This Privacy Policy ("Notice") describes how eMoney247 Limited collects, stores and uses personal information
("Personal Information") including information about cardholder customers, contacts, suppliers and job
applicants, as well as about visitors to the eMoney247 Limited Website ("our site").
In this Notice, we use the terms "we", "us", and "our" (and other similar terms) to refer to eMoney247 Limited
and "you" and "your" (and other similar terms) to refer to our cardholder customers, contacts, suppliers, job
applicants and site visitors.
This Notice is an important document. We recommend that you read it carefully and print and keep a copy for your
future reference. When you deal with eMoney247 Limited we will assume you agree to the uses of your Personal
Information described in this Notice unless you tell us otherwise in writing.
For general data protection purposes, the data controller is Lerex Technology Ltd of Abacus House, Caxton Place, Cardiff, Wales, CF23 8HA. However, please note that the data controller in relation to any personal data that you provide in relation to your UK issued eMoney247 E-money account is our partner & issuer of e-money, Modulr FS Ltd (Modulr) and for accounts issued in the EEA Modulr Finance B.V. Modulr is an e-money institution, authorised and regulated by the FCA in the UK and De Nederlandsche Bank (Relatienummer R182870) in the EEA. Modulr’s registered office address is Scale Space, 58 Wood Lane, London, United Kingdom, W12 7RZ.
If you have any questions about how we collect, store and use Personal Information, then please contact us using the following contact details: Write to us at: eMoney247 Limited, New Broad Street House, 35 New Broad Street, London, England, EC2M 1NH, help@emoney247.co.uk.
eMoney247 Limited is a boutique payment solution that offers digital wallets and a payments platform that facilitates solutions for established international businesses. It can provide financial services such as multi-currency accounts along with foreign exchange (FX) services. The platform enables customers to accept payments from around the world, make payments to suppliers, employees or even make remittances globally by transacting in multiple currencies through our FX providers.
Depending on how you engage with us, we will collect and process the following data about you:
(a) Information that you provide voluntarily.
If you are an employee or other staff member of a eMoney247 Limited, supplier or partner: We will use the
personal and/or professional contact details, professional title and if necessary, identity documents that we
ask you to provide for the purposes of carrying out customer due diligence and KYC checks, managing invoicing
and/or payments and corresponding with our corporate customer, supplier and/or partner in connection with the
applicable services. We may also keep your contact preferences, such as requests to subscribe to publications
that we may circulate from time to time, to receive news about any events we are organising or participating in,
or to receive information about eMoney247 Limited and the services we provide.
If you are a site visitor: We will use any information that you provide by filling in forms on our site. This
includes information provided at the time of registering to use our site, subscribing to our service, posting
material or requesting further services. We may also ask you for information when you report a problem with our
site.
If you write to us: We will keep a record of that correspondence.
If you complete any of our surveys: We will use your responses for research purposes.
If you are a job applicant: We will use your contact details, copies of your job application, curriculum vitae
and covering letter, as well as any references provided, for the purposes of processing your application and for
general recruitment and selection purposes.
(b) Information that we collect automatically
If you are a eMoney247 Limited customer, we will automatically collect information about the transactions that
you make using your eMoney247 Limited card, your card number, transaction amount transaction date, merchant name
and any details about applicable chargebacks in connection with our provision of card issuing and settlement
services in relation to the programme.
If you are a site visitor: We will collect, store and use certain, limited information relating to your use of
the eMoney247 Limited for the purposes of better understanding the types of visitors who browse our site and
improving our site offering. Specifically, the information we collect automatically may include information like
your IP address, device type, unique device identification numbers, browser-type, broad geographic location
(e.g. country or city-level location) and other technical information. We may also collect information about how
your device has interacted with our site, including the pages accessed and links clicked. Collecting this
information enables us to better understand the visitors who come to our site, where they come from, and what
content on our site is of interest to them. We use this information for our internal analytics purposes and to
improve the quality and relevance of our site to our visitors. Some of this information may be collected using
cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking
technology” below.
(c) Information that we obtain from third party sources
If you are a eMoney247 Limited cardholder customer of one of our partners we may receive from the applicable
partner your name, address, DOB, email address, mobile number, IP address of sign up location, bank account
details, eMoney247 Limited card details and any and all other supporting documents that may be required (i.e.
including utility bills) for the purposes of carrying out appropriate customer due diligence to enable us to
comply with our anti-money laundering obligations. We may also receive information from you via third party
fraud prevention and credit reference agencies or other organisations involved in the support or provision of
your card and the associated services.
Depending on how you engage with us, we will use your information for the following purposes:
For communication purposes: We use information and preferences to communicate with our Partners and suppliers
and to send publications that we may circulate from time to time, news about any events we are organising or
participating in, and/or other information about eMoney247 Limited and the services that we provide. We will
only contact you in accordance with the contact preferences that you have specified (which may include e-mail)
and will not send you marketing communications where you have told us you do not wish to receive these. You can
specify your contact preferences when registering online to receive communications from us (for example, through
the eMoney247 Limited) or by subsequently advising us of your contact preferences using the contact details
provided above.
To provide our card services to Partners (our customers) and cardholders engaged by our Partners: We will use
Personal Information to provide our services to our Partners, for example, opening, administering and running
cardholder card accounts (including using mobile phone numbers and email addresses to provide balance updates
and transaction alerts in the manner requested by our customers), facilitating settlement and reconciliation of
the cardholders accounts, carrying out due diligence checks and transaction monitoring for compliance with
anti-money laundering obligations and Mastercard scheme requirements and dealing with any cardholder customer
enquiries.
