Privacy Policy

We collect and process your personal data in accordance with applicable data protection law. This privacy notice sets out how we process your personal data and your rights in relation to that processing.

At Fayzano, we take data privacy seriously. This privacy notice forms a framework for the processing of data, and may be supplemented by terms in specific agreements we have with you. If you have any questions about how we protect and use your data, or if any terms in this privacy notice are unclear, please contact us at data.protection@fayzano.com.

1. Who we are
Fayzano is a private limited company in England and Wales (company number: 13065727) with its head office and registered address at Suite 212 Rex House, 354 Ballards Lane, London, England, N12 0DD.
Fayzano is a Small Payment Institution registered by the Financial Conduct Authority (firm reference number: 944414). If you want to know more about our permission to provide payment services, please, visit the Financial Services Register available at https://register.fca.org.uk. We are registered with the Information Commissioner’s Office (ICO) under number ZB284505.
You can always contact us via the Platform or by emailing us at info@fayzano.com

2. Data that we collect and process
2.1 Information provided to us
When you sign up for our products or services, you may provide us with personal information such as your name, phone number, and email address. In order to verify the information you provide, we may also require corresponding documents. Your use of our products or services may also provide us with additional information about you.
Please ensure that you have obtained consent from any individuals whose personal information you supply to us. By providing us with such information, you warrant that you have informed them of our intended use for the data and that they have consented to its transfer.

2.2 Information that we automatically collect
We automatically collect certain information about you when you use our products or services. This includes data about:

• Payments you initiate and receive, including the payment counterparty’s full name, time, amount, currencies used, exchange rate, address and purpose of the payment;
• Interaction and technology, which includes data such as your IP address, geolocation, device information, unique device identifier, login information, and information about your interactions with our products and services, such as scrolling and clicks. We also monitor page response times and download errors.
• Visit information, if you physically enter our premises we may have CCTV in operation and record your visit.

2.3 Information received from third parties 

We may receive information from third-party providers that we use to provide products or services or to ensure that we comply with our legal obligations. This includes reports from identity verification, transaction monitoring, and fraud prevention solution providers.

2.4 Sensitive data
At times, we may need to process sensitive data. This includes information about race, ethnicity, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), and sexual orientation. We may receive this information as part of our identification and verification process, while screening the identification documents you provide to us, and on an ongoing basis while we provide our products or services.

2.5 Children’s data
We do not knowingly request to collect personal information from any person under the age of 18. If we are made aware that you are suspected to be younger than 18 years of age, we will not allow you to apply to use our products or services.

3. How we protect your personal information
We have put in place measures to protect your personal data from being lost, used or accessed in an unauthorised way. We limit access to your data only to those who need it to do their job. 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. If we believe that your data has been compromised in any way, we will notify you and any applicable regulator as soon as possible.

4. How we use your information
We use your information in instances that require the processing of your information. Such instances include the following:

• to enter into an agreement or carry out our obligations under the agreement concluded with you;
• to notify you about changes to our products or services;
• to comply with any applicable legal and/or regulatory obligations;
• to ensure the safety and security of the products or services;
• to administer products or services and for operational purposes, including data analysis, testing, troubleshooting, research, statistical and survey purposes;
• to improve our products and services;
• to allow you to participate in interactive features of our products or services;
• to provide you with information about other similar products and services we offer.

5. Legal basis for processing
Whenever processing your data we only do so in accordance with an appropriate legal basis. We will not process your data without having legitimate grounds in doing so. The legal bases on which we rely are as follows:

• Consent- it is explicit consent under which you allow us to process your data. We rely on consent when you enter into a promotional survey or subscribe to marketing offers.
• Contractual performance- it is either an existing agreement that is entered between you and us or a future agreement for entering into which we need to process your data. We rely on contractual performance when we process the information that is required to enter into a contractual arrangement with you or when we have entered into a contractual arrangement and processing is required to exercise our rights or fulfil our obligations.
• Compliance with a legal obligation- it is a common law or statutory obligation for compliance with which we need to process your data. The processing of your personal data will be carried out in instances when we need to do so to fulfil our legal obligations such as compliance with anti-money laundering or counter-terrorist financing legislation.

6. Data sharing
We may share your personal information with other companies in order to provide products and services you have requested or to comply with our legal obligations. This sharing will be limited to those companies that are reasonably required to receive your information in order for us to be able to provide our services or products. Whenever sharing such information with them we take precautions to safeguard your data by using appropriate security measures. The third parties include:

• Fraud monitoring and identity verification service providers;
• Payment service providers and technical and non-technical processors;
• Information technology and cybersecurity service providers;
• Third parties who offer complementary services to our services or products;
• Governmental agencies and regulatory authorities;
• Other organisations allowing to provide services to you.

We do not have a list of all third parties we share your data with, as this would be dependent on your specific use of our products or services. However, if you would like further information about who we have shared your data with, or to be provided with a list specific to you, you can request this by writing to data.protection@fayzano.com.

7. Transfers of data
We may transfer and store your data at a destination outside the United Kingdom. It may also be processed by staff operating outside the United Kingdom who work for us or for one of our business partners or third-party service providers. By submitting your personal data, you agree to such transfer, storing and processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy while ensuring that there are appropriate safeguards in place to ensure such security.

8. Profiling and automated decision making
Our company sometimes uses profiling and automated decision making in order to provide our customers with exceptional service within a short time frame and comply with our legal obligations. When we do so, we take all reasonable measures that your data would be secure and employ pseudonymisation where possible.

9. Data Retention
We retain data for no longer than it is necessary and erase the information as soon as it is possible. Generally, we retain information about you for 5 years after the last transaction or end of our relationship with you, whichever occurs last. Furthermore, we retain transaction data of all current clients for a period of 10 years from the time when the transaction took place. These periods are subject to our legal obligations and in certain instances when we are obliged by law we will retain your information for either a shorter or longer period of time.

10. Your rights
Data protection legislation (General Data Protection Regulation and complementary legislation) offers you certain rights related to your data. These rights are not absolute and may be subject to exceptions. Nevertheless, they can be summarised as follows:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. 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.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove 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 where we are relying on a legitimate interest (or those of a third party) 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.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  – If you want us to establish the data’s accuracy.
  – Where our use of the data is unlawful but you do not want us to erase it.
  – 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.
  – You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of 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 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.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You will not have to pay a fee to access to exercise any of the abovementioned rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it could 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 accordingly and keep you updated.

11. Changes to our privacy notice
From time to time, to follow the changes to the market practices and applicable legislation, we may update this privacy notice. In such a case the updated privacy notice will be published on this page http://www.fayzano.com/privacy. We will inform you of any corresponding changes if so required. Nevertheless, you should visit this page from time to time to check whether any changes have taken place.

12. Cookies
We use small files (known as cookies) to distinguish you from other users, see how you use our site and products while providing you with a better experience. You can set your cookie preference (i.e. accept and reject certain types of cookies) upon visiting our website and thereafter periodically. Furthermore, you can change your preferences by visiting the following page http://fayzano.com/cookies or by changing your browser settings. If you disable or refuse cookies, please note that some parts of our website, web or mobile application may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy at http://fayzano.com/cookies.

13. How to raise concerns
In case you have any questions or would like to raise any concerns regarding our data processing practices or this privacy notice you can always write to us at data.protection@fayzano.com. We will try to respond to you in a timely manner and resolve any queries that you have.

Furthermore, you have the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.