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Privacy Policy
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This privacy policy applies between you, the User of this Website and Verge Capital Limited, the owner and provider of this Website. Verge Capital Limited takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

Please read this privacy policy carefully.

Definitions and interpretation

Data collectively all information that you submit to Verge Capital Limited via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws; Data Protection Laws any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK; GDPR the General Data Protection Regulation (EU) 2016/679; Verge Capital Limited is a limited liability company incorporated in England and Wales (RC 13223057), with registered offices at Digital World Centre, 1 Lowry Plaza, The Quays, Salford, UK M50 3UB.

User or you any third party that accesses the Website and is not either (i) employed by Verge Capital Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Verge Capital Limited and accessing the Website in connection with the provision of such services; and the website that you are currently using, https://joinverge.com/contact/, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

In this privacy policy, unless the context requires a different interpretation:

the singular includes the plural and vice versa; references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy; a reference to a person includes firms, companies, government entities, trusts and partnerships; “including” is understood to mean “including without limitation”;

reference to any statutory provision includes any modification or amendment of it;

the headings and subheadings do not form part of this privacy policy.

This privacy policy applies only to the actions of Verge Capital Limited and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

For purposes of the applicable Data Protection Laws, Verge Capital Limited is the “data controller”. This means that Verge Capital Limited determines the purposes for which, and the manner in which, your Data is processed.

Data collected

We may collect the following Data, which includes personal Data, from you:

name;

date of birth;

gender;

profession;

contact Information such as email addresses and telephone numbers;

financial information such as credit / debit card numbers;

IP address (automatically collected);

operating system (automatically collected);

in each case, in accordance with this privacy policy.

How we collect Data

We collect Data in the following ways:

data is given to us by you ; and data is collected automatically. Data that is given to us by you.

Verge Capital Limited will collect your Data in a number of ways, for example:

when you contact us through the Website, by telephone, post, e-mail or through any other means; when you register with us and set up an account to receive our products/services; in each case, in accordance with this privacy policy.

Data that is collected automatically

To the extent that you access the Website, we will collect your Data automatically, for example:

we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and i

includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

Our use of Data

Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

Products and services; in each case, in accordance with this privacy policy.

We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).

When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

Who we share Data with

We may share your Data with the following groups of people for the following reasons:

any of our group companies or affiliates – To credit check before approval;

third party service providers who provide services to us which require the processing of personal data – To ensure that AML requirements are met;

relevant authorities – If the authorities request this information we will need to provide this by law;

in each case, in accordance with this privacy policy.

Keeping Data secure

We will use technical and organisational measures to safeguard your Data, for example:

access to your account is controlled by a password and a username that is unique to you.

we store your Data on secure servers.

payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology.

Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this email address: Hello@joinverge.com 

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

You have the following rights in relation to your Data:

Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.

Right to erase – the right to request that we delete or remove your Data from our systems.

Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.

Right to data portability – the right to request that we move, copy or transfer your Data.

Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this email address: Hello@joinverge.com

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Links to other websites

This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of business ownership and control

Verge Capital Limited may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Verge Capital Limited. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

We may also disclose Data to a prospective purchaser of our business or any part of it.

In the above instances, we will take steps with the aim of ensuring your privacy is protected.

General

You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

Verge Capital Limited reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

You may contact Verge Capital Limited by email at Hello@joinverge.com

Prepaid Financial Services – Privacy and You

Who are we?

Prepaid Financial Services (PFS) is a fast-growing technology company and e-money payments institution with offices in the UK, Malta and Ireland. PFS is authorised and regulated by the Financial Conduct Authority in the UK, as an electronic money institution, under reference number 900036. We provide our own label and white label e-money financial solutions, including e-wallets, prepaid cards, and current accounts. PFS provides complete end to end solutions for clients by designing, developing, implementing, and managing these programmes.

What, Why?

It is important that you know exactly what we do with the personal information you and others make available to us, why we collect it and what it means for you. This document outlines the PFS approach to Data Privacy to fulfil our obligations under the EU General Data Protection Regulation (GDPR) 2018 of 25th May 2018. We also welcome it as an opportunity to reassure you of the importance we place on keeping your personal data secure, and of the strict guidelines we apply to its use.