To receive services from our suppliers: We will use our suppliers Personal Information to receive their services
from them. Please note that we will assume, unless our suppliers instruct us otherwise in writing, that we may
use and disclose their Personal Information in such manner as we believe is reasonably necessary to receive and
to review the provision of those services from them.
To collect our charges or costs in connection with other legal enforcement: We will use Personal Information to
agree payment arrangements with you, and to collect our fees and costs owing to us in connection with legal
enforcement.
To manage our supplier relationships: We will use our suppliers Personal Information to agree payment
arrangements with our suppliers, and to make payments to them.
For recruitment and selection purposes: If you apply for a position with eMoney247 Limited, we will use your
Personal Information to process your job application and for general recruitment and selection purposes. If you
are successfully recruited, the Personal Information you provide will be stored on your personnel file.
For monitoring and quality assurance purposes. We may monitor telephone and e-mail communications between our
employees and third parties for the purpose of quality assurance and training or as otherwise permitted by
law.
For site analytics purposes: We may collect, store and use certain, limited information relating to your use of
our site for the purposes of better understanding the types of visitors who browse our site and improving our
site offering. Other than information you choose to submit voluntarily to receive communications from eMoney247
Limited (as described in the "If you are a contact of eMoney247 Limited bullet above), the information we
collect about site visitors does not enable any visitor to be individually identified, is processed only in
anonymised, aggregated form, and will only be used for site analytics purposes as described in our Cookies
Notice.
You have the following data protection rights, subject to certain exemptions and satisfying certain conditions:
If you wish, to access, correct, update or request deletion of your Personal Information, you can do so at any
time by contacting us using the contact details provided under the “How to contact us” heading above eMoney247
Limited.
In addition, you can object to processing of your Personal Information, ask us to restrict processing of your
personal information or request portability of your personal information. Again, you can exercise these rights
by contacting us using the contact details provided under the “How to contact us” heading above eMoney247
Limited.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right
by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other
forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details
provided under the “How to contact us” heading above help@emoney247.co.uk.
Similarly, if we have collected and process your Personal Information with your consent, then you can withdraw
your consent at any time.
Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal,
nor will it affect processing of your personal information conducted in reliance on lawful processing grounds
other than consent. Again, you can exercise these rights by contacting us using the contact details provided
under the “How to contact us” heading above help@emoney247.co.uk.
You have the right to complain to a data protection authority about our collection and use of your personal
information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in
accordance with applicable data protection laws.
We may disclose your Personal Information with the following categories of recipients:
Group companies, business partners (i.e. our Partners), service providers and other affiliated third parties:
who provide data processing services to us (for example, to support the delivery of our site or due diligence
services), or who otherwise process personal information for purposes that are described in this Privacy Policy
or notified to you when we collect your personal information. A list of our current group companies is available
here and a description of the categories of the current service providers we work with is available here.
To any competent law enforcement body, regulatory, government agency, court or other third party: where we
believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or
defend our legal rights, or (iii) to protect your vital interests or those of any other person.
To an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed
purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your
personal information only for the purposes disclosed in this Privacy Policy.
To any other person with your consent to the disclosure.
Our legal basis for collecting and using the personal information described above will depend on the personal
information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only
(a) where the processing is in our legitimate interests and not overridden by your rights,
(b) where processing is necessary to fulfil a contract with you (such as your prepaid card contract if
applicable),
(c) where processing is necessary to fulfil a contract with merchants that we work with, or
(d) we have your consent to do so. In some cases, we may also have a legal obligation to collect personal
information from you or may otherwise need the personal information to protect your vital interests or those of
another person (e.g. our legal obligation to carry out appropriate customer due diligence and anti-money
laundering checks).
If we ask you to provide personal information to comply with a legal requirement or to perform a contact with
you, we will make this clear at the relevant time and advise you whether the provision of your personal
information is mandatory or not (as well as of the possible consequences if you do not provide your personal
information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third
party), this interest will normally be to provide our services to you and for our legitimate commercial
interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for
the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if
appropriate we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use
your personal information, please contact us using the contact details provided under the “How to contact us”
heading above help@emoney247.co.uk.
We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Statement.
As described above, from time to time, eMoney247.co.uk may need to transfer your Personal Information to
business partners, service providers and other eMoney247 Limited offices that are located in territories outside
of the European Economic Area ("EEA").
Please note that the legal regimes of some territories outside of the EEA do not always offer the same standard
of data protection as those inside the EEA, although we will ensure that your Personal Information is only ever
treated in accordance with this Notice and, if you are a customer, our terms and conditions.
We have in place what we believe to be appropriate technical and organisational security measures to protect
your Personal Information against unauthorised or unlawful use, and against accidental loss, damage or
destruction. We put in place strict confidentiality agreements (including appropriate data protection
obligations) with our third-party service providers. The measures we use are designed to provide a level of
security appropriate to the risk of processing your personal information.
If you or others on your behalf give us any Personal Information about another person, you take full
responsibility for complying with any relevant data protection laws which apply to the provision of that
information to us, and our use of it as explained in this Notice.
We retain Personal Information where we have an ongoing legitimate business need to do so (for example, to
provide you with a service you have requested or to comply with applicable legal, tax or accounting
requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or
anonymise it or, if this is not possible (for example, because your personal information has been stored in
backup archives), then we will securely store your personal information and isolate it from any further
processing until deletion is possible.
We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.
You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of online Privacy Policy.