Privacy Policy

Privacy Notice Pathfinder FX Ltd

Updated November 2022

Background

Pathfinder FX Limited understands that your privacy is important and all due care is taken with any collected personal data. We respect and value the privacy of all of our service users and customers and will only collect and use personal data in ways that are described below. We only collect what data is necessary to fulfil our duties to you, the customer and what is required by law in regards to the activities we engage in to deliver an efficient and compliant service to you, the customer.

This Privacy Notice (Notice) explains in detail the types of personal data we may collect about you and what we do with your personal data. It also sets out what we do to keep your personal data secure, as well as your rights in relation to the personal data we hold about you.

1. Information About Us

Pathfinder FX Limited. Company number 10226764

Foreign Exchange Consultancy registered in England under company number.

Information Commissioner's office number: ZA574195

Registered address: 1 Knights Court, Battlefield Enterprise Park, Shrewsbury SY13FA

Data Protection Officer: Gareth Bowles

Email address: gb@pathfinder-fx.com

Telephone number: 01743 290955

2. What Is Personal Data?

Personal data is, in simple terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

3. What Personal Data Do You Collect and How?

We may collect and hold some or all of the personal and non-personal data set out below, using the methods also set out in the table. We do not collect any sensitive personal data, personal data relating to children or data relating to criminal convictions and/or offences.

Data Collected

Identity Information including name, title, date of birth, gender.

Contact information including telephone number, email address

Copies of documents to prove your age or identity so we can satisfy our ‘Know Your Customer’ checks. For example, the government issued ID, passport, driving licence, marriage certificate and utility bill.

Payment information including Bank account details

Business information including Name of Business, employee details, Nature of business

Personal details of your payees (“Beneficiary Details”) – note: by providing this information to Pathfinder FX, you agree to have obtained the payee’s consent to their personal data being processed by us in accordance with this Notice.

Details of the transactions you carry out when using our Services, including geographic location from which the transaction originates and where you are likely to send payments too

How We Collect the Data

When you visit our website

When you make an enquiry about our Services or open an account with us online, over the telephone, by post or in person

When you ask us to provide our Services to you

When you exchange and transfer your foreign currency with us

When you enter into a competition or take up a promotional offer

When you sign up to receive our newsletter and other general marketing from us

When you have given a third-party permission (e.g. a Referring Partner) to share with us your personal data

When you report a problem, make a query, or issue a complaint about our services

During correspondence with Pathfinder FX employees (or persons acting on our behalf) over telephone*, email, post or in person

*We are obliged to record telephone calls, in regards to arranging contracts over the phone

4. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in this Notice.
The right to access the personal data we hold about you.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in this Notice.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in in this Notice to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us. It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in this Privacy Notice.

5. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. Data Protection Law sets out six lawful basis that organisations, businesses and governments can rely on to collect and process personal data. Pathfinder FX predominantly relies on the following: Consent This means processing your personal data where you have explicitly given us permission to do so. Performance of a Contract This means processing your personal data in order to fulfil our contractual obligations with you. Legal Obligations This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject. Legitimate Interests This means processing your personal data where we or a third party have a legitimate interest to do so. We make sure we consider and balance any potential impact on your rights before we process your personal data for our legitimate interests. Where our interests are overridden by a negative impact on your privacy rights, we will not process your personal data. The following table describes how we will use your personal data, and our lawful bases for doing so:

What We Do

To deliver our foreign exchange and international payment services.

To respond to your queries and complaints.

To comply with our legal and regulatory obligations.

Personalising and tailoring our products and services for you.

For training and quality purposes

To keep you informed about relevant products, special offers and market news.

what data we use

Your personal data, your contact information and any other data required for us to deliver the services.

Your personal data and your contact information.

Your personal information, your documents and any other such data.

Your personal information, your payment information, your documents and any other such data.

All categories of your data.

Your personal data and your contact information.

our lawful basis

Performance of a contract.

Legal obligation.

Legitimate interest.

Consent – you can ask to be removed from these contact lists at any time.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in this Notice. If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so. In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

6. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary. In accordance with our legal and regulatory obligations (for example, Money Laundering Regulations), we will retain your personal data for a period of six years from the end of your relationship with us. Inactivate Accounts If you have not used your account for more than two years, it will be flagged as inactive and we’ll contact you to ask whether you want to keep it open. Unless you reply to say ‘yes’, we will close and deactivate your account. Closed Accounts If you inform us you wish to have an account with Pathfinder FX, we will close and deactivate your account. At the end of the retention period, your personal data will either be anonymised (so that it can only be used in a non-identifiable way for statistical analysis, business planning), made inaccessible or unintelligible (for system integrity purposes) or deleted completely. However, we may retain your information beyond this retention period if we have a legitimate business interest to do so (or we can rely on another lawful basis).

7. How and Where Do You Store or Transfer My Personal Data?

We will only store your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation. We will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office. Please contact us using the details in this Notice for further information about the particular data protection safeguards used by us when transferring your personal data to a third country. The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

8. Do You Share My Personal Data?

We may share your personal data with the following entities for the purposes described in this Policy: 1) Third party service providers This includes:

Auditors and professional advisers such as lawyers and consultants.
Banks and financial services who facilitate our foreign exchange transactions.
Companies who host, support, and maintain our website, databases, archives, and other business systems.
Companies who provide off-site hard copy information management facilities.
Companies who perform functions on our behalf in the areas of IT development, IT support, back office, compliance, and finance.
Companies that provide our email archiving and backup system.
Companies that provide our telephone call recording system and tracking analysis software.
Companies that carry out our direct marketing and research survey emails and texts.

2) Public authorities & Regulatory Bodies This will only be in response to lawful requests made from public authorities, regulatory bodies, and law enforcement in order to meet national security, public interest and/or our legal and regulatory obligations. 3) Referring Partners If you have been referred to Pathfinder FX by a third party who you and Pathfinder FX both have a separate direct relationship with (e.g. an estate agent, law firm or an independent financial advisor), we may provide such third party with personal data relating to you (name & trading activity) in which they are interested in by virtue of Pathfinder FX’s agreement with them (e.g. for verifying and allocating commission earnt or to monitor the success of referrals) and where your interests and privacy rights do not override those interests. 4) Other third parties With your consent only, we may pass your data to a third party for their direct marketing purposes. We may also pass your personal data to third parties for the purposes of administering Pathfinder FX promotions/prize draws/competitions you have entered in to. We will rely on our legitimate interests to do this. In the event we sell our business, we may disclose your personal data to prospective purchasers and their advisers so they can evaluate the relevant business. We will rely on our legitimate interests to do this. Please note our websites may, from time to time, contain links to and from the websites of our 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 that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites. Sharing your personal data outside of the UK and EEA To facilitate our global operations, the personal data that we collect from you may be transferred to, and stored at, destinations both in and outside the UK and EEA. Where processed outside the UK and EEA, we will take appropriate steps to ensure your personal data still receives a level of protection that is consistent with UK and European data protection standards. For example, we will only share your personal data outside the UK and EEA if a) the location has received an adequacy decision from the UK government or European Commission b) we have an EU approved model clauses agreement in place or if the third party receiving your personal data has signed up to an UK or EU approved data sharing mechanism.

9. How Can I Access My Personal Data?

If you want to know what personal data, we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 10. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

10. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details: Email address: gb@pathfinder-fx.com

11. Changes to this Privacy Notice

We may change this Privacy Notice from time to time in accordance to changes of legislation in this area, or if we change our business in a way that affects personal data protection. Any changes will be made available and published on our website.