This website is provided by Fexserv Financial Services Ltd and describes our use of your personal information when you use this website, any of our mobile software applications (Apps) or platforms (collectively the Online Services), bureaux de change stores, customer services telephone lines and when you interact with us using other channels such as social media platforms, as well as information we receive when you purchase or use Fexserv Branded products which are provided by our partners. These services and products are collectively referred to in this policy as ‘Fexserv Services’. The Fexserv Services you may purchase or use are provided by Fexserv Financial Services Ltd or by our partners.
Information we collect:
We collect and process personal information in three ways::
1) Information you give us
Personal Information. When you use the Fexserv Services, we may ask for information about you. This may include your:
• Date of birth
• Home address
• Billing address
• Office address
• E-mail address
• The form(s) of identification you provide (e.g. ID Card, Passport or Driving Licence) and the personal information contained within those forms of identification
• Mobile telephone number
• Landline telephone number
• Credit or debit card information
• Other payment details, such as your bank account information, as required by us in order to complete your transaction and provide your payment choices and travel details (including future travel dates and destinations).
If you do not provide the information we require to process a transaction, we may not be able to proceed with your order.
2) Information we collect from your use of our services
We may collect information about you, the Fexserv Services and how you use them. This could include:
Transactional information about our Services and how you use them.
• Information you share with us when you contact us for any reason either in writing, by phone or by any other means. This may for example be in-store at one of our bureaux or through social media.
• Registration details when you set up an account with us.
• Content you post on our websites, including personal descriptions, photographs and videos.
• Information when you take part in promotions, competitions or surveys.
• Registration information when you sign up to loyalty schemes offered by us.
• Details of your visits to the Online Services. This includes page interaction and Online Services site activity, including which website you came from, pages you viewed during your visit, and the page you viewed immediately after you left.
• Data collected by cookies and corresponding technologies, together with the personal information we have collected.
• Location information, for example your IP address, registered beacons or GPS (geo-location) signals. We may use your exact geo-location when you have consented to it.
• Your marketing preferences.
• CCTV images from equipment in place at our bureaux de change stores for the purposes of prevention and detection of crime and public safety.
3) Information we receive from third parties
We may also receive information from third parties. This may include: Non-personal information used to supplement existing information, such as demographics and affluence metrics (e.g. social-demographic groupings through matching postcode information) Information about you from other sources with whom we work closely to provide the Fexserv Services to you, including third party payment and delivery service providers, identity verification and fraud prevention services, and other companies in the Fexserv group.
How we use the information we collect
We may use your information for the following purposes:
• Collecting payment, processing and fulfilling your order and otherwise providing you with the information, products and services you may request from us;
• Complying with our legal and regulatory obligations (including fraud prevention, anti-money laundering and sanction screening). This may include checking the information you provide to us against information from other sources;
• Enforcing any contract entered into between you and us for the Fexserv Services Contacting you (including by email or SMS) with marketing messages according to your preferences;
• Providing you with any alerts or other messages you have registered to receive
• Providing you with service messages, notifying you about changes to our Services or changes to our terms, conditions and policies;
• Improving customer experience and our quality of service;
• Data analysis to allow us to derive insight and to help make the Fexserv Services personalised and relevant, as well as to develop our business processes, products and services;
• Enabling us and third party websites to display relevant and targeted advertisements, based on previous behaviour, purchases, or any other relevant information.
Information we share
We may disclose your personal information to any member of the Fexserv Group (a list of Fexserv Group Companies is available here). We do not share personal information with companies, organisations or individuals outside of Fexserv for marketing purposes or otherwise, nor do we sell your personal information except for the following situations:
• We have your prior consent to do so;
• We are using a third party to send targeted advertisements, using an identifier such as an email address or site cookies We have aggregated, non-personally identifiable information, which is to be used for segmentation, statistical modelling, general research or trend analysis;
• We sell or buy any new business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business assets;
• We are purchased by a third party, in which case personal information held by us including you as our customer will be transferred. We will notify you of this through the most appropriate means;
• We need to comply with the obligations we have to our third party product issuers or third parties providing products or services on our behalf, so that they may process your order or otherwise provide the information, products or services you have requested (please note that these third party product issuers have their own privacy policies and accordingly we cannot accept any responsibility or liability for the handling of personal information by such third parties in accordance with such policies);
• We are under a duty to disclose or share your personal information in order to comply with our legal obligations or in order to enforce our conditions of sale (including the Online Terms and Conditions) and other agreements; or to protect the rights, property, or safety of Fexserv, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Retention of Personal Information
Your personal information will be retained in accordance with statutory periods contained in regulations applicable to financial transactions including those in anti-money laundering, anti-terrorist financing and other laws applicable to us. Otherwise, we will retain your information only if necessary for the specific purposes it was collected, or to resolve any query you may raise. We will typically keep your information for no longer than the purpose(s) for which it was obtained, unless we have a legal obligation to keep it for a longer period or retention is advisable for Fexserv’s legal position (for example, regarding applicable statutes of limitations, litigation or regulatory investigations).
