Privacy Policy

PRIVACY POLICY effective as of 25th May 2018

This privacy policy describes how we collect, process, use and disclose your information in relation to your access and use of UCS Financial services. UCS Financial is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

What information we collect


We ask for and collect from you the following personal information when you use the UCS Financial services.

This information is necessary for us to comply with our regulatory obligations and to adequately perform our services.

When you sign up for UCS Financial services, we require certain personal information such as: First name and surname, Nationality, Registered address, Date of birth, Place of birth, Mobile telephone number, E-mail address, Identification document and all data from the identification document such as Type of identification document Issue date, ID number, Issuing authority. We may choose to collect other date in our enroll forms, which is necessary for your identification and verification.

In accordance with our legal obligations under the relevant Anti-money laundering and anti-terrorism financing regulations, we are obliged to verify your identity or the identity of the authorized user who is opening the Account.

In order to comply with relevant Anti-money laundering and anti-terrorism financing regulations we collect personal data regarding you related to your sources of income and any other similar financial information about you which would help us prevent money laundering and/or terrorism financing.

We may collect information about your computer, including your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns and does not identify any individual. For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our site and to deliver a better and more personalized service. They enable us:

To estimate our audience size and usage pattern. To store information about your preferences, and so allow us to customize our site according to your individual interests. To speed up your searches. To recognize you when you return to our site.
You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.
Please note that our advertisers may also use cookies, over which we have no control.

Because of the way that World Wide Web communication standards work, when you arrive at or leave the eMoneySafe website, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our Website you visit while you are on the eMoneySafe site, the type of browser you use and the times you access our Website. We use this information only to try to understand our customers' preferences better and to manage the load on our servers, so as to improve our service and your experience with eMoneySafe.

We collect information about your payment cards, which are issued to you by third-party issuers and are linked to your account. The information may be as follows: address of delivery of card, issue date, expiry date, IBAN or other payment account identifier to which card is linked to, currency, card transaction data, spending limits, expired cards’ details, SMS or other communication which the cardholder has received or has initiated with us, card status history, date of activation, linked cards or duplicates.

We collect information related to your payment transactions under UCS Financial services for example when you make purchases from merchants, you receive money transfers, you accept card payments, we process payments executed by you, or you send money to friends and family.
The payment transaction information may include the payment instrument’s details used, date and time of transactions performed by you, amount of payment transaction, payment instrument expiration date and billing postcode, email address, IBAN or other account identifier information, your address and other related transaction details. This information is necessary for the adequately perform our services.

How we use the information we collect


We use, store, and process information, including personal information, about you to provide, understand, improve, and develop UCS Financial services, create and maintain a secure environment, pursue our legitimate interests and comply with our legal obligations.
Initiate a payment, send or request money, acceptance of card payment, funding transaction of your eMoneySafe account; authenticate your access to your eMoneySafe account or your payment instrument; communicate with you about your eMoneySafe account and payment instruments; communicate your personal information with third financial institution of Participants in your payment transaction; create an account connection between your Account and a third-party account or platform, if applicable; perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes. Detect and prevent fraud, abuse, security incidents, and other harmful activity by blocking UCS Financial services or by applying other fraud prevention measures. Conduct security investigations and risk assessments. Conduct checks against databases and other information sources. Comply with legal obligations (such as anti-money laundering regulations). Enforce our rights, interests and claims arising from the Terms & Conditions. We process this information given our legitimate interest in improving the UCS Financial services and our clients’ experience with it, and where it is necessary for the adequate performance of the contract with you as well as to comply with applicable laws.

With who we share personal data


We will not disclose your personal data to anyone except as described in this policy.

With third party service providers
We may share personal information with third party service providers that support us in providing our services, products and/or Platform with functions at our decision and our behalf. These third-party service providers may for example: verify your identity or authenticate your identification documents, facilitating technically the Video Call and/or store the Video Call recording; check information against public databases, conduct background or police checks, fraud prevention, and risk assessment, perform risk monitoring; perform product development, maintenance and debugging, allow the provision of UCS Financial services through third party platforms and software tools (e.g. through the integration with our APIs); provide customer support; IT support and development services; card plastic production services; resell and distribute UCS Financial products; provide technical support for UCS Financial products; promote UCS Financial services as business introducers, distributors, promoters, sales agents or similar; perform courier services on our behalf; provide cloud, storage or collocations services; provide audit and accountancy services; provide legal, compliance or other consultancy services. These providers have limited access only to your information necessary to perform the tasks for which they were contracted for on our behalf and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy.

With other financial institutions that we have contracted to enable us to provide effectively our services to our customers
These financial institutions may only use this information in order for us to provide you with the wider scope of payment features. Such may be: Correspondent banks for the purposes of settling money transfers and currency exchange operations; Domestic payment schemes for the purposes of processing domestic payments; international payment schemes for the purposes of processing euro payments; Card Organizations for the purposes of card issuing and acquiring; Financial Institutions.

