TransferLab Ireland Privacy Notice
Welcome to TransferLab's privacy notice.
Purpose of this privacy notice
TransferLab is authorised by the Central Bank of Ireland under the European Union (Payment Services) Regulations 2018 (Reference number: C182347) for the provision of payment services. We are registered with the Data Protection Commission (DPC), the data protection regulator in the Republic of Ireland, to use personal data.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
DPO: Fiona Gildea
Contact Address: Unit 10, Creative Spark, Clontygora Court, Dundalk, County Louth, A91 HF77
Email: privacy@transferlab.io
- Identity Data includes your name, username or similar identifier, date of birth, gender, nationality, date of birth, identification documents (for example, your passport or international identity card), copies of any documents provided for identification purposes to provide you are eligible to use our services (for example bank statements or utility bill), your photo or video (captured during an identity verification session) and photos from your device (if you grant us access)[1].
- Contact Data includes your address, email address, telephone number.
- Financial Data includes bank account details (including the account number, sort code and IBAN) and copies of any source of proof of source of funds (including bank statements or solicitor/accountant letters etc.).
- Transaction Data includes details about payments to and from you, including the transaction date, time and amount, the currencies and exchange rate used, beneficiary details and the payment method you used.
- Technical Data includes internet protocol (IP) address, your login data, browser or mobile browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, type of device, unique device identifier (including the IMEI number, the AMC address of the device's wireless network interface, or the mobile phone number used by the device) mobile network data, mobile operating system and other technology on the devices you use to access our website or use our app.
- Profile Data includes your username and password, the services used by you and records of our communication, if you contact us or we contact you.
- Usage Data includes information about how you use our website or our app, products and services, including the links you've clicked on through and from our website or our app (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction data (such as scrolling and clicks) and methods used to browse away from the webpage or the app.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
We only collect limited Special Categories of Personal Data about you (which is limited to biometric data and limited information about criminal convictions and offences) where you have chosen to provide that type of personal data to us.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity Data, Contact Data and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- use our services;
- create an account on our website or our app;
- subscribe to our service or publications;
- request marketing to be sent to you; or
- give us feedback or contact us, including our customer helpline and messaging service. We may record calls to our customer helpline, messages and emails but only to train and monitor our staff so that they give you the best support possible.
- Automated technologies or interactions. As you interact with our website or our app, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy at https://transferlab.io/cookie-policy for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Jumio Corporation and IVXS UK Limited trading as ComplyAdvantage.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Purposes for which we will use your personal data
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
To register you as a new customer, check your identity and decide whether or not to approve your application to use TransferLab's services. This is part of our Know Your Customer (KYC) processes and obligations |
(a) Identity (b) Contact
|
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (including our anti-money laundering and KYC obligations) |
To process and deliver the services including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice (b) Asking you to leave a review or take a survey (c) to provide Customer Support, either by phone or by email. |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To administer and protect our business, our website and our app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical
|
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant website and app content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our website and our app, products/services, marketing, customer relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website or our app updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Cookies are a small piece of information saved in your browser storage. They are used to improve the customer experience in pages and help third-party services to work properly. We uses cookies extensively in both public pages and the product, as do third-party providers. The data stored in cookies is anonymous, rather than private, and cannot be retained for more than 24 months.
- Third parties who provide a service to us and their sub-processors, including:
- The Jumio Corporation (identification and KYC services);
- IVXS UK Limited trading as ComplyAdvantage (identification and KYC services);
- HubSpot (customer relation services); and
- Inbound Fintech Ltd (I.T. and marketing services).
- A public authority in the event that we are required to do so by law.
- A third party where we are under a legal obligation to transfer it to that third party.
- A prospective seller or buyer of any of our assets or business.
- A third party where it is necessary to protect the vital interests of the data subject or another natural person.
- We may also be required to share your personal data with our regulator the Central Bank of Ireland
- Our banking and financial services partners and payment networks to allow us to transfer your money internationally.
- Professional advisers, including our lawyers and accountants.
- Social media platforms, including Facebook and LinkedIn.
Some of our external third party service providers, including the Jumio Corporation and HubSpot Inc., are based outside the EEA so their processing of your personal data will involve a transfer outside the EEA.
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the DPC (as applicable). For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission or the ICO (as applicable) which give personal data the same protection it has in the EEA. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
It is still important for you to keep your TransferLab account details and password safe. You should not share these with anyone.
How long will you use my personal data for?
In some circumstances you can ask us to delete your data: see section 'Your legal rights' below for further information.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights
- Request access to your personal data;
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data. 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. 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.
- Request the transfer of your personal data to you or to a third party.
- 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.
If you wish to exercise any of the rights set out above, please contact us
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.
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 and keep you updated.
If you have any questions about this privacy notice or our privacy practices, please contact us at privacy@transferlab.io
You have the right to make a complaint at any time to the DPC, the Irish supervisory authority for data protection issues (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review. This version was last updated on 04/01/2022.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
[1] This may require us to have access to your photos and other digital content on your device for this purpose only.