct transactions;
• Raise an enquiry on the Moneycorp website, call centre and/or respond to our emails, messages or surveys or communicate with us  by telephone, email and online via Moneycorp website or App;
• Provide feedback, participate in promotions or contests, visit our Expo stalls, networking events,  provide referrals, respond to our press release, article, or upload content; 
• reserve or purchase foreign currency with us;
• Sign up to receive our daily brief, whitepapers and other general marketing from us and to receive rate alerts from us; 
• Register for one of our webinars;
• Report a problem, make a query or issue a complaint about our Services; 
• When you download the copy of our marketing materials online;
• Give a third party permission (e.g. a Referring Partner) to share with us your personal data; and 
• Connect with us via your social media account. 

We collect Personal Data about you from third parties and other sources, including government agencies, identity verification and fraud detection service providers and databases, credit bureaus, credit reporting bodies, credit reference agencies, community forums used to post ratings or reviews, social media platforms, advertising, advertising technology and market research companies, third-party sales lead sourcing companies, demographic & profile data brokers including companies that publish marketing and advertising materials that you interact with, Moneycorp business partners and associates through which you access our services.

Data Protection Law sets out the key, lawful basis that organisations, businesses and governments can rely on to collect and process personal data. Moneycorp predominately relies on the following: 

1. Consent 

This means processing your personal data where you have explicitly given us permission to do so. 

2. Performance of a Contract 

This means processing your personal data in order to fulfil our contractual obligations with you. 

3. Legal Obligations 

This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject. 

4. Legitimate Interests 

This means processing your personal data where we or a third party have a legitimate interest to do so. We make sure we consider and balance any potential impact on your rights before we process your personal data for our legitimate interests. Where our interests are overridden by a negative impact on your privacy rights, we will not process your personal data. 

We may process your personal data for the following purposes, depending on how you interact with us.

1. To complete the delivery of our foreign exchange, bank, international payment and wholesale banknote services (the “Services”)

Without your personal data, we would not be able to open your Moneycorp Account, facilitate your foreign exchange transactions or complete the delivery of our Services. 

As part of our online account opening process, we will send you a one-off follow up registration email should you not complete the second page of the online account registration page. We will do this on the basis of our legitimate interests.

At the start of the relationship, Moneycorp may also call or email you to discuss the reasons for opening an account and your foreign exchange needs. We will do this on the basis of our legitimate interests.

When you login into your Moneycorp Account online, we will send you, via SMS or email, a one-time password as part of our two-factor authentication login process. We will do this to comply with our legal and regulatory obligations. 

Throughout the relationship, Moneycorp may also be required to send you communications known as ‘service messages’ in order to inform you about changes to the services we provide you. For example; changes to our terms and conditions and/or privacy policy, changes to our opening hours and bank account details, reserve and collect order confirmations and proof of payment confirmations. These service messages will not include any promotional content and cannot be unsubscribed from.

2. To respond to your queries and complaints.

Without your personal data, we would not be able to effectively respond and handle queries or complaints. We may keep a record of our correspondence to demonstrate how we communicated with you throughout. We will do this on the basis of our legitimate interests and our legal obligations.

To comply with our legal and regulatory obligations

To comply with laws, regulations, codes of conduct, binding determinations or to respond to government authorities, to address disputes or resolve claims related to the use of our services, to enforce our terms and conditions, to verify your identity or authenticate your right to access an account or other information, and to conduct manual or automated monitoring in order to meet our legal and regulatory requirements, we are required to carry out regulatory checks in order to prevent and detect fraud, money laundering, identity theft and other crimes. 

4. To analyse, test and improve our systems and databases

We may use your personal data to ensure that our systems are tested thoroughly. This ensures that the system can cope with comparable volumes of information, that a wide range of realistic scenarios are covered, and that the test will reflect all the possible combinations that occur in the real environment. Test systems are isolated from external networks to ensure that live systems are not compromised. In addition, to ensure data is not compromised, we carry out various risk assessments, and have implemented safeguards to ensure data security. We will do this on the basis of our legitimate interests.

5. To develop new and improved products and services, including conducting market research and product analysis

To analyse trends, usage, preferences and other user activities on our online channels to optimise user experience and to enhance the effectiveness of our promotional campaigns.

