Effective from 25 May 2018

1. This policy together with our Terms and Conditions (as applicable) apply to your use of:

• our websites at dttcl.com and www.dttmt.com (the “Sites”);
• the DT&T Mobile App (“App”) once you have downloaded a copy of the App on to your mobile telephone or handheld device; and
• any of the services accessible through the App or the Sites

2. This privacy policy describes how DT &T Corporation Ltd collects and uses your personal information, including the information you provide on the websites, owned and operated by DT &T Corporation Ltd (“DT&T” “we”, “us” or “our”) or our mobile application.

It describes the choices available to you regarding our use of your personal information, and how you can access and update this information.

Controller

DT &T Corporation Ltd is registered as a data controller with the UK Information Commissioner’s Office with a registration number Z3598016.

Data Protection Officer

We have appointed a data protection officer (“DPO”). Our DPO has a number of important responsibilities including:

• Monitoring DT&T’s compliance with the GDPR and other data protection laws;
• Raising awareness of data protection issues, training DT&T staff and conducting internal audits; and
• Cooperating with supervisory authorities such as the ICO on our behalf.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us in writing.

INFORMATION WE COLLECT ABOUT AND USES

We will collect and process the following data about you:

1. Information you give us “Submitted Information“: This is information you give us about you by filling in forms on the Websites, App, at our business locations or by corresponding with us (for example, by e-mail or via the chat functions on the App and/or the Site). This includes information you provide when you register to use the website, App, download or register the App, subscribe to any of our services, enter into any transaction on the App or the Site (such as a remittance order), participate in discussion boards or other social media functions on the App or the Site, enter a competition, promotion or survey and when you report a problem with an App, the Services, or the Site. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, address, date of birth, e-mail address, phone number, the Device’s phone number, username, password and other registration information, financial, details of your bank account including the bank account number, bank sort code, IBAN, details of your debit and credit cards including the long number, relevant expiry dates and CVC, identification document numbers, copies of identification documents (for example, passport, driving licence and utility bill) personal description and photograph and any other information you provide us in order to prove your eligibility to use our services.

2. Information we collect about you and your device. Each time you visit the App or our Site we will automatically collect the following information:

• Technical information, including the internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information and the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting “Device Information”;
• Information about your visit, including the full uniform resource locators (URL), clickstream to, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, device information;
• Transaction information including date, time, amount, currencies used, exchange rate, beneficiary details, details and location of the merchant associated with the transaction, IP address of sender and receiver, sender’s and receiver’s name and registration information, messages sent or received with the payment, device information used to facilitate the payment and the payment instrument used;
• Information stored on your Device, including if you allow DT&T access contact information from your address book, login information, photos, videos or other digital content (Content Information). The App will periodically recollect this information in order to stay up-to-date;
• Details of your use of our App or your visits to our Site including transaction details relating to your use of our services, including whom you have sent money or electronic money to, foreign exchange transactions you have entered into, the time, date and location of the place the transaction was entered into.

3. Location Information. We use GPS technology and your IP address to determine your location – this may be used when the App is running in the foreground and the background of your Device. This is used to prevent fraud, for instance if your mobile phone is saying that you are based in the UK but your account is being used in France, we may not allow that transaction to be processed. Our account protection and fraud-prevention measures require this personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling location permission for the DT&T App within your device settings “Location Information”.

4. Information to help us deliver our service to you. We work closely with third parties in order to help us deliver our Service to you. These third parties are business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, fraud prevention agencies, customer service providers and developers. Information we may collect about you from such parties can include information that helps us to verify your identity or information relating to your payment transactions.

5. If you allow us to, we will collect friends lists from Facebook and similar information from other third parties such as Twitter and Google – the App will periodically re-collect this information in order to stay up-to-date.

