PRIVACY POLICY

/Privacy Policy
Privacy Policy2018-09-06T15:54:02+00:00

Our commitment

We at Infinity International are committed to maintaining the highest standards of integrity in our operations. Protecting the security and privacy of personal data is no exception and is integral to the way we conduct our business.

We strive to ensure compliance with relevant data protection law, including the General Data Protection Regulations (“GDPRs”), and take appropriate measures for the security and protection of personal data.

The purpose of our Privacy Policy is to explain:

  • who we are
  • what personal data we might obtain
  • how we might use (or “process”) it and why
  • who we might obtain it from
  • how long we might keep it
  • with whom we might share it
  • any sharing that might happen outside of the EEA (the European Economic Area)
  • how we keep your data safe
  • your rights, including how to make a complaint.

Before going into detail, we thought it would be helpful to set out some explanation of a few important data protection terms and themes

What is personal data?

Personal data is any information relating to you if you are a natural person or individual.

It includes things like your personal name, address, telephone number and email. It can also include things like your date of birth, relationships and financial information, such as your credit history.

It does not generally include information about companies but it does include similar information relating to a company’s employees, directors or shareholders.

We might get your personal data from you or we might get it from others (such as your employer or a third party who introduces us to you).

What is processing?

Processing means just about anything which might be done with any personal data.

It includes things like collecting, recording, using, storing or sharing it with others. For example, we may process personal data so we can answer your queries and provide you with our products and services and we may share your personal data with third parties who help us to provide them to you.

Who is the data controller?

If we obtain personal data to enable us to provide you with our services, we will normally be the data controller over that personal data. This is because, we determine what personal data we need and what happens to it to enable us to provide you with those services.

As a data controller, we have certain duties and responsibilities under data protection law. We take our role as a data controller seriously. Some of our duties and responsibilities as a data controller are addressed in this Privacy Policy.

Who is the data processor?

We will not always be the data controller. If we receive personal data with restrictions on how we can use it or for a limited purpose set by someone else, we may only be a data processor, and our duties and responsibilities under data protection law will be more limited.

For example, where we receive your personal data from a third party, such as one of our affiliates, who introduces you to us, and we use it to make contact with you, initially we will normally be a data processor only of that personal data. When we make contact with you, and should you decide to register with us, from that point we will then become a data controller of the same personal data and of any other personal data you share with us.

What if we share personal data with someone else? Are they a controller or a processor? And who is responsible for it?

It depends on what they do with the personal data.

If we share any personal data with others, they may be a data processor (if they only use it on our behalf – and where, even though they have it, we will remain responsible for it as a controller if we were a controller of it when we shared it with them) or a data controller (if they use it for their own or other purposes – making them a controller of it and responsible for it).

We are Infinity International Limited.

Our offices are based at 25 Canada Square, Canary Wharf, London, E14 5LB.

Our registered office is at Third Floor, 24 Chiswell Street, London, United Kingdom, EC1Y 4YX and we are incorporated with company registration number 06333730.

In this privacy policy we also refer to Infinity International Limited as “we”, “us”, “our” or “Infinity International”.

Infinity International provides foreign exchange and related money transfer services.

We are authorised as a payment institution and regulated by the Financial Conduct Authority (FCA) for the purposes of providing payment services. We are also registered with HM Revenue & Customs (HMRC) as a money services business.

When you ask us to perform our services, in the course of our providing them, or otherwise during and in connection with our business operations, we may collect and use (or “process”) personal data.

What personal data do we obtain?

The sort of personal data we might obtain includes:

  • your name, email address and telephone number (such as where you make contact with us, where we make contact with you following a referral, where you ask us to provide you with our daily update, or where you wish to provide us with your feedback)
  • your name, email address and telephone number, home address, date of birth, nationality and occupation (where you register with us for, or ask us to provide you with, our foreign exchange and related money transfer services)
  • the same or similar information relating to any joint account holder on any account
  • the same, similar or supplemental (further details about you, such as regarding your occupation, address, previous address, source of wealth or history) information, for example, where we feel it is appropriate for the purposes of performing proper due diligence relating to an instruction
  • information about the intended recipient (or “beneficiary”) of any money transfer (such as their name, address, account details, date of birth, nationality, occupation, and connection with you or the joint account holder)
  • other transaction related information, such as other information about the trade you want us to make, the amount and currencies involved, when you want us to make it and where you want the money to be sent
  • any other personal information which you decide to tell us (such as when one of our dealers or sales agents speaks with you).

