(w.e.f. May 25, 2018)
We are committed to protecting and respecting Your privacy and handling Your information in an open and transparent manner.
As a regulated financial institution, we are bound by the legal requirement to collect, verify and record certain data about you or recipients of your transactions. All types of data we gather may be used to prevent or detect crime.
We may collect and use the following data:
Basic personal data, such as (but not limited to):
This data is necessary for ACE to provide the Service to you. We will request this data when you sign up, before the Service is provided.
Data for ‘Know Your Customer’ (KYC) regulations, such as (but not limited to):
This data will sometimes be needed to conduct Know Your Customer (KYC), Customer Due Diligence (CDD) and security checks, as required by local and international regulations. This helps us keep your money safe, and we will only request these details when necessary.
Data about your recipient, such as (but not limited to):
We also collect from you information in relation to other people (e.g.: details of the recipients of Your money transfers), where You provide us with such information. By providing us with such information you confirm that you have obtained any necessary permissions from such persons to the reasonable use of their information for such purposes in accordance with this notice, 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.
Data from other third party sources, such as (but not limited to):
ACE collects this data only when you provide the relevant permission to social media sites.
Technical data, such as (but not limited to):
This data is used to help us to understand how you use our Service, so that we can improve it.
When You download our Mobile App, in addition to the information mentioned above we:
We collect your data to personalise and improve our Service for you. The specific purposes for which we collect your data include:
We need to collect data in order to process your transactions. Without data such as you and your beneficiaries bank account details or full name and address, we would be unable to transfer money for you.
As regulated financial institutions, both ACE and our partners are required to conduct Know Your Customer (KYC) and Customer Due Diligence (CDD) checks to comply with our legal and regulatory requirements.
These include our requirements under Anti Money Laundering (AML) and Counter Terrorist Financing (CTF) legislation. All of this helps us keep our Service safe and secure.
Marketing purposes We may process your personal data to provide you with certain types of marketing communication that we believe will be relevant and of interest to you. This helps us provide you with a more personalised Service. This kind of activity is permitted by our ‘legitimate interest’ (for more information on legitimate interest, please see Section 8 of this Policy). We will always endeavour to make these communications relevant and unintrusive, and you are able to object to marketing communication from us at any time.
We may collect and analyse data such as website or app visit logs in order to improve the quality of our Service.
You do not have to disclose any of the above data to us. However, if you choose to withhold certain data, we may not be able to provide you with our Service.
The law permits us to process Your personal data in the way we do because the processing is:
All the data that you provide to us is encrypted on our secure servers. We restrict access to your data to specific employees of ACE who have an important business-related reason for handling it. Our communications are encrypted using the TLS (Transport Layer Security) technology protocol.
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 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. In general, we will keep our records for up to 5 years after you have terminated your relationship with us, in order to comply with our legal obligations.
We may retain Your contact information collected for the purposes of sending You marketing communications in accordance with this policy for as long as You do not unsubscribe from receiving the same from us.
We share your personal data with third parties only when it is necessary for the fulfilment of the Service or to comply with applicable laws.
We will never sell your personal data to other organisations.
We work with partners who help us to complete your transactions. If they are based outside the EEA, we will share your personal data with them only when they apply essential safeguards, or if it has been established by EU institutions that the relevant country has an appropriate data protection regime in place, or when we otherwise ensure that the appropriate level of protection is applied for data processing.
The following are some purposes for which we may share your data with third parties:
To fulfil the contract between you and ACE
We may share your data with third parties, such as our partners and intermediaries, when they are necessary for the fulfilment of the Service.
When required by law
We may share your data when required by law, for example for the purposes of security, taxation and criminal investigations.
For marketing and communication
We may share your data with third parties such as providers of customer service tools, marketing campaign tools, email communication tools, analytics software (for marketing purposes) and data visualisation tools (for analytical purposes).
If we sell or buy any business or assets, we may be obliged to share your personal data with the prospective seller or buyer.
The law gives you a number of important rights in relation to your personal data, which are listed below.
There are certain exceptions where these rights may be superseded by laws and other requirements applicable to regulated financial institutions like ACE. An example of this would be the obligatory retention period (seen Section 5), which supersedes the right to data erasure.
Your rights are:
If you would like to read more about your rights in relation to your personal data, please refer to the Information Commissioner’s Office website.
Legitimate interest is a specific legal justification for the collection and processing of your personal data. It applies when we have reasonable grounds to collect and/or process your personal data to improve our Service, as long as this does not infringe on your rights.
Our legitimate interest may justify some examples of automated decision-making. One of those is our estimated transaction timing, which we use to determine the time in which the transfer will reach your beneficiary.
We believe that if you are an active customer of ACE, it is in your interest to receive occasional information about our Service. We may therefore send you communications about offers or promotions that we believe are relevant for you based on your previous use of the Service. If we notice that you are having problems using our Service, we may on our own initiative decide to contact you, in some cases by phone, to offer help.
We may also process your data to help develop new product features that we believe will improve the Service. We may contact you occasionally to assess your satisfaction with the Service. We may also use your data to determine the effectiveness of marketing or promotional campaigns. We may also contact you with information about any changes in the Service, and/ or other important updates.
We will only share anonymised or encrypted data with the third parties. We may also provide our partners with anonymous aggregated data about our customers for marketing and analytical purposes, to help optimise our marketing communications.
You can object to data processing based on our legitimate interest at any time by contacting us at firstname.lastname@example.org or by changing the settings on your ACE account.
Cookies are small text files which are stored on your device when you access ACE. They allow us to recognise you and store data about your past activity and your preferences so that we can personalise and improve the Service for you.
Cookies and other similar technologies may collect data such as language preference, country and previously viewed pages.
We use the following cookies:
By using our Service, you agree to place the cookies described above on your device. You have the right to withdraw your consent at any time. If you would like to delete our cookies, you can do so by changing the settings of your browser.
Blocking or deleting cookies may mean that some features of the Service may not be available to you.
You can log in to ACE using your Facebook or Google profiles. This allows us to authenticate your identity by obtaining access to:
By using your Facebook or Google login credentials, your personal data may be processed by Facebook or Google marketing tools. An example of this is the Facebook tool called ‘Lookalike Audiences’ or a similar tool used by Google called ‘Customer Match’. These help us to identify people who have similar interests or behaviours to those of our customers. We may use similar tools provided by Facebook or Google in the future.
You can contact ACE:
By post: 61-67 Pall Mall Court, Manchester M2 4PD, United Kingdom
Via our website: www.acemoneytransfer.com
ACE has a Data Protection Officer who is responsible for matters related to privacy, data protection and data security. Our Data Protection Officer can be contacted at email@example.com.