This policy (and any documents referred to in it) sets out the basis on which we process data about individuals including anyone who visits our website (“Website Visitors”).
We gather data about Website Visitors from our website.
We collect data from Website Visitors in two main ways: (1) the data that you give to us on any forms on the website; and (2) the data we collect about you using cookies and similar technologies (see below).
The categories of data that we collect about you include your first name, last name, email address, phone number and survey data such as how much (in currency transfers) do you transfer per year and at what frequency, ‘currency pairs of interest’, and whether you would like a service allowing you to convert at an exchange rate of your choice and earn interest.
The lawful basis for this processing of data is that you have either consented for us to process it or it is within our legitimate interest to collect information about customers who may be interested on our products and communicate with them and market directly to them.
Duality Banx does not collect any “Special Categories of data” that could reveal information such as racial or ethnic origin, sexual orientation, political opinions physical or mental health, religious or philosophical beliefs, trade union membership or genetic or biometric data).
We may disclose your personal data, in various ways and for various reasons, with the following categories of people:
Duality Banx may need to transfer your information globally. We want to make sure your information is stored and transferred in a way which is secure. We will therefore only transfer data outside for the European Economic Area (“EEA”) (i.e. the member states of the European Union, together with Norway, Ireland and Liechenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:
We only keep your information for as long as it is necessary to fulfil the purpose for which it was collected.
We use the following criteria to determine how long we need to keep your data:
We will use technical and organisational measures to safeguard your information, for example we rely on the security measures provided by G-Suite, AWS and we use password protection where necessary.
We have outlined below the individual cookies we use and why we use them:
|Cookie Name||Expiry Period||Purpose||More Information|
|ga||2 years||Used by Google Analytics to distinguish users.||Google Analytics Cookie Usage|
|_gat||10 minutes||Used by Google Analytics to throttle request rate.||Google Analytics Cookie Usage|
Our platform and website may contain links to and from the online properties of third parties. If you follow a link to any of these online properties, please note that these online properties have their own privacy policies and that we cannot and do not accept any responsibility or liability for these policies or for any personal data that may be collected through these online properties. Please check these policies carefully before you click on any links and/or submit any personal data to these online properties.
You have the following rights in relation to your information:
If you would like to request any of the above, please contact us at firstname.lastname@example.org to make any such requests. We will comply with the Data Protection Legislation in responding to any such requests.
If you have any complaints about the way in which we collect, store and use your information, you can contact the supervisory authority in the United Kingdom, the Information Commissioner’s Office: https://ico.org.uk/concerns
Policy last updated: July 1st 2019