For this purpose, we will use cookies to personalise your next visits to our websites and to measure volumes and patterns of website usage. Full information can be found in our Cookie Policy here. This includes information on how to adjust your browser settings to accept or reject cookies. We will do this on the basis of our legitimate interests. 

6. For training and quality purposes

We are continually reviewing the quality of the services we provide in order to improve your experience with Moneycorp. We will do this on the basis of our legitimate interests.

7. To keep you informed about relevant products, special offers and market news 
Moneycorp US Customers (Private & Corporate)

For Moneycorp US Inc. customers, we will keep you informed about relevant products, special offers and market news up and until you tell us otherwise (i.e. until you opt-out).

Moneycorp Shared Services Ltd, Moneycorp Technologies (Ireland and its branches in France, Romania and Spain), TTT Moneycorp, Moneycorp FRM, Moneycorp (Hong Kong) Limited) and Moneycorp Bank Ltd - (Private Customers)

For customers who agreed to receive to marketing before the 25th May 2018, we will continue to send you relevant products, special offers and market news unless you tell us otherwise (i.e. until you opt-out). We will rely on our legitimate interests and the soft opt-in exception made available by the Privacy and Electronic Communications Directive 2002 to do this.

For new private customers (incl. sole traders and non-limited partnerships), we will only keep you informed about relevant products, special offers and market news where you have explicitly consented. 

Moneycorp Shared Services Ltd, Moneycorp Technologies (Ireland and its branches in France, Romania and Spain), TTT Moneycorp, Moneycorp FRM, Moneycorp (Hong Kong) Limited, and Moneycorp CFX Customers (Private) and Moneycorp Bank Ltd (Corporate Customers)

For new and existing corporate customers (exc. sole traders and non-limited partnerships) we will keep you informed about relevant products, special offers and market news up and until you tell us otherwise (i.e. until you opt-out).

You are free to opt-out of receiving marketing communications from us at any time by following one of the options set out in the “Managing your marketing preferences” section of this Policy.

Telephone calls made and received by Moneycorp may be recorded and internally monitored for the purposes of:

1. Ensuring that Moneycorp complies with its regulatory obligations;
2. Evidencing your use of our Services;
3. Investigating complaints;
4. Gathering evidence in disputes; and
5. Improving Moneycorp’s Services (training and quality control).

Moneycorp may also maintain a record of all emails sent by or to Moneycorp for the same purposes.

We will never sell your Personal Data to marketers or other third parties. 

We may share your personal data with the following entities for the purposes described in this Policy:

1) Moneycorp subsidiaries, overseas branches, affiliates and sister companies

A complete and up-to-date list can be found in the “Definition and Glossary” section of this Policy.

2) Third party service providers

We engage a variety of service providers to enable us to provide our services to you. This includes:

• Agencies who provide credit referencing/reporting, identity & verification checks, adverse media checks, sanction screening, PEP checks and fraud prevention services.

• Payment processing service providers, intermediary banks and financial institutions to process your transactions.

• Auditors and professional advisers such as lawyers and consultants.

• Banks and financial services who facilitate our foreign exchange transactions and provide our Explorer Card product. 

• Companies who host, support and maintain our website, databases, archives and other business systems.

• Companies who provide off-site hard copy information management facilities.

• Companies who provide Moneycorp with its customer relationship management applications

• Companies who perform functions on our behalf in the areas of IT development, infrastructure, analytics, insights generation, IT support, back office, compliance and finance. 

• Companies that provide our email archiving and backup system.

• Companies that provide our telephone call recording system and tracking analysis software.

• Companies that carry out our direct marketing and research survey emails and texts.

• Companies who assist with distributing marketing materials, conduct market research, perform audits, provide professional advice.

• Companies that provide our online live chat platform. 

• Companies who assist with providing our two-factor authentication security process.

• Companies that provide our online electronic signature software. 

• Companies that provide our refer-a-friend programme. 

• Companies that enables Moneycorp to collect customer reviews of its Services. 

• Companies that provide our customer rewards and incentive scheme.

• Companies that provide Moneycorp with its appointment/meeting scheduling software. 

• Companies that provide Moneycorp with its webinar platform. Cash-in-Transit Carriers (wholesale banknote clients only).

