1. WELCOME TO OUR PRIVACY POLICY! We respect your privacy and we are committed to protect your personal data. This privacy policy will inform you :
- about how we use your personal data through your use of this website, including any data you may provide us when you purchase a product or service from us or sign up to our communications.
- about your privacy rights and
- how the law protects you.
This privacy policy is provided in a layered format so you can choose the specific areas in which you are particularly interested. Alternatively, you can find a summary here.
2. ABOUT US We are Lycamoney Financial Services Ltd (LMFS), operating under the trading name of ‘Lycaremit’. We provide an online money transfer service. We are authorised by the Financial Conduct Authority (FCA) to provide payment services and issue electronic money.
We are a company incorporated under the Laws of England and Wales with registration number 08662355 and we are based in the UK at Wallbrook Building, 195 Marsh Wall, London, E14 9SG.
LMFS is a data controller and is responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).
3. WHAT DATA DO WE COLLECT? Personal Data is any information about you from which you can be identified. It does not include data where your identity has been removed (it’s called anonymous data).
We may collect, use, store and transfer different kinds of personal data about you and your beneficiary, which we have grouped together as follows:
- Your Identity Data includes your first name, last name, date of birth, gender, nationality.
- Your Beneficiary’s Identity Data includes the recipient’s first name, last name, nationality, gender.
- Your Contact Data includes your email address, contact number, current full address.
- Your Beneficiary’s Contact Data includes the recipient’s current full address and contact number.
- Financial Data includes your bank account, payment card details, bank statements and salary details for the last 3 months. It may also include your beneficiary’s bank account details.
- Transaction Data includes details about your transaction amounts, including their status and top up amounts and purpose of remittance.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform you use to access our website.
- Profile Data includes your username and password, your interests, and preferences.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from LMFS and your communication preferences.
- Customer Care Data includes your correspondences, feedback to us, survey responses for market research purposes and voice mail recordings when you contact us.
Where we need to collect personal data by law and you fail to provide that data when requested, including failing to update your personal data, we may not be able to provide you with the products or services. We may also have to cancel a product or service you have with us but we will notify you if this is the case at the time.
4. HOW DO WE COLLECT YOUR PERSONAL DATA? We use different methods to collect data from and about you including through:
Direct interactions. You may give us your personal data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you do the following:
- Purchase our products or services;
- Create an account on our website;
- Subscribe to our services or communications;
- Request marketing to be sent to you;
- Enter a competition, promotion or survey; or
- Give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies. Please see our Cookie Policy for further details.
5. HOW DO WE USE YOUR PERSONAL DATA? We will only use your personal data when the law allows us to, most commonly, in the following circumstances:
- Where we need your personal data to provide the services in accordance with our terms and conditions.
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
| Purpose | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer | - Your Identity Data
- Your Contact Data
| Performance of services in accordance with terms and conditions |
- To supply products and services to you
- To charge for our products and services
| - Your Identity Data
- Your Beneficiary’s Identity Data
- Your Contact Data
- Your Beneficiary’s Contact Data
- Financial Data
- Transaction Data
| - Performance of services in accordance with terms and conditions
- Necessary to comply with a legal obligation
- Necessary for our legitimate interests (to recover any sums owed to us)
|
To manage our relationship with you and administer your account which will include: - Notifying you about changes to our terms and conditions or privacy policy
- Detecting and preventing crime and fraud
- Asking you to leave a review or take a survey
- Manage any concerns that you raise to our customer care department
- Quality assurance and monitoring purposes
| - Your Identity Data
- Your Contact Data
- Profile
- Marketing and Communications
- Customer Care
- Usage
- Your Beneficiary’s Identity & Contact Data [only in cases of suspicious transactions]
| - Performance of services in accordance with terms and conditions
- Necessary to comply with a legal obligation
- Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services to serve them better)
|
| To enable you to complete a survey for purely market research purposes (non-promotional) | - Your Identity Data
- Your Contact Data
- Profile
- Usage
- Marketing and Communications
| - Performance of services in accordance with terms and conditions
- Necessary for our legitimate interests (to study how customers use our products/services to serve them better)
|
To market products and services to you
To complete a survey (promotional) | - Your Identity Data
- Your Contact Data
- Marketing and Communications
- Profile
| (a) Legitimate interest to process marketing data (to serve our products/services to our customers) and consent for sending electronic marketing communications to new customers or reliance upon an existing customer relationship to send electronic marketing communications |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | - Technical
- Usage
| Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant for clients, to inform our marketing strategy so that we serve our customers with better products and services) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | - Your Identity Data
- Your Contact Data
- Technical
- Usage
- Profile
| Necessary for our legitimate interests (to inform our marketing strategy so that we serve our customers with better products and services) |
Marketing You will receive marketing communications from us either if you have consented to receive them or you have purchased products or services from LMFS, and in each case, you have not opted out of receiving that marketing.
6. HOW CAN YOU MANAGE YOUR MARKETING PREFERENCES? You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by Contacting our Customer Services Department (See contact details below).
You can also Contact our Customer Services Department to let us know whether you’re happy to hear from us by email, text, or telephone.
You can also send us an email at [email protected].
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other purposes.
