1. BACKGROUND:

The privacy and confidentiality of the Sender’s personal and business data is very important to Access Finance. Below is a summary of how Access Finance collects, uses, communicates and discloses and makes use on the information gathered. Information will be collected by lawful and fair means and where appropriate, with the knowledge or consent of the Sender. Access Forex undertakes to protect personal and trade information by reasonable security safeguards against loss or theft, as well as unauthorised access, disclosure, copying, use and modification. Access Finance will make readily available to customers information about policies and practices relating to the management of personal and trade information. It is important to ensure trust by being transparent about how the Sender’s information is used. Access Finance is committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal trade information in protected and maintained. Data that is collected via the usage of the Service is stored in a secured data base. It is used for the sole purpose of providing for the Service by Access Finance.

Access Finance takes your privacy very seriously. Please read this Privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We respect and value the privacy of all our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

2. INFORMATION ABOUT US:

Access Finance, a private company registered in the United Kingdom under company number 2015/146574/07. We are an Authorised Dealer with Limited Authority regulated by the Bank of England and the Financial Services Conduct Authority.

Registered address: Kings Court, London Road, Stevenage, Hertfordshire, England, SG1 2NG

Email address: info@accessforex.com Telephone number: 08708 200 854

3. WHAT DOES THIS NOTICE COVER?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

4. WHAT IS PERSONAL DATA?

Personal data is defined by the Data Protection Act of 2018, in particular Section 1 as any data that can be used to identify a living individual. This relates to information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. The personal data that we use is set out in Part 5, below.

5. WHAT ARE MY RIGHTS?

Under the Data Protection Act, you have the following rights, which we will always work to uphold:

• the right to be informed about the collection and the use of their personal data
• the right to access personal data and supplementary information
• the right to have inaccurate personal data rectified, or completed if it is incomplete
• the right to erasure (to be forgotten) in certain circumstances
• the right to restrict processing in certain circumstances
• the right to data portability, which allows the data subject to obtain and reuse their personal data for their own purposes across different services
• the right to object to processing in certain circumstances
• rights in relation to automated decision making and profiling
• the right to withdraw consent at any time (where relevant)

the right to complain to the Information Commissioner For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11. It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the following link https://www.gov.uk/government/publications/data-protection-rights-for-data-subjects/data-protection-rights-for-data-subjectsIf you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Officehttps://www.gov.uk/data-protection/make-a-complaint http://www.justice.gov.za/infore. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.

6. WHAT PERSONAL DATA DO YOU COLLECT AND HOW?

Depending upon your use of our services on our site or through our mobile applications, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect personal data relating to children or data relating to criminal convictions and/or offences.

We collect most of this personal information directly from you—in person, via our website and apps and/or by telephone, text or email. However, we may also collect information:

• from publicly accessible sources, e.g. Department of Home Affairs, South Africa directly from a third party, e.g.: sanctions screening providers, credit reference agencies, customer due diligence providers;
• from cookies on our website
• via our IT systems: automated monitoring of our websites and applications other technical systems, such as our communications systems, email and instant messaging systems.

7. HOW DO YOU USE MY PERSONAL DATA?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will use your personal data, and our lawful bases for doing so:

• Administering our business.
• Supplying our products and services to you. For the performance of our contract with you or to take steps at your request before entering into a contract
• Managing payments for our products and services. For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for us and for you.
• Personalising and tailoring our products and services for you. For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price.
• To prevent and detect fraud against you. To comply with our legal and regulatory obligations.
• Communicating with you. To comply with our legal and regulatory obligations.
• Supplying you with information by email and/or post or text messages that you have opted-in-to you may optout at any time by sending an email to: or an SMS to:  or clicking on the option on our website to opt out. To comply with our legal and regulatory obligations.
• Checking your information against sanction screening list. To comply with our legal and regulatory obligations.

With your permission and/or were permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or text message with information, news, and offers on our products services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Electronic Communication and transactions act as well as the Consumer Protection Act, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time. We use the following automated systems for carrying out certain kinds of decision-making and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 11. The following automated decision-making method(s) may be used: sanctions screening. The following automated profiling may take place: use of our website, apps and services or products.

We will only use your personal data for the purposes for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purposes and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 12. If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purposes for which it was originally collected, we will inform you and explain the legal basis which allows us to do so. In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

8. HOW LONG WILL YOU KEEP MY PERSONAL DATA?

We will keep your personal information while you have an account with us or we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf.
• to show that we treated you fairly.
• to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

9. HOW AND WHERE DO YOU STORE OR TRANSFER MY PERSONAL DATA?

We will normally only store or transfer your personal data within the United Kingdom. This means that it will be fully protected under the Data Protection Legislation. We may however sometimes need to share your data within the group of companies of which we are a part to enable scanning and prevention of fraud, following up on queries or enabling a transaction. Where this involves the transfer of personal data outside of United Kingdom, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the following link   https://www.gov.uk/data-protection .

If we share your personal information for the reasons outlined above, we may transfer some or all of your personal data across borders. The countries to which your personal day may be transferred are known as “third countries” and may not have data protection laws that are as strong as those in South Africa. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within South Africa and under the Data Protection Legislation as follows:

• we will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the Information Commissioner. More information is available from the Information Commissioner.
• and we use specific contracts with external third parties that are approved by the Information Regulator for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation.

Please contact us using the details below in Part 12 for further information about the data protection mechanisms used by us when transferring your personal data to a third country. The security of your personal data is essential to us, and to protect your data, we take several important measures, including the following:

• your personal information is encrypted when transferred or stored.
• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality.
• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Regulator’s Office where we are legally required to do so.

10. DO YOU SHARE MY PERSONAL DATA?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority. We may share your personal data with other companies in our group for enabling the transaction, following up on queries, monitoring fraud. We may sometimes contract with the following third parties to supply insurance products and remittance services.

Recipient	Activity Carried Out	Sector	Location
Insurance Provider	Underwriting	Insurance	United Kingdom
Payment Service Providers	Processing of transactions	Financial and mobile money services	United Kingdom and the country to which money is remitted by you.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third partysʼ obligations under the law, as described above in Part 8. If any personal data is transferred outside of the United Kingdom, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the United Kingdom  and under the Data Protection Legislation, as explained above in Part 8. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11. HOW CAN I ACCESS MY PERSONAL DATA?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12 request as quickly as possible.

There is not normally any charge for a subject access request. If your request is manifestly unfounded or excessive (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within less than one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

12. HOW DO YOU USE COOKIES?

Our website and applications may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience website and applications and to provide and improve our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and always respected.

All Cookies used by and on our website and applications are used in accordance with the current Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 (“Cookie Law”) Before Cookies are placed on your computer or device, you will be shown a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our website and applications may not function fully or as intended.

Certain features of our website and applications depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that our website and applications may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them. In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

13. HOW DO I CONTACT YOU?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of Access Finance Information Officer:

Registered address:  Kings court Road Stevenage Hertfordshire, England SG1 2NG

Email address: info@accessforex.com

Telephone number: +44(0)1438 878 862

14. CHANGES TO THIS PRIVACY NOTES

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be made available on our website or via our mobile applications Access Finance. This Privacy Notice was last updated on