Where we receive enquires from or referrals in relation to a firm or company, or a firm or company registers with us for, or ask us to provide it with, our foreign exchange and related money transfer services, we may obtain similar information relating to that firm or company or the related transaction. Only that similar information which relates to a natural person or individual (such as any relating to a director, partner, trustee, shareholder, named contact or authorised person of the firm or company) is personal data.

We may use (or “process”) personal data for any one or more of the following purposes:

so we can take pre-contract steps at your request or to perform our contract with you, including

  • responding to enquires about our products, services and rates
  • to contact you or return your call
  • to provide an estimate or quotation
  • to provide rate related information
  • to register you and any joint account holder as our customer
  • to perform customer on-boarding
  • for the purposes of acceptance of our terms and conditions
  • to understand and record the required transaction
  • to enable performance of the transaction and communicate its performance
  • to provide our products and services to you and any joint account holder

to comply with a legal obligation on us or to perform a task in the public interest, including

  • to confirm or verify your identity, the identity of the intended beneficiary or any other relevant party (such as, where our customer is a business, any director, partner or shareholder of that business)
  • to perform due diligence and any further due diligence concerning you, the intended beneficiary or any other relevant party (such as, where our customer is a business, any director, partner or shareholder of that business)
  • to record your instructions and the transaction
  • to meet requirements imposed on us by, and to respond to notices and requests we receive from our regulator the Financial Conduct Authority or HM Revenue & Customs, or their replacements
  • to perform checks for the purposes of crime and fraud prevention, including for anti-money laundering purposes, such as client due diligence, identification and verification, source of wealth, sanctions and PEP checks and clearances
  • to meet requirements of data protection law, and to respond to notices and requests we receive from, the Office of the Information Commissioner (ICO) or any other national or supra-national authority with the same or similar responsibilities
  • to enable us to carry out enquiries of and reporting to, and to co-operate in any investigations by, the National Crime Agency (NCA), HMRC, HM Treasury and the Office of Financial Sanctions Implementation (OFSI)
  • in connection with any court order or police warrant or investigation
  • in connection with any statutory audit of our business.

for our legitimate interests or those of a third party, including

  • responding to enquires
  • to contact you or return your call
  • to provide an estimate or quotation
  • to provide rate related information
  • to record your trades, requirements and preferences
  • to provide you with our daily update and other insight
  • to provide you with information about our products and services
  • to help us to better understand you and your needs
  • to help us to optimise our products, services and performance
  • to confirm or verify your identity, the identity of the intended beneficiary or any other relevant party (such as, where our customer is a business, any director, partner or shareholder of that business)
  • to perform due diligence and any further due diligence concerning you, the intended beneficiary or any other relevant party (such as, where our customer is a business, any director, partner or shareholder of that business)
  • to enable you to provide us with your feedback on our products and services, and any transaction we perform for you, including any follow up action (which might include contacting you or speaking with our dealer)
  • to enable us to qualify or respond to our leads, including any received from our sales agents or affiliates at your request (including communicating with you and with the relevant sales agent or affiliate)
  • to enable us to respond to enquiries from our regulator, the Financial Conduct Authority (FCA), and from other relevant government agencies and authorities, including the National Crime Agency (NCA), HM Revenue & Customs, HM Treasury, the Office of Financial Sanctions Implementation (OFSI), the Police, the Office of the Information Commissioner (ICO) and any replacement or equivalent national or supra-national authority, and for them to perform their duties and responsibilities
  • to enable us to respond, in the case of any complaint or dispute, and to take legal advice and prosecute or defend any claims
  • in connection with a corporate restructuring, re-organisation or sale of our business or assets
  • in connection with any statutory or other audit of our business
  • to enable us to provide our products and services to you and any joint account holder, continuously, safely and securely.