• We may disclose or otherwise provide anonymised/aggregated data to third parties for statistical purposes.

3) Public Authorities & Regulatory Bodies

This will only be in response to lawful requests made from public authorities and regulatory bodies, if we believe it is necessary or appropriate, we may share your Personal Data with law enforcement officials, government authorities, regulatory bodies or other third parties, including for the purposes of: (i) enforcing our terms and conditions or other applicable agreements or policies; (ii) protecting our rights, property, privacy, or security, or that of others; or (iii) complying with applicable law, legal process, or government orders including any request made in order to meet national security, public interest or law enforcement requirements.

4) Media Partners

Moneycorp provides its international payment services to and on behalf of a number of media companies. This include, Telegraph Media Group LTD, News UK

5) Referring Partners 

If you have been referred to Moneycorp by a third party who you and Moneycorp both have a separate direct relationship with (e.g. an estate agent, law firm or an independent financial advisor), we may provide such third party with personal data relating to you (name & trading activity) in which they are interested in by virtue of Moneycorp’s agreement with them (e.g. for verifying and allocating commission earnt or to monitor the success of referrals) and where your interests and privacy rights do not override those interests.

6) Mastercard Prepaid Management Services 

If you have a red or white Moneycorp Explorer Card, we will share your personal data with Mastercard Prepaid Management Services Limited (MPMS) who act as programme manager of the Explorer Card for and on behalf of the card issuer, Prepay Technologies Limited, who is the Controller of your personal data associated with your Explorer Card. 

If you require any further details about your Moneycorp Explorer Card, please contact MPMS at prepaidmgmt_cardservices@mastercard.com  

7) Third-Party  Acquirers

If we are the subject of or are involved in any corporate merger, acquisition, consolidation, reorganisation, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in connection with bankruptcy or similar proceedings), we may disclose or transfer data, including Personal Data, with third parties in connection with such events.

8) Other third parties

With your explicitly consent only, we may pass your personal data to a third party for their own direct marketing purposes.

We may also pass your personal data to third parties for the purposes of administering Moneycorp promotions/prize draws/competitions you have entered in to. We will rely on our legitimate interests to do this.

In the event we sell divisions of our business, we may disclose your personal data to prospective purchasers and their advisers so they can evaluate the relevant business. We will rely on our legitimate interests to do this.

Please note our websites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.

To facilitate our global operations, the personal data that we collect from you may be transferred to, and stored at, destinations both in and outside the UK and EEA.

Where processed outside the UK and EEA, we will take appropriate steps to ensure your personal data still receives a level of protection that is consistent with UK and European data protection standards. For example, we will only share your personal data outside the UK and EEA if a) the location has received an adequacy decision from the UK government or European Commission b) we have an EU approved model clauses agreement in place or if the third party receiving your personal data has signed up to an UK or EU approved data sharing mechanism. 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Personal data is protected by a defence in depth security programme that is certified to the international standard for security management (ISO 27001). Protections include, but are not limited to, two-factor authentication, mature access control (with strict procedures around privileged access), network segmentation, DDOS protection, layered security appliances (firewalls, IPS, AV, monitoring via SIEM), email and web filtering, DLP protection, rogue detection, patch management and vulnerability remediation. A continual assurance programme is in place as part of ISO 27001 certification, which includes independent audits, vulnerability management and penetration testing. We also secure access to all transactional areas of our websites and apps using ‘https’.

We provide our employees with training and detailed information about our data handling practices through internal company policies such as our Data Protection Policy. All employees have to certify that they have read and understood the contents of our Data Protection Policy which is reviewed and updated on an annual basis. As well as our Data Protection Policy, which governs how we process data throughout the Moneycorp Group, we have a separate suite of internal policies which govern areas such as information security and information classification.

In accordance with our legal and regulatory obligations (for example, Money Laundering Regulations), we will retain your personal data for a minimum period of Seven years from the closure of your account and 10 years if you are a Moneycorp SLU, Spain customer).

In some circumstances, such as an enquiry from a law enforcement agency, we may retain your personal data for a longer period of time.  We may also retain information if doing so protect our interests, for example, if legal proceedings are anticipated or on-going.  When data falls outside Moneycorp’s retention periods, we will take steps to delete it from our system. Where you have asked us not to contact you, we will retain that information on a ‘do not contact’ list to reduce the risk of us contacting you in the future.