Maintenance of Accurate Information
We strive to ensure that the information we maintain about our customers is accurate, current and complete. We respond to requests from customers to correct inaccurate information in a
timely manner so please tell us if you think we hold incorrect information about you at the address below.
We have a number of security measures in place to protect your personal information. However, when transmitting personal information over the internet, please bear in mind that no transmission over the internet can ever be guaranteed secure. Therefore, please note that we cannot guarantee the security of any personal information that you transfer over the internet to us.
Similar to other websites, our website utilizes a standard technology called ‘cookies’. A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer’s (or other device’s) browser from a website’s server and is stored on your computer’s (or other device’s) hard drive. Cookies allow a website to remember things like your preferences or whether you have logged in, and they allow us to tailor our website to your interests. Information supplied by cookies can also help us to analyze your use of our website and help us to provide you with a better user experience.
We currently use one type of cookies being Essential Cookies for the internet service. These are session cookies that expire at the end of the session (that is, once you log-out of the mobile device or internet service) or when the browser is closed. The cookies we use are: JSESSIONID, for both the private Website and the Console. If you block or refuse these cookies you might not be able to log in or use the internet service.
We currently do not use Non-Essential Cookies.
Whilst we take measures to ensure that your personal data cannot be intercepted by third parties, please note that when using our website, data is transported over an open network (the internet) which is accessible to third parties and which cannot be regarded as a secure environment. We may transmit or store any data provided by you when using our website outside
your country of residence. In such cases, we will make every effort to secure an appropriate standard of protection for your data, including those relating to client confidentiality and data protection, but it is possible that data may be relayed to a country in which the prevailing standards of data protection are lower than in your country of domicile. We accept no responsibility or liability for the security of your data during transmission via the internet. We would like to draw your attention to the fact that you can communicate with us by other means whenever you consider it appropriate on data protection grounds.
Links to Third Party and Fexserv Group websites
Our Website may, from time to time, contain links to and from the websites of our group companies, selected partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and accordingly we cannot accept any responsibility or liability for such policies. It is therefore advisable to check these policies before you submit any personal information to these websites.
You have a number of rights in relation to the information that we hold about you. These rights include:
• The right to access information we hold about you and to obtain information about how we process it;
• In some circumstances, the right to withdraw your consent to our processing of your information, which you can do at any time. We may continue to process your information if we have another legitimate reason for doing so;
• In some circumstances, the right to receive certain information you have provided to us in an electronic format and / or request that we transmit it to a third-party;
• The right to request that we rectify your information if it’s inaccurate or incomplete;
• In some circumstances, the right to request that we erase your information. We may continue to retain your information if we’re entitled or required to retain it;
• The right to object to, and to request that we restrict, our processing of your information in some circumstances. Again, there may be situations where you object to, or ask us to restrict, our processing of your information but we’re entitled to continue processing your information and / or to refuse that request.
You can exercise your rights by contacting us using the details set out in the “Contact Us” section below. We will endeavor to respond to your request within 30 days but response time may vary depending on the laws and regulations applicable to your request, and we may be entitled to extend this period in certain circumstances. We will comply with your request to the extent required by applicable law. Please note that certain requests may require us to perform further identification and/or verification procedures to ensure that the request is coming from you.
You also have a right to complain to the Malta Information and Data Protection Commissioner’s Office by visiting https://idpc.org.mt, or to the data protection regulator in the country where you live or work.
Removal from Fexserv Email Marketing Communications
You may want to discontinue receiving information from us. While this may mean that you will not receive product or service information of interest to you, we respect anyone’s wishes not to be informed directly of these promotions or product introductions by emailing email@example.com.
You will also be provided with an unsubscribe link in any email or SMS marketing message we send you.
Fexserv does not knowingly collect or solicit personal information from individuals under 13 years of age. If you are under 13 years of age, you should not register or provide personal information on the Fexserv Applications. If we later obtain actual knowledge that a user is under 13 years of age, we will take steps to remove that user’s personal information from our systems. If you believe that we might have any information from or about a child under 13, please contact us as indicated under the “Contact Us” section below.
Providing personal information about other people
You can provide us with another person’s personal information to enable us to contact them (for e.g. by recommending a friend to use Fexserv Services, or by entering them into a competition). By providing the other person’s information you are confirming that they have given their explicit consent for you to provide their email address, mobile phone number or postal address to us and for us to contact them by email, phone or post. A message may be sent to the other person using the contact details provided by you and this message will make reference to your name and explain to the recipient that you were the source of his/her contact details.