We may also further process your personal data for any purpose compatible with the above, including:

  • for internal compliance reasons, including to conform with regulation and policy
  • to provide staff training
  • to calculate and pay any transaction related charges, costs, fees or commissions
  • for market research and statistical analysis, including to qualify and keep records of our leads
  • in connection with the use and hosting of our email and of our website
  • in connection with our website, application, network and infrastructure support, maintenance and improvement
  • for business continuity reasons, including for the purposes of electronic back up
  • to protect the security and integrity of our business operations
  • for other internal recording, management and administration purposes
  • for storage, archiving and retrieval.

We may record texts, emails or telephone calls, including for training purposes, customer service, quality control, performance improvement, to verify any comments you or any of our dealers may make during any conversation, for regulatory purposes and for the purposes of fraud or crime prevention and detection.

Consent

Consent is also a lawful basis for our processing of personal data and so, sometimes, we may ask for your permission (called “consent” in the legislation) to process your personal data.

Where this is the case, we will make this clear together with how we might use your personal data should you allow us to do so. If, at the time we ask for it, you choose not to provide us with the requested information or do not consent, then we will not use it in that way.

Even if you do give us permission to use it in that way, you can always withdraw your consent to us doing so at any time. This does not affect the lawfulness of our previous same use of that information with your permission but we will then stop using it in that way.

You can contact us at any time on;

Tel: 0203 384 7280

Email: info@iifx.co.uk

To tell us you wish to withdraw your consent. We may also provide you with other ways for you to withdraw your consent to make it easier for you, such as by an unsubscribe button or other electronic means to alter your preferences.

Please note that if you choose not to give us permission or if you withdraw your consent, this may affect service quality and performance. We may also have to stop providing you with certain services.

Provision of “optional” information

On our website or in our forms, we may indicate where the provision of any information by you is “optional”. If this is the case, it is up to you whether you want to provide us with this information.

If you provide us with optional information, we rely on our legitimate interests to process this information rather than your consent. This may be to help us to better understand you, provide you with a better service, or to assist us with our risk assessment or compliance processes.

If you choose not to provide us with optional information this may affect service quality and performance.

If you choose not to provide us with information in a “required” field, then we may not be able to respond to your request or provide you with our products or services.

Direct marketing

We may carry out direct marketing to you about our products and services. If we do, this is on the basis of our legitimate interests and you have the right to object to our further use of your information for direct marketing by us at any time. If you object, we will then stop doing so.

You can contact us at any time on;

Tel: 0203 384 7280

Email: info@iifx.co.uk

To tell us you wish to object. We may also provide you with other ways for you to object to make it easier for you, such as by an unsubscribe button or other electronic means to alter your preferences.

Please note that if you choose to object to direct marketing, this may affect service quality and performance. We may also have to stop providing you with certain product or services.

We do not pass on any personal data to third parties for the purposes of any direct marketing by them.

Special category personal data

We will not normally process data which the GDPRs describe as “special category” personal data but if we do, we will process it based on your consent, for the establishment, exercise or defence of legal claims or for reasons of substantial public interest on the basis of EU or other law applicable in the United Kingdom.

Cookies

Like most websites, we use cookies to improve your user experience. A cookie is a small text file which is placed onto your computer (or other electronic device) when you visit our website.

You can set your browser not to accept cookies. If you choose not to accept cookies, you may still use our website, however some of our website features and your ability to use some areas may be more limited as a result.

We have a separate Cookies Policy which goes into more detail about the type of cookies we use and our use of them. You can find this here www.iifx.co.uk/cookie-policy. For more information about cookies, please visit our Cookies Policy. You can also find out more information about cookies at www.allaboutcookies.org

From you

Very often we will obtain personal data directly from you, for example, when you speak with one of our dealers, or where you provide your details to us as part of our registration or client on-boarding process, or to enable us to perform identity or verification checks, or further due diligence.

