Cremello Currency Management Ltd ("Cremello", "we", "us", or "our") is committed to protecting and respecting your privacy. This Privacy Policy outlines how we collect, use, and safeguard your personal data in compliance with the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).
1. Information We Collect
We may collect and process the following data:
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Personal Identification Information: Name, address, email address, phone number, date of birth, and other contact details.
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Financial Information: Bank account details, transaction history, and payment information.
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Identification Documents: Copies of passports, driving licenses, utility bills, or other documents for identity verification.
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Technical Data: IP address, browser type, operating system, and other technical information collected through cookies and similar technologies.
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Usage Data: Information about how you use our website, products, and services.
2. How We Use Your Information
Your data is used to:
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Provide and manage our foreign exchange services.
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Verify your identity and conduct anti-money laundering checks.
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Process transactions and manage your account.
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Communicate with you regarding our services.
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Comply with legal and regulatory obligations.
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Improve our website and services.
3. Legal Basis for Processing
We process your personal data based on:
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Contractual Necessity: To fulfill our contractual obligations to you.
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Legal Obligation: To comply with legal and regulatory requirements.
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Legitimate Interests: To manage our business operations and improve our services.
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Consent: Where you have provided consent for specific processing activities.
4. Data Sharing and Disclosure
We may share your information with:
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Service Providers: Third-party companies that provide services on our behalf, such as payment processing and IT support.
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Regulatory Authorities: To comply with legal obligations or respond to lawful requests.
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Affiliated Entities: Our partners, such as Ebury Partners UK Ltd, who are authorized and regulated by the Financial Conduct Authority (FCA) as an Electronic Money Institution (Reference Number: 900797).
We ensure that any third parties with whom we share your data are obligated to protect it and use it only for the purposes specified by us.
5. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for legal, accounting, or reporting requirements. Typically, this means retaining data for a minimum of six years after the end of our relationship with you.
6. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, or destruction. Client funds are held in segregated accounts with tier 1 banks, ensuring they are ring-fenced and separate from our operating accounts.
7. Your Rights
Under the UK GDPR, you have the right to:
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Access the personal data we hold about you.
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Request correction of inaccurate or incomplete data.
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Request deletion of your data under certain circumstances.
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Object to or restrict the processing of your data.
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Request the transfer of your data to another service provider.
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Withdraw consent where processing is based on consent.
To exercise any of these rights, please contact us at info@cremellocurrency.co.uk.
8. Cookies
Our website uses cookies to enhance user experience and analyze website traffic. You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies.
9. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Any changes will be posted on this page, and where appropriate, notified to you by email.
10. Contact Us
For any questions regarding this Privacy Policy or our data practices, please contact:
Cremello Currency Management Ltd
One Canada Square
London, E14 5AA
Email: info@cremellocurrency.co.uk
Phone: +44 (0)203 325 5700
