Privacy and Cookies

Privacy


Elemental Financial Holdings Ltd ‘EFH’ we endeavour to maintain the highest standards of confidentiality and to respect the privacy of our clients and associated persons, our employees, and other individuals whose personal information we collect and process. Our commitment to privacy includes being transparent about the nature and extent of that processing and the rights that may be available to you with respect thereto.

This Privacy Policy describes:

  • the information we collect;
  • how we use that information;
  • when we share information;
  • your rights;
  • and how to get in contact.

Overview


To provide you with our services we need to know things about you. We will only collect information we need to provide you with the services you have requested and will handle your information with the utmost care. Any information we receive about you will be subject to strict controls to minimise the risk of misuse – including unauthorised access to, or disclosure of, your personal data.

This Privacy Policy applies to information that EFH may collect about visitors to our website (even if you do not become a customer), companies and individuals who register for our services, and continue using our services, and any other person who contacts us over the telephone or in writing.

Please read this notice carefully, together with our Terms and Conditions and any other documents referred to within. Here we explain the basis on which any information we collect about you, or that you provide to us, will be processed by us and other parties in providing you with the services you use.

For the purposes of this Privacy Policy, the term “personal information” means any data that can identify you as an individual for example name, address and contact information.

If you would like to know more about any of the terms of this Privacy Policy, please contact us (information provided below) so that we can help you with any questions or concerns.

What Information do we collect & how do we collect it?


Information you provide to us

To open an account or use EFH services, you will be asked to provide identifying information about yourself (e.g. name, address, and email address), your company and documents to verify the information provided.

In order to make payments, you will be asked to provide the information required to facilitate the payment – e.g. beneficiary information, bank account details and source of funds.

Through the course of our business relationship, we may ask for additional evidence in order for us to comply with our legal obligations – e.g. anti-money laundering regulations. These can include, but are not limited to, documents

Information we collect when you use our website or app

Our website uses cookies to provide you with a better experience on our website, for fraud prevention and to provide internet-based advertisement. For detailed information on the cookies we use and the purposes for which we use them, please see our full Cookie policy.

The EFH user community participants will have their sessions recorded to allow us to capture the feedback to improve our services and help with the development of new products. This will always be based on your consent, which you can withdraw at any time.

For the detection and prevention of fraud and cyber-crime, we will collect information, including session, device and IP address to help ascertain the legitimacy of the account login.

Public information

For non-registered users, we may contact you using publicly available information or information from third parties, which you have consented to being shared, to let you know about products that could be relevant for your business.

Transactional information

Once your account is fully set up and you begin to transact with us we will collect, process and store your EFH financial and transactional information. This information includes the amount, currency, type of transaction, source of funds, exchange rate, recipient name and bank details.

Information about you that we receive from third parties

To protect ourselves and our customers against fraud, we verify the information you provide with Anti-Fraud agencies and Electronic Identity Verification Services. In the course of verification, we receive and process information about you from such services.

Information may be collected from credit reference agencies. More information on this can be found here: https://www.callcredit.co.uk/legal-information/bureau-privacy-notice

Communications

All calls are recorded, and correspondence retained for the purposes of quality control and training, as evidence of transactions and to fulfil regulation requirements. Any information you disclose to us will be held on these recordings.

Individuals who are not registered users of EFH

Connected parties

EFH will collect information about connected parties to a EFH client during the course of the business relationship from the client to comply with our legal obligations – e.g. directors or shareholders of a company.

Beneficiaries

EFH will collect information required to be able to send a payment to an individual, who may not be an EFH client. This will include name and bank account details that are required by regulations to process the payment.

Who do we share your data with?


Banking Partners

EFH uses various banking partners around the world to ensure your payment can get to where it needs to go as quickly as possible. When you transact with EFH, we may need to share your information with payment providers or banking partners outside of the EEA, such as intermediary or beneficiary banks – e.g. if you ask us to make a USD payment to China the funds would be cleared through an intermediary bank in the US before reaching China.

For transparency, verification and legal requirements, we are required to include certain information on the payment which could include:

  • Your name
  • Your date of birth
  • Your address
  • Beneficiary details
  • Your national identity reference (e.g. passport)

Trusted Partners

If you were introduced to EFH by one of our trusted partners, we may provide them with your information to fulfil our contractual obligations with the partner.

Additionally, we may share your details with a trusted partner for marketing purposes if you have given your consent to do so.

Other Parties

We may share your information with trusted companies providing services to us under confidentiality agreements or to companies that assist us in meeting our obligations to you and our regulators– e.g. the processing of card transactions or the verification of documentation. These companies do not have any rights to market other services with you.

These trusted companies may be outside of the EEA. EFH will ensure that the company is based in a country with adequate data protections under their law, or that we impose contractual obligations or require them to be certified with a framework of protection deemed suitable by EFH. EFH performs due diligence to ensure third parties are compliant with applicable legal and contractual requirements.

Also, we may share your information with any person acting on your behalf provided that you have given us the permission to do so.

Regulators and Law enforcement

We may need to pass necessary information on to Governmental departments, regulatory bodies, the police/law enforcement agencies or other third parties where we are legally compelled to do so – e.g. if we have reason to believe an individual is acting fraudulently and using our services for an illegal purpose.