From others

We may also obtain personal data from others, for example:

  • from one of our sales agents or affiliates, such as when we receive a referral or where you have asked them to ask us to contact you because you have expressed an interest in our products or services
  • where our customer is a firm or company, that firm or company may provide us with your personal data, for example where you are a director or shareholder of a company or a named contact or person authorised to enter into transactions on behalf of a company
  • where you are a joint account holder, we may be provided with your personal data by the prime account holder, or vice versa
  • where we perform identity, verification or other checks and we consult with expert third parties
  • where you are the intended recipient of the funds (or “beneficiary”), your personal data may be provided to us by the prime or joint account holder
  • our regulator, government bodies, public authorities or agencies may share personal data with us, for example in connection with an enquiry or investigation.

From a publicly available source

We may also obtain personal data from publicly available sources, such as Companies’ House, the Information Commissioner, and other government websites.

We use the following criteria to determine how long we retain personal data:

We retain personal data

  • for as long as necessary to deal with queries and to fulfil our obligations to our customers, including contract performance.
  • for as long as legal claims might be brought against us or we might need to bring legal claims. This includes after we have performed our contractual obligations and after your account has closed or our service has come to an end.
  • for as long as necessary to meet legal and regulatory requirements. This includes after we have performed our contractual obligations and after your account has closed or our service has come to an end.

Third parties with whom we share personal data will adopt their own criteria.

Who do we share personal data with?

We may share personal data with:

  • our third-party service providers for the purposes of providing services and support to us or helping us to provide our products and services to you, including:
    • to help us respond to your enquiries
    • to help us provide you with our daily update and insights
    • to help us provide you with quotations
    • to facilitate customer registration and on-boarding
    • for the purposes of carrying out risk assessment, due diligence and legal checks, such as anti-money laundering, sanctions and PEP checks and clearances
    • for the purpose of identity and verification
    • to facilitate mandatory reporting
    • in order to make payments
    • to enable our customers to provide us with their feedback
    • in connection with the use and hosting of our email and of our website
    • in connection with our website, application, network and infrastructure support, maintenance and improvement
    • relating to the provision of network and system integrity and security
    • relating to the provision of electronic back up
    • for the purposes of archiving
    • for the purposes of call recording
  • recipient banks, so that payments can be received
  • any subcontractors we may use to help us to provide our products and services
  • our sales agents and affiliates, such as following our receipt of a referral or where you have asked them to ask us to contact you because you have expressed an interest in our products or services
  • our legal and professional advisers, including our auditors, for the purposes of legal advice and auditing
  • our regulator, the Financial Conduct Authority (FCA) or its replacement
  • other relevant government agencies and authorities, including the National Crime Agency (NCA), HMRC, HM Treasury, the Office of Financial Sanctions Implementation (OFSI), the Police, the Office of the Information Commissioner (ICO) and any replacement or equivalent national or supra-national authority
  • the courts, to comply with legal obligations and for the administration of justice
  • anyone else where you have asked us to do so, we have your consent or where we have to do so by law.

Sharing outside of the EEA (“European Economic Area”)

Where we intend to share your personal data outside of the EEA (or “European Economic Area”, which is all the member states of the European Union, together with Norway, Iceland and Lichtenstein), we have a duty to inform you, including about any additional safeguards we have put in place to protect your personal data in cases where the European Commission has determined that the destination country does not have adequate protections in place for the protection of personal data absent other measures.

The list of countries outside of the EEA which the European Commission has deemed as adequate is updated from time to time and available from the European Commission. At the time of publication of this Privacy Policy, twelve additional countries had been included on the list, including the United States (subject to the terms of the US Privacy Shield).

In most cases your personal data is processed by us or our third party service providers on our behalf in the United Kingdom or the EEA but in certain circumstances we or they will transfer personal data to countries outside of the EEA. In each such case, we will require that either the destination country meets the requirements of adequacy or that other appropriate safeguards are put in place, such as by means of a detailed contract between us and the entity based in that destination country or storing its data there, or between us and our third party service provider obliging them to take appropriate measures.

At the time of publication of this Privacy Policy, our systems and infrastructure are based in the United Kingdom and we do not share personal data outside of the EEA or jurisdictions meeting the requirement of adequacy. To our knowledge, based on the enquiries we have made of our third party service providers, they do not do so either.