We use information held about you in the following ways:

To perform our contract with you for the relevant services:

• Register you with an account;
• To take steps at your request prior to entering into it;
• Provide the Services as described in our terms and conditions;
• To manage and perform that contract;
• Fulfil your Transaction Request;
• Send you a confirmation;
• To notify you about changes to our service;
• To update our records; and
• To trace your whereabouts to contact you about your account.

For our own legitimate interests or those of other persons and organisation:

• For good governance, accounting, and managing and auditing our business operations;
• To monitor emails, calls, other communications, and activities on your account;
• For market research, analysis and developing statistics; and
• For send marketing communications and for marketing to you in our business locations.

To comply with a legal obligation:

• When you exercise your rights under data protection law and make request;
• For compliance with legal and regulatory requirements and related disclosures;
• For establishment and defence of legal rights;
• To verify your identity to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our products and services;

Based on your consent:

• When you request us to disclose your personal data to other people, organisations, or otherwise agree to disclosures in writing;
• To send you marketing communications where we have asked for your consent to do so.

MARKETING

We use your data for marketing purposes and you can ‘opt-out’ from receiving any marketing communications from us whenever you want.

We have provided you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a ‘Privacy’ section within the ‘Profile’ section of your account where you can view and make certain decisions about your personal data use in relation to marketing emails and push notifications. Please see the ‘Privacy’ section within the ‘Profile’ section on your account for more details.

Choice/Opt-Out

You can ask us to stop sending you marketing messages at any time by adjusting your marketing preferences via ‘Privacy’ section found within the ‘Profile’ tab on your account or by following the unsubscribe links on any marketing message sent to you.

We will also send you service related email announcements on rare occasions when it is necessary to do so. For instance, if our service is suspended for maintenance, we might send you an email. You do not have an option to opt out of these emails, which are not promotional in nature.

Opt-In

We will obtain your express opt-in consent before we share your personal data with any company outside the DT&T group of companies for marketing or promotional purposes.

DISCLOSURE OF YOUR INFORMATION

We will disclose the data we collect from you to certain third parties who use personal data in delivering their services to us, they use data securely and confidentially and under strict contractual controls in accordance with data protection laws and enforced by DT&T.

We send personal data to the following sets of data processors in order to perform the DT&T Services:

1. Fraud prevention agencies. This is in order to verify your identity, protect against fraud, comply with anti-money laundering laws and to confirm your eligibility to use our products and services;
2. Banking and financial services partners that help us to provide our services;
3. Cloud storage providers where your data is stored safely and securely within DT&T environment;
4. If DT&T or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
5. When we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;
6. In response to lawful requests by public authorities, including to meet national security or law enforcement requirements;
7. When we believe in good faith that disclosure is necessary to protect our rights, fulfil our legal or compliance obligations, protect your safety or the safety of others, investigate fraud, or respond to a governmental or regulatory request;
8. To any other third party with your prior consent to do so.

We may transfer your personal information overseas and to jurisdictions, which may offer a level of legal protection to your information, which does not meet European legal standards. In such cases, we take steps to protect your information and only make such transfers in compliance with the Data Protection Act.

YOUR PERSONAL INFORMATION

Correcting and Updating

Upon request, DT&T will provide you with information about whether we hold any of your personal information. You may request to review, delete or update your personal information to ensure it is accurate, by contacting us in writing. We aim to respond to your request for access within 30 days.

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 may refuse to comply with your request in these circumstances.

Retaining

We will retain your information for as long as your account is active or as needed to provide you services, including a record of your Transactions on our website. If you wish to cancel your account or request that, we no longer use your information to provide you services contact us in writing. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and will securely delete your information when we no longer have a need to retain it.

CHANGES TO PRIVACY POLICY

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 SMS by e-mail and/or when you next start the App or log onto the Site. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.

CONTACT INFORMATION

You can contact us about this privacy policy by writing or email us at the address below:

DT & T Corporation Ltd, 3 Harbour Exchange Square, Canary Wharf, London E14 9GE

Email: privacy@dttcl.com

Phone: +44 (0)20 8806 6444