Privacy Policy

Welcome to our top-notch money transfer service, where your privacy is our priority!

Our Privacy Policy is your guide to how Velox Payments Limited ("Velox Payments", "we", "us", or "our") handles your personal data. We've simplified the details, outlining the information we collect, why we collect it, and the measures in place to protect it.

This notice empowers you with insights into your rights and how to exercise them. Trust us to deliver outstanding service while safeguarding your privacy. Explore our Privacy Policy for a clear and confident understanding of our approach.

Velox Payments is a money remittance company that makes it easy to stay in touch with family and friends, to increase the level of financial connectivity for the African diaspora, with a focus on serving customers from the United Kingdom and Canada to African countries, including Nigeria and Kenya ("supported African Countries") and vice versa.

This privacy policy governs the collection of information through our services, applicable to all current and former users of Velox Payments, including yourself. The term "Services" encompasses products, features, technologies, or functions, and all associated websites, applications, and services provided by Velox Payments. Even after you cease to be our customer, we may continue to utilize your information as outlined in this policy.

In this policy, the term "personal data" refers to data associated with a specific person that can be used to identify them. We do not classify personal data to include data that has been aggregated and/or anonymized to the extent that it no longer identifies a specific user.

This policy is designed for users and covers the usage of information in connection with your account.

When you create an account, we may collect the following categories of information from you:

• Personal identification details such as name, date of birth, email, address, and phone number;
• Supplementary identification particulars, including government-issued identity documents, taxpayer identification number or national insurance number, and employment details;
• Financial data, which may involve income/wealth verification documents or bank account statements;
• Information related to your browser, IP address, location, and device;
• Behavioural data on our website, covering pages viewed, links clicked, keystrokes, and actions taken, including copy/paste functions;
• Transaction details, encompassing information about the use of Services, types of Services requested, dates and times of such requests, payment methods, sender and recipient names, and similar details;
• Transaction data to track transactions and allocate points for our loyalty program;
• Location data, including User location searches;
• Communication data, such as messages, comments, or file transmissions;
• Information about your internet connection, the equipment used to access our Resources, and usage details;
• Additional information deemed necessary by Velox Payments (at its discretion) to verify a user's identity, which may include utility bills as proof of residency, etc.
• Aggregated Data such as statistical or demographic data for any purpose.

Failure to provide the required information may prevent us from delivering our services.

Velox Payments collects personal data through the following methods:

• when you create an account, complete forms, or communicate with us.
• when you register, access, or use our website, mobile application, or services
• When you voluntarily participate in surveys, promotions, or provide feedback through our communication channels.
• When you download, install, or use the Velox Payments mobile application.
• When you submit content on our platforms, including reviews, messages, comments, or support requests.
• When you enable location services on your device.
• Through direct interactions such as correspondence by email, phone, post, or other means.
• Through automated technologies that monitor usage, performance, and security of our platforms.
• From third parties and lawful public sources, including identity verification partners, analytics providers, fraud-prevention services, and regulatory or compliance databases.

You may give us your Identity, Contact and Financial Data by filling out forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our newsletters;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.

Velox Payments only collects and processes personal data where a lawful basis exists. This includes the following:

To provide products and services which you have requested, and to conduct business with you

(for example, to register you as a new customer, to process your application, to manage your account, to tell you about important changes to our services, to process and to respond to your enquiries, complaints and issues) and to keep updated and bring together and improve records.

• Lawful basis: Performance of a contract with you

For security, credit, identification and verification purposes

• Lawful basis: Comply with a legal obligation (e.g., compliance with our Anti-Money Laundering and Know Your Customer obligations).

To detect, investigate, prevent and prosecute criminal activity and to meet our regulatory, legal and compliance obligations

(including performing regulatory and prudential compliance checks on an ongoing basis, account and transaction monitoring, checks for sanctions and politically-exposed persons, and transaction and tax reporting. Also making disclosures to, co-operating with, and complying with requests from: public authorities, regulators, courts of law, tax authorities, governmental bodies or law enforcement agencies, and investigating and preventing fraud, terrorism and other crime).