The personal data we would like to collect from you is:

→ First Name and Surname with title → Address

→ Date of birth → Gender

→ Email → Bank Account details

→ Proof of address documents → Telephone number

→ ID Documents → Transactional information

→ Other personal information such as telephone recordings; security questions, user ID

→ CCTV footage where you visit our offices or branches

The personal data we collect will be used for the following purposes:

Providing prepaid card services to you as per our contractual obligations

Providing e-wallet services to you

Providing IBAN Account services to you

Processing your account information

To comply with our legal obligations for the prevention of fraud, money laundering, counter terrorist financing or misuse of services

Verifying your identity

Contacting you regarding our service to you

Where requested by law enforcement for investigation of crime

Our legal basis for processing the personal data:

receipt of your consent

performance of a contract where you are a party;

legal obligations that PFS is required to meet;

national law

Any legitimate interests pursued by us, or third parties we use, are as follows:

the prevention of fraud, money laundering, counter terrorist financing or misuse of services

Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified above. Consent is required for PFS to process personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

Consent for Children Under 16

If you are giving consent on behalf of a child under 16 then please be aware that Children need specific protection with regard to their personal data, as they may be less aware of the risks, consequences and safeguards concerned, and also of their rights in relation to the processing of personal data for the purposes of using these services. By consenting to this privacy notice on behalf of a minor you are giving permission for their data to be used for the purposes described above.

Withdrawal of Consent Conditions

You may withdraw consent from direct marketing at any time by contacting our Data Protection Officer. Please note, where you have consented to your data being used for carrying out financial transactions, then the right to withdraw consent does not exist. As a payment service provider, PFS is obliged to retain data concerning financial transactions for 6 years in accordance with national law for the purpose of preventing, detecting and

investigating, by the FIU or by other competent authorities, possible money laundering or terrorist financing.

Disclosure

PFS will only pass on your personal data to third parties, including internationally, once we have obtained your consent. Some of our service providers, like payment processors, risk management solutions and suppliers are based outside of the EEA. Where we authorize the processing or transfer of your personal information outside of the EEA, we require your personal information to be protected to data protection standards and we ensure that there are adequate safeguards in place for data protection. The GDPR prohibits transfers of personal data outside the European Economic Area to a third country that does not have adequate data protection. Where transfer occurs outside the EEA the following mechanisms are in place with the third parties:

Data Protection clauses in our contracts and agreements with third-parties

EU-US Privacy Shield

Personal Information Protection and Electronic Documents Act (PIPEDA)

Retention period

PFS will process personal data for the duration of the contract for services and will store the personal data for 6 years after that date of termination of the contract.

Your rights as a data subject.

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

Right of access – you have the right to request a copy of the information that we hold about you.

Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. Your data relating to financial transactions, accounts or cards cannot be deleted due to national law associated with the prevention of fraud, money laundering, counter terrorist financing or misuse of services for crime.

Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.

Right of portability – you have the right to have the data we hold about you transferred to another organisation.

Right to object – you have the right to object to certain types of processing such as direct marketing.

Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

Right to judicial review, in the event that PFS refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.

All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data. You will find a copy of our Subject Access Request Form on our website.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by PFS (or third

parties as above), or how your complaint has been handled, you have the right to lodge a complaint directly

with the supervisory authority and PFS’s Data Protection Officer by email to

DPO@prepaidfinancialservices.com

Data Protection Officer Prepaid

Financial Services Fifth Floor,

Langham House,

302-308 Regent Street, London,

W1B 3AT

If you are unhappy with our response or if you need any advice you should contact the Information

Commissioner’s Office (ICO).

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire SK9

5AF

ICO helpline

Telephone: 0303 123 1113

Further information can be found in our Cookies Policy on our website.

Use of Intercom Services

We use third-party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. As a data processor acting on our behalf, Intercom analyzes your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. For more information on Intercom’s use of cookies, please visit https://www.intercom.com/terms-and-policies#cookie-policy. We may also use Intercom as a medium for communications, either through email, or through messages within our product(s). The Intercom Messenger Apps and Apps in Inbox products may also provide you with access to other third party applications such as Stripe. You should consult these third parties’ privacy notices for further information on their use of your personal data. As part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience. For more information on the privacy practices of Intercom, please visit https://www.intercom.com/terms-and-policies#privacy. Intercom’s services are governed by Intercom’s terms of use which can be found at https://www.intercom.com/terms-and-policies#terms. If you would like to opt out of having this information collected by or submitted to Intercom, please contact us.