For example, we share personal data with a third party service provider who provides us with SMS capability for the purposes of ensuring two factor verification in line with requirements on us pursuant to payment services related legislation. The third party service provider is certified under the US Privacy Shield and equivalent applicable to Switzerland. Another example is a third party service provider who provides us with the means to provide our customers with our daily updates. This third party service provider is similarly certified.

Further detail concerning the US Privacy Shield can be found here www.privacyshield.gov  and concerning the requirement for adequacy, together with details of those destination countries which have been deemed adequate by the European Commission, can be found here https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

Where you instruct us to share your personal data with people who you have asked us to deal with, or who you already know, or who already know you, wherever they are based, this will be on the basis of your consent and we will not normally make any further enquiry concerning them, or take any further steps to ensure that your personal data is protected, save to the extent we must do so by law.

If you are the “data subject” (which means the natural person to whom the personal data relates – you do not have these rights in relation to any personal data concerning anyone else or if you are not that person) you have the following rights relating to your personal data:

Rights of request

  • Access: You can ask us for confirmation of whether your personal data is being processed and for a copy of your personal data undergoing processing, provided the provision of it does not adversely affect the rights and freedoms of others.
  • Rectification: You can ask us to correct the personal data we hold about you if it is inaccurate or incomplete.
  • Erasure: You can ask us to erase the personal data we hold about you, for example, on grounds that it isn’t necessary for us to process it any more for the purposes for which it was collected or because it is being processed unlawfully.
  • Objection: You can object to further use of your personal data where we are relying on legitimate interests as the reason for the processing of the data.
  • Restriction: You can ask us to no longer process your personal data for certain purposes for a period of time, for example, where you contest the accuracy of the personal data we hold, or the lawfulness of its processing, or you have objected to its processing on legitimate interests’ grounds. We will still be entitled to store the data.
  • Portability: You can ask us to facilitate the transfer of your data to a replacement service provider (if relevant and where practicable).

You should direct any request to;

Tel: 0203 384 7280

Email: info@iifx.co.uk

Please note that we may not be able to do exactly what you have asked or there may be other steps which you or we need to take before we are able to, or can determine whether we can, meet your request.

In general, we will normally respond to your request either with the action we have taken, or explaining why we will not be taking action, within one month of the receipt of your request. However, sometimes we may have to extend that period and, if this is the case, we will let you know.

Right to object in relation to direct marketing

You can ask us to stop any direct marketing to you at any time.

Where we send any direct marketing to you by email we will make sure that a way to unsubscribe or change your marketing preferences is included in the email. Alternatively, you can contact us at any time on

Tel: 0203 384 7280

Email: info@iifx.co.uk

Right to withdraw your consent

You can withdraw your consent where we have relied upon your permission to perform any processing at any time.

You can contact us at any time on;

Tel: 0203 384 7280

Email: info@iifx.co.uk

To tell us you wish to withdraw your consent. We may also provide you with other ways for you to withdraw your consent to make it easier for you, such as by an unsubscribe button or other electronic means to alter your preferences.

Right to make a complaint

You have the right to complain to the Office of the Information Commissioner (the “ICO”), which is the supervisory authority in relation to data protection law and its enforcement in the United Kingdom.

You may also be entitled to seek compensation in certain circumstances where a breach of the legal requirements for the protection of personal data has occurred.

The ICO

Further details concerning the ICO, its powers and your rights, including your right and how to make a complaint to the ICO, can be found here ICO.

We hope you have found this Privacy Policy helpful.

If you have any questions about this Privacy Policy, please contact our Customer Support Team on;

Tel: 0203 384 7280

Email: info@iifx.co.uk

You can also visit the ICO website at ICO.

Further detail concerning the US Privacy Shield can be found here and concerning adequacy can be found here https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

Please note that we may update our privacy policy by posting a new version on our website and/or providing you with other notice of any specific changes. We recommend you check our website periodically for any changes which may affect you.

Last updated [1 August 2018)

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