IP ADDRESSES AND COOKIES We may collect information about your computer, including, where available, your IP address, operating system and browser type for system administration and to report aggregate information to our advertisers. This is statistical data about a user's browsing actions and patterns, and does not identify any individual.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our website and to deliver a better and more personalised service. Cookies enable us:
To estimate our audience size and usage pattern. To store information about your preferences and so allow us to customise our website according to your individual interests. To speed up your searches. To recognise you when you return to our website. You may refuse to accept Cookies by activating the setting on your browser which allows you to refuse the use of Cookies. However, if you select this setting you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse Cookies, our system will issue Cookies automatically when you log on to our website. Please note that our advertisers may also use Cookies, over which we have no control.
7. TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA? We may have to share your personal data with the parties set out below for the purposes explained:
- Affiliated Lyca entity which provides compliance services to LMFS.
- Affiliated Lyca entities which provide call centre support for fulfilment of your orders and clarifying any of your queries.
- External third parties which provide IT technical support services and data centre services.
- Regulators which require reporting of processing activities in certain circumstances.
- Third party which assist the business in conducting ‘Know Your Clients’ checks.
- Third parties whom we have engaged to facilitate the processing of your transactions in the destination countries.
If a change happens to our business where we may choose to sell, transfer or merge parts of our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
Where applicable, we require all external third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
8. WHERE IS YOUR DATA TRANSFERRED TO? Some of our service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguard is implemented:
| Category of Recipient | Location of Recipient | Safeguards in place or lawful ground for processing |
| (1) Technical services provider | India | Model Clauses |
| (2) Affiliated Lyca entity for compliance services | India | Consent |
| (3) Affiliated Lyca entities for call centre support | India | Consent |
| (4) External vendors which facilitate processing of transactions in destination countries | US
Mauritius
Indonesia
Instant Cash Nepal | Performance of terms and conditions |
For those countries where there no appropriate safeguards in place, the EU recognises that these countries do not provide the same level of data protection as provided in the EU. As such, we take steps to ensure your privacy rights are at least as compliant with the requirements of EU law, including by requiring appropriate security measures from such third parties, set out in a contract between us, to protect your personal data.
9. HOW SECURE DO WE KEEP YOUR PERSONAL DATA? We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those staff members or other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority of a breach where we are legally required to do so.
10. HOW LONG DO WE RETAIN YOUR PERSONAL DATA FOR? We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any financial legal requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case, we may use this information indefinitely without further notice to you.
11. WHAT ARE YOUR PRIVACY RIGHTS? Under certain circumstances, you have rights under data protection laws in relation to your personal data which are as follows:
- Access to your personal data - This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Correction of your personal data - This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Erasure of your personal data - This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. - Object to processing of your personal data – This right can be exercised where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Restriction of processing your personal data - This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Transfer of your personal data - This enables you to ask us to transfer your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Note, however, that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
If you wish to exercise any of the rights set out above, please send your request to [email protected].
No fee usually required 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.
What we may need from you 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.
Time limit to respond 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.
12. HOW TO CONTACT US? You may contact our Customer Services Department on 0207 132 0015 or email the Customer Services Department at [email protected].
If you have any questions about this privacy policy, please email us at [email protected].
You have the right to make a complaint at any time to the ICO, the UK’s data protection supervisory authority.
We would, however, appreciate the chance to deal with your concerns first before you approach the supervisory authority, so please do contact us in the first instance.
Changes to the policy This privacy policy applies from 25 May 2018 until such time it is updated again. Historic versions are archived here.
PRIVACY NOTICE
It’s important to us that you understand what personal information we have, how we use it and how you can check and update some of your information. This is why we are providing you with a snapshot of the main points in our privacy policy.
If you would like to read the full policy, you can find it here.
So, what information do we have about you? We have information telling us about who you are, such as your name, address, date of birth and interests. You can find these details in your account.
This is not an exhaustive list, so please read our privacy policy for more information.
Why do we collect your personal information? We keep your information secure and use it to provide you with the products and services you are interested in, help us look after your account, improve our products and services and manage our business. It also helps us to tell you about our new products and services. Financial Regulations require us to keep some information as well.
We collect personal information from you when you sign up with us or contact us and also when you use our products and services, for example, when you register as a LMFS customer to use the Lycaremit products and services, visit our website.
For a detailed explanation of why and how we collect your personal information, please visit our privacy policy.
Who do we share your data with? We may share your information with others who help us run our business and provide you with our services. This could mean sharing your information with others, such as Lyca affiliated companies and third parties for call centre support, compliance services, technical support, regulatory purposes and for facilitating the execution of the payment in the destination countries.
Some of these organisations are based outside the EU. These countries do not provide the same level of data protection as in the EU. Your privacy matters to us. We have implemented appropriate safeguards, where required.
Where there are no appropriate safeguards in place, we have taken steps to ensure your privacy rights are protected, at least in accordance with the requirements of the General Data Protection Regulation in the EU, including requiring appropriate security measures, setting out contractual obligations to protect your personal data and monitoring of compliance.
Please read our privacy policy for more information.
How can you manage your marketing preferences? You can follow the unsubscribe links in any email or text marketing that we send you.
Alternatively, you can call 0207 132 0015 or email the Customer Services Department at [email protected] and you can also let us know whether you’re happy to hear from us by email, text, or telephone.
Visit our privacy policy for more information.