With the other parties to transactions when you use our services, such as other Clients, merchants, and their service providers
We may share information with the other participants to your transactions, including other clients or payers/payees you are sending or receiving funds from, and merchants or their service providers when you use our services to pay for goods or services. The information includes: Personal Data necessary to facilitate the transaction; Personal Data to help other participant(s) resolve disputes and detect and prevent fraud; and

With other third parties for our legitimate interest or as permitted or required by law
We may share information about you with other parties for our legitimate interest or as permitted or required by law, including: if we need to do so to comply with a law, legal process or regulations; to law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to us or our corporate family; if we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; to protect the vital interests of a person; with credit agencies and data processors for credit reference checks and anti-fraud and compliance purposes; to investigate violations of or enforce a user agreement or other legal terms applicable to any Service; to protect our property, Services and legal rights; to facilitate a purchase or sale of all or part of our business; in connection with shipping and related services for purchases made using a Service; in relation to promoting UCS Financial services to end users by third party business introducers. To help assess and manage risk and prevent fraud against us, our clients and fraud involving our websites, mobile apps or use of our services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals, and merchants; to banking partners as required by card association rules for inclusion on their list of terminated merchants; to credit reporting and collection agencies; to companies that we plan to merge with or be acquired by; and to support our audit, compliance, and corporate governance functions.

We do not share your Personal Data with third parties for their marketing purposes without your consent.

Monitoring
We may monitor or record telephone calls, emails, web chat or other communications with you for regulatory, security, customer services or training purposes.

Social Media
We may review and use public comments and opinions made on social networking sites (e.g. Facebook and Twitter) to better understand our customers and our provision and development of UCS Financial services.


Your rights


You have the right to obtain the following: confirmation of whether, and where, the we are processing your personal data; information about the purposes of the processing; information about the categories of data being processed; information about the categories of recipients with whom the data may be shared; information about the period for which the data will be stored (or the criteria used to determine that period); information about the existence of the rights to erasure, to rectification, to restriction of processing and to object to processing; information about the existence of the right to complain to any Regulator; where the data was not collected from you, information as to the source of the data; and information about the existence of, and an explanation of the logic involved in, any automated processing. Additionally, you may request a copy of the personal data being processed.

You have the right to ask us to correct inaccurate or incomplete personal information concerning you.

You have the right to: receive a copy of your personal data in a structured, commonly used, machine-readable format that supports re-use; transfer your personal data from one controller to another; store your personal data for further personal use on a private device; and have your personal data transmitted directly between controllers without hindrance

We generally retain your personal information for as long as is necessary for the performance of our services and to comply with our regulatory obligations. If you no longer want us to use your information to provide UCS Financial services to you, you can request that we erase your personal information and close your eMoneySafe account, providing your account is in good standing, not blocked or somehow limited for compliance, risk or regulatory reasons, or due to your outstanding obligation to us, court order, pledge or order by another regulator or other reason which prevent us by law to close your account or terminate the Service. In case the Data Controller is a regulated financial institution, such as credit institution, E-money institution or similar, such Data Controller is obliged under PSD and AML laws to keep your personal information and all transactions history for a period of 5 years after the termination of the relation with you. Please note that if you request the erasure of your personal information: We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing security. For example, if we suspend an eMoneySafe account for fraud or safety reasons, we may retain certain information from that eMoneySafe account to prevent that client from opening a new eMoneySafe account in the future. We are also obliged to retain personal data which we have collected for the purposes of complying with the relevant anti-money laundering and anti-terrorism financing for a period as defined under the applicable law. We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, UCS FINANCIAL may keep some of your information for tax, legal reporting and auditing obligations.

Security


We are committed to ensuring that your information is secure. To prevent unauthorized access or disclosure of information we have physical, electronic and managerial procedures in place to keep your information safe. Once logged into your eMoneySafe Wallet, all internet communication is secured using Secure Socket Layer (SSL) technology with high security 256bit encryption, certified by Comodo.

However, this high level of protection can only be effective if you follow certain security practices yourself. You must never share your eMoneySafe Wallet or login details with anyone. If you are concerned that any of your login details have been compromised, you can change them any time once you are logged on but you should always also immediately contact Customer Services and tell us why you think your login details have been compromised. Please read our eMoneySafe Wallet Terms & Conditions for further information on how to keep your eMoneySafe Wallet Account safe. Details of how to contact Customer Services are available from the “Support” section of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. When transferring data outside the EU, we will take steps to ensure that your data is afforded substantially similar protection as data processed within the EU. Please be aware that not all countries have laws to protect data in a manner equivalent to that of the EU. Your use of our products and services will indicate to Us that you agree to the transfer of Your data outside the EU. You have the right to object to the processing of your data and to its transfer outside the EU on compelling legitimate grounds.

Complaints


If you have any complaints you should try first to resolve the issue with the respective Data Controller by sending an email, from you registered e-mail address with us, at dpo@emoneysafe.com.

In case you are not satisfied with the response you can contact the respective data protection supervisory authority at commissioner@dataprotection.gov.cy

Changes to Our Privacy Policy


We reserve the right to modify this Privacy Policy at any time in accordance with this provision. Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of UCS FINANCIAL Platform will be subject to the revised Privacy Policy. Contact, questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@ucsfinancial.com.

Governing Law


Your use of this Site is governed by the laws of the Republic of Cyprus. All disputes arising out of or relating to this website shall be resolved by the Courts of the Republic of Cyprus.
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