• Lawful basis: (a) Comply with a legal obligation (b) Legitimate interests (ensuring effective compliance in all relevant jurisdictions, protecting our customers, maintaining a good relationship with law enforcement, regulators and other relevant authorities. We also consider that we have a legitimate interest in protecting our legal rights.)

To improve customer service, and to decide if a product or service is suitable for your needs

• Lawful basis: Legitimate interests (we consider that we have a legitimate interest in providing quality customer service, as this allows us to maintain good client relationships and to deal with queries and complaints effectively. We also consider that we have a legitimate interest in ensuring that we provide our customers with appropriate products and services, to ensure both appropriate risk management and good client relationship management.)

To provide you with the appropriate level of service, to accommodate your specific individuals needs and treat you fairly based on any vulnerability you may have

whether you have told us or we believe necessary to record, to improve customer service and ensure equality of treatment, protect vulnerable customers or safeguard your economic wellbeing.

• Lawful basis: (a) Consent (b) Public Interest (c) Vital Interest (d) Legitimate interests (we consider that we have a legitimate interest in providing quality customer service, as this allows us to maintain good client relationships and to deal with queries and complaints effectively).

To carry out operational and administrative functions

(e.g. to maintain our own accounts and records, to operate information technology systems, to carry out billing-related and payments administration, to maintain stocks and shares registers).

• Lawful basis: (a) Comply with a legal obligation (to maintain certain statutory records) (b) Legitimate interests (we consider that we have a legitimate interest in running our business efficiently).

To share relevant information in respect of a prospective sale of Velox Payments, or any of its subsidiaries, or any part of its or their business

• Lawful basis: (a) Comply with a legal obligation (b) Legitimate interests (we consider that we have a legitimate interest in complying with due diligence requirements and being efficient in how we run the business).

To manage, support and provide training to our staff

• Lawful basis: Legitimate interests (we consider that we have a legitimate interest in managing, supporting and providing training to our staff).

Marketing: To tell you about other Velox Payments products, services and facilities that may interest you

(by post, email, phone or text, in accordance with your preferences). We may share some personal data (for example, your email address), in a secure format, with our advertising partners and social media companies, so that they can display the most relevant messages to you and others about our products and services. This includes instructing these companies not to show adverts to our existing customers. If you do not want us to share your personal data with our advertising partners or social media companies for this purpose, you can tell us not to.

• Lawful basis: (a) Consent (b) Legitimate interests (we have a legitimate interest in making our customers aware of our other services and offerings). Legitimate interests (we consider that it is in our legitimate interests to give you information about our products and services that you or others may be interested in).

To evaluate the effectiveness of marketing and for research, training and statistical analysis with the aim of improving services

• Lawful basis: Legitimate interests (we consider that we have a legitimate interest in improving our products, services and operations).

To help us to improve our products, services and operations

including market research, analysis of customer preferences, transactions and market trends, evaluating proposed products, testing new systems and upgrading existing systems.

• Lawful basis: Legitimate interests (we consider that we have a legitimate interest in improving our products, services and operations).

To track and allocate loyalty points and referral rewards

• Lawful basis: Legitimate Interests (we consider that we have a legitimate interest to improve user experience and reward users)

To manage our business and to protect and enforce our rights

including assessing, monitoring and managing financial, reputational and other risk, conducting audits, liaising with regulators and law enforcement, and to establish, enforce and defend against legal claims).

• Lawful basis: (a) Comply with a legal obligation (b) Legitimate interests (we consider that we have a legitimate interest in prudently managing our business and in protecting and enforcing our rights).

To be able to work with other companies that provide services to us and our customers

• Lawful basis: Performance of a contract with you

Purpose limitation

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

Velox Payments may send you information about our products, services, and promotions where you have provided consent or were permitted by law. You may give consent during account registration or through your account settings.

We may use limited personal data, such as contact, technical, and usage data, to tailor communications and offers that we believe may be relevant to you.

We will obtain your explicit consent before sharing your personal data with third parties for their own marketing purposes.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You have the right to opt out of marketing communications at any time by adjusting your account preferences, using the unsubscribe link in our messages, or contacting us directly. Note that opting out of marketing communications will not affect essential service-related messages.

