This Privacy Policy describes how Reciprocal Payments Limited ("RECIPROCAL," "we," "us," or "our") collects, uses, discloses, and protects the personal data of individuals who visit our website or otherwise interact with us. We are committed to protecting your privacy and complying with applicable data protection laws, including the General Data Protection Regulation (GDPR).
1. Data Controller:
1.1. For the purposes of the GDPR, Reciprocal Payments Limited, a company incorporated in England and Wales with company number 15217588, and having its registered office at 124 City Road, London, United Kingdom, EC1V 2NX, is the Data Controller (as described in the GDPR). You may contact us via the contact form on our website, via the provided email address, or by writing to us on the address provided above.
2. Collection of Personal Data:
2.1. We may collect personal data directly from you when you voluntarily provide it to us, such as when you create an account on our website, fill out forms on our website, contact us via email or phone, or request information about our products and services. The types of personal data we may collect include your name, email address, mobile number, office phone number, banking details, and any other information you choose to provide.
2.2. We may also collect personal data automatically when you interact with our website. This may include your IP address, device information, browser type, log and usage data, and browsing behaviour. We use cookies and similar technologies to collect this information. Please refer to our Cookie Policy for more details.
2.3. We may also request information such as physical address or billing information, transactional information, payment information (for example, in certain cases we process your payment method and credit card number), and additional authentication information (such as copies of your government issued ID, passport, or driving licence, as permitted by applicable laws).
3. Use of Personal Data:
3.1. We use the personal data we collect for the following purposes:
a. To provide and maintain our financial products and services, including responding to your enquiries and fulfilling your requests;
b. To personalise and improve your experience on our website;
c. To send you marketing communications, updates, and promotional materials, if you have opted to receive them;
d. To analyse and understand how our Website is used, diagnose technical issues, and improve our website's functionality and performance;
e. To comply with applicable laws, regulations, and legal obligations;
f. To protect our rights, property, and safety, as well as the rights, property, and safety of our users and the public;
g. Communicating with you about activities on our Website and policy changes;
h. Processing your financial information and other payment methods for products purchased;
i. Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
j. Measuring interest and engagement in our Website and short-term, transient use, such as contextual customisation of ads;
k. Undertaking research for technological development and demonstration;
l. Improving, upgrading, or enhancing our Website;
m. Ensuring internal quality control;
n. Verifying your identity and preventing fraud;
o. Debugging to identify and repair errors that impair existing intended functionality;
p. Enforcing our terms and policies;
q. Furnishing you with customised materials about offers, products, and services that may be of interest, including new content, product, or services; and
r. Protect your vital interest or as may be required for the public good.
3.2. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4. Legal Basis for Processing Your Personal Data:
4.1. Where relevant under applicable laws, all processing of your personal information will be justified by a "lawful ground" for processing. In the majority of cases, processing will be justified on the basis that:
a. you have provided your consent for us to use your personal information for a specific purpose;
b. our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g., to provide you with products or services which you have requested);
c. the processing is necessary to comply with a relevant legal obligation or regulatory obligation that we have (e.g., fraud prevention); or
d. the processing is necessary to support our legitimate interests as a business (e.g., to improve our services to you), subject to your interests and fundamental rights and provided it is conducted at all times in a way that is proportionate.
5. Disclosure of Personal Data:
5.1. We may share your personal data with third parties in the following circumstances:
a. With service providers and business partners who assist us in delivering our services and operating our business, subject to appropriate confidentiality and security measures;
b. With competent authorities, law enforcement agencies, or other third parties if required by law or necessary to protect our rights, property, or safety, or the rights, property, or safety of others;
c. With your consent or at your direction; and
d. Third parties as part of a merger or acquisition.
5.2. We do not sell, rent, or trade your personal data to third parties for their marketing purposes.
6. Data Retention:
6.1. We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy, which includes (but is not limited to) the period during which you use our website. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
6a. Data Security:
6.1. We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. However, please note that no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.
7. Your Rights:
7.1. Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are as stipulated below;
a. Rights to be informed.
b. Right of access.
c. Right to rectification.
d. Right to erasure.
e. Right to restrict processing.
f. Right of data portability.
g. Right to object to processing.
h. Right to withdraw consent to processing.
i. Right to make a complaint to the data protection authorities.
7.2. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
7.3. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
7.4. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
8. International Data Transfers:
8.1. Some of our external third parties are based or send personal data outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
8.2. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
a. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. Standard Contractual Clauses (SCC) - European Commission (europa.eu).
b. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield. EU-US data transfers - European Commission (europa.eu)
8.3. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
9. Changes to This Privacy Policy:
9.1. We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy
