Privacy Policy

UK First Fintech Limited (hereinafter “First Fintech”) is a company incorporated in England and Wales (company number: 11972677); its registered place of business is 3rd Floor, The News Building, 3 London Bridge Street, London, United Kingdom, SE1 9SG.

UK First Fintech Limited is an Authorised Electronic Money Institution. Its activities license (Reference number: 901002) can be found on the Financial Conduct Authority of the UK (hereinafter FCA) webpage.

The FCA exercises supervision over UK First Fintech Limited. Contact details of the FCA and the list of Authorised Electronic Money Institutions maintained by FCA are available at FCA’s webpage register.fca.org.uk.

Overview

First Fintech has developed this Privacy Policy (“Policy”) in compliance with the Data Protection Act (the “DPA”) and according to the General Data Protection Regulation (GDPR) to explain the ways we may collect, process, store, share and transfer your personal data through our services and via our online presence, which includes the website www.firstfintech.co.uk (“our website”). We are committed to protecting and respecting your privacy. This Policy provides information on how we use personal data, with whom we share it, your rights and choices, and how you can contact us about our privacy practices. This policy does not apply to any third-party websites, their products or services, even if they link to our services or site.

This Policy (together with our Terms and Conditions and Cookie Policy) constitutes the basis on how any personal data collected by us will be processed. Please read the following carefully to understand our views and practices regarding your personal data. By using our services or visiting our website you are accepting and consenting to the practices described below.

Information provided by you

You may provide us information about you in various ways – filling in electronic forms on our website or contacting us via phone (including the mobile app), e-mail or otherwise. This includes any information provided by you when submitting application to open an account, subscribing to our service, searching for a product or service on our website or reporting on a problem on our site. The information you provide us may include:

• your name;
• birth date;
• physical appearance (photo/video);
• address;
• passport/ID details (including image);
• contact details (e-mail address, phone number, website);
• credit card or other financial information;
• personal description;
• information regarding your business;
• information on the representatives, officers and shareholders of your business (including information/data mentioned above).

By submitting any application, you confirm that you are authorised and have the necessary consents to disclose the personal data provided in the application to us. We shall not be liable for any claim brought by any individual arising from an act or omission resulting from your failure to ensure that the lawful transfer of personal data.

Information we collect about you

Every time you visit our website, we may automatically collect the following:

• The Internet Protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, browser plug-in types and versions, operating system and platform and other technical data;
• information about your visit like Uniform Resource Locators (URL) clickstream to, through and from our site; products, services or other information viewed or searched for; page response, interaction statistics and logs, including errors, and methods used to browse away from the page and any phone number used to call us.

We also may collect information about online activity on our website and connected devices over time and across third-party websites, devices, apps and other features and services.

Cookies

Our website uses cookies to distinguish visitors of our website. This helps us to provide you with a good and quality service when you browse our website and allows us to improve our website. For more detailed information on cookies, please refer to our Cookie Policy.

Use of the received and collected information

We may use the information about you in the following ways:

Information you provide to us

We may use this information:

• to evaluate any applications to receive our services, provide you with the services as stated in contracts between you and us and to provide you with the information, products and services that you request from us;
• to enable fraud protection and risk management processes such as checking third party sanctions lists and other databases to ensure that you are eligible to receive our services;
• to monitor, prevent and detect unauthorised payment transactions;
• to comply with our legal and compliance obligations;
• to respond to enquiries, send service notices and provide customer support;
• to provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about;
• to provide you with information about other products or services that may interest you;
• to inform you about any changes to our services; and
• to ensure that the content of our website is presented in the most convenient manner for you.

Information we collect about you

We will use this information:

• to administer our website as well as for internal operations (troubleshooting, testing, research, data analysis, a.o.);
• to improve the content on our website and make sure it is presented in the most convenient manner;
• to keep the website safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
• to make suggestions and recommendations to visitors of our website about products or services that may be of interest.

Disclosure of your information

Your personal data may be shared with any member of our Group, which means affiliated companies, subsidiaries, owners and their subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may also share your personal data with third parties including:

• Business partners including subcontractors for the performance of any contract we enter into with them or you.
• Advertisers that need the data to select and serve relevant adverts to you and others.
• Analytics and search engine providers that assist us in the improvement and optimisation of our site.
• Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

We may disclose your personal information to third parties:

• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and/or other agreements; to protect the rights, property, or safety of First Fintech, our clients, business partners, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• To respond to requests from courts, law enforcement, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
• In the event sale or purchase of any business or assets by our Group, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If First Fintech or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

Storage of data

First Fintech maintains various security measures designed to provide reasonable protection for your personal data against loss, misuse, unauthorised access, disclosure, and alteration. The security measures include firewalls, data encryption, information access authorisation and physical access controls to our data centres. Your personal data is accessible to a limited number of personnel to perform their duties.

We are dedicated to securing our systems and services and are constantly improving them, you are responsible for securing and maintaining the privacy of your password(s) and account/profile information and verifying that any personal data we maintain about you is accurate and up to date. We ask you not to share a password with anyone. We are not responsible for protecting any personal data that is with a third-party based on an account connection that you have authorised. This If you have reason to believe that that the security of your account has been compromised, please contact us immediately.

We cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features for unauthorised access prevention.

We retain your personal data as long as we are providing our services to you and retain personal data after we cease providing services to you, even if you close your account, to the extent necessary to comply with our legal and regulatory obligations, including tax, accounting, and financial reporting, fraud monitoring, detection and prevention, we are required to retain the data by our contractual commitments, and where data retention is mandated by the payment methods that we support.

Your rights

You may limit or restrict our use and disclosure of your personal data and we will try to comply with your request as soon as reasonably practicable.

Opting out of electronic communications

In case you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. Please note that while you may opt-out of receiving marketing-related emails from us, we may still send you important messages or notifications that are required to provide you with our services and for First Fintech to comply with laws and regulations.

Updating your account personal data

We encourage you to review, correct, or update personal data that you have previously disclosed to us in order to keep it up to date, you may do so by signing in to your First Fintech account or by contacting us.

Data protection rights

Depending on your location and subject to laws and regulations, you may have the following rights with regard to the personal data we control about you:

• The right to request confirmation of whether First Fintech processes any personal data relating to you, and to request a copy of that personal data; ask to change or update data that is inaccurate, incomplete or outdated or to erase or restrict the use of your personal data in certain circumstances provided by law;
• The right to request that we export to another company, where technically feasible, your personal data that we hold in order to provide our services to you.

Where the processing of your personal data is based on your previously given consent, you have the right to withdraw your consent at any time. You may also have the right to object to the processing of your personal data on grounds relating to your particular situation.

In order to exercise your data protection rights, you may contact First Fintech as described in the Contact Us section below. We take each request seriously. We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your personal data.

For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process personal data about you in order to provide our services, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.

If you are a customer of a First Fintech client (“Client”), please direct your requests directly to the Client.

Access to information

You have the right to access information held about you. Your right of access can be exercised in accordance with the applicable legislation. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.

International data transfers

First Fintech is a global business. Therefore, your personal data may be stored and processed in any country where we have operations or where we engage service providers. We may transfer your personal data that we maintain about you to recipients in countries other than the country in which the personal data was originally collected, including to the United States. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your personal data remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal data.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Links to other websites

Our website 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 or liability for these policies. Please check these policies before you submit any personal data to these websites.

Contact

If you have any questions regarding our Privacy Policy, please contact us by email at privacy@firstfintech.co.uk.