Inactivate Accounts

If you have not used your account for more than two years, it will be flagged as inactive and we may contact you to ask whether you want to close the account.

Closed Accounts

If you inform us you longer wish to have a Moneycorp account, we will close and deactivate your account.

At the end of the retention period, your personal data will either be anonymised (so that it can only be used in a non-identifiable way for statistical analysis and business planning), made inaccessible or unintelligible (for system integrity purposes) or deleted completely. However, we may retain your information beyond this retention period if we have a legitimate business interest to do so (or we can rely on another lawful basis).

Your data may be retained on offline backup systems for a longer period, however these backups are not part of our day to day processing.

Where processed outside the UK and EEA, we will take appropriate steps to ensure your personal data still receives a level of protection that is consistent with UK and European data protection standards. For example, we will only share your personal data outside the UK and EEA if a) the location has received an adequacy decision from the UK government or European Commission b) we have an EU approved model clauses agreement in place or if the third party receiving your personal data has signed up to an UK or EU approved data sharing mechanism.

You have a number of rights under Data Protection Law which, in certain circumstances, you may be able to exercise in relation to the personal data we process about you. This includes:

Right to Access: You have a right to receive a copy of the personal data we hold about you. This is commonly known as a Data Subject Access Request. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required.

Right to Data Portability: You have a right to receive certain information you have provided to us in a ‘machine-readable’ format and/or request that we transmit it to a third party.

Right to Erasure: You have a right to request that we erase your personal data. However, we may not always be able to comply with your request of erasure for specific legal and regulatory reasons which will be notified to you, if applicable, at the time of your request.

Right to Object: In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Right to Lodge a Complaint: You have the right to lodge a complaint with your national data protection authority. Further details can be found in the “Contact Us” section of this Policy.

Right to Rectification: Where your personal data is inaccurate, out-of-date or incomplete, you have the right to request an amendment to it.

Right to Withdraw Consent:  Where you have given us your consent to process your personal data, you have the right to change your mind at any time and withdraw that consent.

Right to ask not to be subjected to automated decision making and profiling: Moneycorp puts the human factor at the heart of our customer service, so there are no circumstances when profiling or other automated decision making will have a legal impact on you without a person reviewing and making a decision on the result. If you feel you may have been unfairly impacted by profiling, our team can manually assess whether the decision is fair and discuss the situation with you.

If you wish to exercise any of these rights, please get in touch by using the details in the “Contact Us” section below. Please note we will ask you to verify your identity before proceeding with any request you make. Once we have verified your identity, we will endeavour to respond to your request within a month from receiving a valid request.

There are a number of ways you can update or stop direct marketing communications from us:

Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular business entity of Moneycorp. Please note unsubscribe links are not sent on service emails. Please note that unsubscribe links are not included in service emails because you cannot unsubscribe from service emails.

If you have a Moneycorp Bank or International Payments account, login into your account, visit the ‘My Account” section of the homepage and click on the “Manage my Communications” link.

Email DataProtection@moneycorp.com or call +44 (0)20 3823 0009

If you have downloaded Moneycorp’s App (UK only) and wish to disable push notifications, you can do this by following the below steps:

For iOS Devices:

• Open your Settings app and tap “Notifications”
• Swipe up until you see the Moneycorp App
• Select the Moneycorp App and tap the check box next to “Allow Notifications” to disable

For Android Devices:

• Open your Settings app and tap “More”
• Tap Application Manager and select “Downloaded”
• Select the Moneycorp App and tap the check box next to “Show Notifications” to disable
• If you have opted in to receive Moneycorp’s web notifications and wish to disable push notifications, you can do this by following the below steps:

For Chrome browsers:

• Open your Settings app and click 'Advanced'.
• Under 'Privacy and security', click Site settings.
• 'Click Notifications'.
• Choose to block or allow notifications:

(i)  Block all: Turn off 'Ask before sending'.

(ii)  Block a site: Next to 'Block', click 'Add'. Enter the site and click 'Add'.

(iii)  Allow a site: Next to 'Allow', click 'Add'. Enter the site and click 'Add'.