Our website uses cookies and similar technologies. You may configure your browser to refuse cookies; however, doing so may affect the functionality of certain features.

Velox Payments uses cookies and similar technologies to operate our website and application, improve functionality, analyze usage, and enhance security. We personalize content and ads, offer social media features, and analyse traffic. Information about your site usage is shared with our social media, advertising, and analytics partners, who may combine it with data you have provided or collected from their services.

Some cookies are strictly necessary for the operation of our services. Other cookies are used for analytics and performance. Your consent will be sought as required by law.

We may also allow third parties to provide audience measurement and analytics services, serve advertisements on our behalf across the Internet, and track/report on their performance.

You may configure your browser to refuse or delete cookies. Please note that disabling cookies may limit certain features or functionality.

Velox Payments is committed to protecting your personal data. We implement appropriate physical, technical, and organizational security measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

Personal data provided by users is stored on secure servers protected by firewalls and other security technologies. Where payment transactions are processed, such information is encrypted using industry-standard Secure Socket Layer (SSL) technology or equivalent safeguards.

Users are responsible for maintaining the confidentiality of their account credentials, including passwords, and must not share these details with any third party.

Velox Payments stores personal data on servers operated by reputable third-party hosting providers. While absolute security cannot be guaranteed, and no method of transmission over the internet or electronic storage is completely secure, we take reasonable steps to protect personal data.

We may process, store, and transfer personal data outside your country of residence, where data protection laws may differ. In such circumstances, Velox Payments will take appropriate measures to ensure that personal data is protected in accordance with applicable data protection laws.

We may share your personal data with the parties set out below for the purposes set out in the table [Why We Collect Personal Data (Legal Basis for Processing)] above.

• Service providers acting as processors who provide financial services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Regulators and other authorities who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all 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.

Velox Payments is committed to respecting the privacy rights of individuals under all privacy laws applicable to us. You have the right to:

a) 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.

b) 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.

c) 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.

d) 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.

e) 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.

f) 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.

g) 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.

h) Right to lodge a complaint with the relevant authority

You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal data. We ask that you please attempt to resolve any issue with us first by contacting us at compliance@veloxpayments.com, although you have a right to contact your supervisory authority at any time.

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 could 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 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 and keep you updated.

To exercise any of these rights, kindly send an email to us at compliance@veloxpayments.com. During this process, we may request proof of your identification to ensure the secure handling of your request and verify your identity.

Velox Payments retains personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Personal data is generally retained for the duration of your relationship with us and for up to seven (7) years after your account is closed, unless a longer retention period is required by law. You may request deletion of your account at any time.

Velox Payments will delete or anonymise personal data that is no longer required, subject to applicable legal, regulatory, tax, insurance, or litigation requirements. In some circumstances, account deletion may be delayed, such as where there are outstanding transactions, credits, disputes, or legal obligations. Once resolved, deletion will proceed in accordance with this Policy.

Where permitted, Velox Payments may anonymise personal data so it can no longer be associated with an identifiable individual and may use such anonymised data for legitimate business purposes.

Velox Payments' services are not intended for individuals under the age of 18. We do not knowingly collect, use, or store personal data from anyone under 18 years of age. If we become aware that we have inadvertently collected personal data from a child under 18, we will promptly delete it, unless we are legally required to retain it.

If you believe that a child under the age of 18 may have provided us with personal data, please contact us immediately at compliance@veloxpayments.com.

From time to time, we may change our privacy policy. The effective date set forth at the top indicates the last time this privacy policy was revised. Checking this effective date allows you to determine whether there have been changes since the last time you reviewed the policy. We will notify you of changes to this privacy policy by posting the revised privacy policy on our websites.

If you have any questions or concerns about how we use your information or want to exercise your rights, you can contact us at:

• Email: compliance@veloxpayments.com
• Canada: +1 (365) 799-9024
• UK: +44 333 188 6313
• 33 Booker Dr, Ajax, Toronto, Ontario, L1Z0H4, Canada
• Registered with FINTRAC number M22769793