We will never sell any personal data that we hold about you.

How long do we keep your information for:


EFH will only retain your information for as long as is necessary for providing our service to you and will not hold or process your information for any longer than we are legally required to. The criteria used to determine the appropriate retention includes:

  • Regulatory requirements EFH is subject to
  • Whether a legal claim could be brought against EFH
  • Necessity of information to provide our service to our customers
  • The legal basis for processing – e.g. consent

Information about connected parties and beneficiaries, which may not belong to a EFH client, are stored for a period to comply with applicable legal requirements.

Communications

We communicate with you on a regular basis via email and phone to provide excellent customer service and fulfil requests.

Additionally, we use your email address, phone number and postal address to:

  • Provide notification as part of the on-boarding and trading lifecycle
  • Send you important changes to our products and services
  • Send notices and disclosures required by law

Due to the service-orientated nature of these communications, you cannot opt out to receiving these.

Marketing

EFH would like to keep you up to date concerning our products and services.
Once you are a client of EFH, we may use your information to provide product information, and rate and market updates that are relevant to you and/or your company.

We may also use your information (whether you are a registered EFH user or a visitor to our website) to keep you up to date on general products, market updates or rate movements provided you have given your consent to do so.

If you change your mind on which communications you would like to receive or how you would like to receive them or you decide that you do not wish to receive these types of communications, you can remove your consent at any time by:

Emailing: privacy@elemental.financial

You will not miss out on any service we provide by not choosing to receive marketing from us and you can change your mind whenever you like as often as you like.

Security


We store all data electronically in a secure manner to protect its confidentiality, integrity and availability. Data is stored on servers which are protected by actively maintained firewalls. We make use of up-to-date anti-virus software and our servers have restricted access.

If you provide paper-based documentation for the purpose of identity verification these will be stored electronically and the original will be destroyed securely or returned to you.

Transmission of data on the internet can never be completely secure. We do not and cannot guarantee the security of information collected or transmitted electronically however, we take reasonable care to safeguard your personal information.

Contact us


If you would like to get in contact with us, please contact our Chief Risk Officer at 20 North Audley Street, London W1K 6LX; send us an email privacy@elemental.financial  or call us on 020 3 940 6670

Cookies


Our Use of Cookies and Your Options

By using EFH Web site with your browser settings adjusted to accept cookies you consent to our use of cookies and other tools to provide the products and services available on those sites. If you would like to modify your browser to notify you when you receive a new cookie or to disable cookies altogether, please refer to Managing Cookies below.

Cookies and How We Use Them

Cookies are small text files that may be placed on your Web browser when you visit our Web sites or when you view advertisements, we have placed on other Web sites. Cookies allow your browser to remember some specific information which the Web server can later retrieve and use. We do not use cookies to store any personal information that could be read or understood by others. When you quit your browser, some cookies are stored in your computer’s memory, while some expire or disappear.

Cookies are used primarily for administrative purposes, to improve your experience with our Web sites. Examples of this would include the use of cookies:

  • To improve site security by “authenticating” you (i.e., verify that you are who you say you are) when you sign-in to our site.
  • To keep track of your specified preferences such as language, time zone and timeouts after periods of inactivity.
  • To allow you to navigate our sites more easily by “remembering” your identity so that you do not have to input your password multiple times as you move between pages or services.
  • In addition to administrative uses, we may also use cookies in one or more of the following ways, depending on the Web site you are using:
  • To conduct research and analytics to improve our Web sites and our products and services. This includes compiling statistical information concerning, among other things, the frequency of your use of our Web sites, the pages visited and the length of each visit.
  • To display EFH advertisements when you visit Web sites of third parties with whom we have marketing relationships and to help us gauge the effectiveness of our advertising efforts. These parties may gather information concerning your use of other Web sites and provide us with de-identified information about you (such as demographic information or the names of sites where you have been shown ads) which we may use to provide you with more relevant and useful advertising.

This paragraph applies only to the www.elemental.financial Web site. That site may use third parties to serve advertisements as described immediately above. To do so, these parties may place or recognize a unique cookie on your browser (including through the use of pixel tags) to gather information concerning your use of our that site and other Web sites and, based on that information, serve advertisements that may be of interest to you. If you would like more information about this practice, and to learn how to opt out of it on the particular device on which you are accessing this Privacy and Cookies Policy, please visit http://optout.aboutads.info/#/. The www.elemental.financial site adheres to the interest-based advertising principles of the Digital Advertising Alliance, available at http://www.aboutads.info/principles.

For more information on how we collect and use information that is identifiable to you, please refer to our Privacy Policy.

Managing Cookies

The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or visiting the Web site of its manufacturer. Some of our sites employ “functionality cookies” that help the site remember your settings and preferences for use when you visit the site in the future. This provides a more tailored and pleasant user experience. These cookies store information in multiple places. On those sites using functionality cookies, you will find a “Delete Cookies” feature on every page that will allow you to delete these cookies completely from your device. Please note that, if you decline to use cookies, you may experience reduced functionality and, for sites using authentication-related cookies, declining cookies will prevent you from using the Web site altogether. To learn more about what cookies are set on your computer as you browse the Web and how to manage or delete them, visit www.allaboutcookies.org.