For Firefox browsers:

• Click the menu button and select 'options'.
• Click 'Privacy & Security' from the left pane.
• Scroll to the Permissions section.
• Click the 'Settings' button next to notifications.
• Select the website.
• Click the 'Remove Website' button.

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

If you are a Moneycorp US Inc. customer, your personal data will processed be in accordance with the terms of this Policy and applicable U.S federal and state law. For the purposes of this Policy, references to ‘personal data’ includes ‘personally identifiable information’, ‘Personal Data’ (as defined in the California Consumer Privacy Act) and ‘non-public Personal Data’ (as defined in The Gramm-Leach-Bliley-Act). 

As part of the Moneycorp Group, please note your personal data may be stored and processed by other Group entities and third party service providers located outside the United States. 

California Privacy Rights 

This part of the Privacy Policy describes the rights of Californians under the California Consumer Privacy Act 2018 (“CCPA”). The CCPA requires businesses like us, which process Californian residents’ Personal Data, to provide certain information to them.

Like all our clients, you have the right to request a copy of your Personal Data. Under the CCPA, you can also request that we disclose how we have collected, used, and shared your Personal Data over the past 12 months, including the categories of Personal Data we collected and our purposes for doing so; the categories of sources for that information; the categories of third parties with whom we shared it for a business purpose and our purposes for doing so. California residents also have the right to submit a request for deletion of Personal Data under certain circumstances. If you wish to do any of these things, please contact us following the instructions in the Contact Us section below However, please note that you must verify your identity and request first before further action is taken. As a part of this process, government identification may be required. 

California residents also have a right to opt out of the sale of their Personal Data by a business and a right not to be discriminated against for exercising one of their Californian privacy rights. Moneycorp does not sell the Personal Data of any of its clients and does not discriminate in response to privacy rights requests. 

In accordance with the CCPA, Moneycorp will also (a) never share your Personal Data with third parties for their own direct marketing purposes without your consent or (b) collect new categories of Personal Data or use them for materially different purposes without first notifying you.

We value your feedback on our data protection processes and aim to resolve any and all complaints to your full satisfaction. We agree to ensure open lines of communication regarding your complaints, and that all complaints will be given an impartial internal review.

For any questions or complaints about the use or disclosure of your personal data, please contact our Data Protection Team via one of the following:

Email: DataProtection@moneycorp.com

Telephone: +353 3823 7518 (for EU-based clients) or +44 (0)20 203 7823 0009 (for UK-based clients, Non-EU & Non-US clients).

Post: Attn: Data Protection Team, Moneycorp, 24 Windsor Place, Dublin 2, Ireland (for EU-based clients) or Attn: Data Protection Team, Moneycorp, Floor 5, Zig Zag Building, 70 Victoria Street, London, SW1E 6SQ (for UK-based clients, Non-EU & Non-US clients).

If you are based in the US and have any questions about this Policy or believe our customer records contain incorrect information about you, please contact us on 1-800-239-2389 or email us at Legal.US@moneycorp.com.

Contacting the Regulator:

If you feel that your personal data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with your national Data Protection Authority.

In the UK, this is the Information Commissioner’s Office. You can contact them by visiting https://ico.org.uk/global/privacy-notice/how-you-can-contact-us/

In Ireland, this is the Data Protection Commission. You can contact them by visiting https://www.dataprotection.ie/en/contact/how-contact-us

For a complete list of all European Data Protection Authorities, click here: https://ec.europa.eu.

For US customers, complaints can be made to the Federal Trade Commission – https://www.ftc.gov.

For Australia customers, complaints can be lodged with the Office of the Australian Information Commissioner – https://www.oaic.gov.au.

For Hong Kong customers, complaints can be lodged with the Privacy Commissioner for Personal Data – https://www.pcpd.org.hk.

For Canadian customers, you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada, or in some Canadian provinces, your local Privacy Commissioner.

For other non-data protection matters, please contact your Account Executive or your usual point of contact. You can also speak to a member of our team by calling Customer Services here.

Effective Date: 25th May 2018

Last Modified: 1st June 2023

We reserve the right to amend this Policy from time to time without notice in order to be consistent with Data Protection Law requirements. Where we do make significant changes to this Policy, we will take appropriate steps to bring those changes to your attention.