by SnapSwap International S.A. (“we”, “our”, “us”)
also known as “Everest Project”.
We’re committed to protecting and respecting your privacy. If you have any questions about your personal information please chat with us through the SnapSwap website, or by emailing us at firstname.lastname@example.org.
“You” refers to the business and people who are authorised to use the account. If more than one person is authorised to give instructions on the account, “you” or “your” can refer to any or all of those people.
If you give us personal data about other people (like directors, owners, business partners or employees), or you ask us to share their personal data with third parties, you confirm that you’ve been authorised by them to disclose information about them, and that they understand how we’ll use their personal data.
The information we hold about you
Information we hold about you and people connected to your business will often come from you directly (for example, when you apply to open an account). That information will include:
- our own records of your shareholders (including beneficial owners), suppliers and companies you use or may have agreements with
- other directors, partners, beneficial owners, signatories or employees in your business
- people appointed to act on your behalf
- information submitted through our app or website
For example, when you sign up to the app and provide details such as your name, ID, selfie and address, or details we collect about how you use the app and website.
There may be times when you give us “sensitive” information, which includes things like your racial origin or biometric data. We’ll only use this information in strict accordance with the law.
- Details about your transactions with us
Including any cards and accounts you use.
- Information on how you use your phone
For example the mobile network you use, your IP address or operating system and the settings on your phone.
- Information you give us permission to access on your phone
Things you give us explicit permission to see, like your address book, photos, geolocation and data from your camera.
- Information from social networks or online accounts
Information from any accounts that you share with us.
- Cookie information
How we use your information
To provide our services we use it to:
- Help us maintain the account.
- Track, analyse and improve the services we give you and other customers.
To meet our legal obligations we use it to:
- Search your record at fraud prevention agencies.
- Prevent illegal activities like money laundering, tax evasion and fraud.
- Make responsible lending decisions. We make our decisions automatically using technology. We’ll notify you once we’ve made this decision. You can opt out or ask for a manual review by email and via the app.
To exercise what’s known as our legitimate interests. This is when we use data for a reason which is in your and/or our interest, and which doesn’t involve overriding your privacy rights. We use it to:
- Market products and services generally in app.
- Search your record at credit reference agencies when you sign up (this is a ‘soft search’ and shouldn’t impact your credit score).
With your permission we use it to:
- Check your credit history if you apply for a certain product (this is a ‘hard search’).
- Market and communicate our products and services and those of affiliated partners where we think these will be of interest to you by email. You can always unsubscribe from receiving these if you want to, by email and via the app.
Who we share it with
We may share your personal information with:
- Anyone who works for us when they need it to do their job.
- Any organisation which supports any of our services you use, when they need it to offer those services. That includes:
- Card manufacturers and card personalization bureaus
- Credit reference agencies
- Analytical, Know Your Customer (KYC) and cyber security service providers
- Customer “interface” providers (like the ones who manage our in-app chat service)
- Government authorities (like financial intelligence units, etc.)
- Partner financial institutions (correspondent banks, etc.)
- Customer AML screening solution providers
- Companies that do advertising for us (but we won’t share identifiable personal data with third parties for their own direct marketing unless you give us permission, and you can opt out any time).
- Certain authorities that detect and prevent terrorism (including authorities outside the UK if one of your payments is processed through a worldwide payment system).
- Anyone who you give us explicit permission to share it with.
We’ll also share it to comply with the law; to enforce our Terms and Conditions or other agreements; or to protect the rights, property or safety of us, our customers or others.
How long we keep it
We keep your data as long as you’re using SnapSwap services, and for 5 years after that to comply with the law. In some circumstances, like cases of anti-money laundering or fraud, we may keep data longer if we need to and/or the law says we have to.
You have a right to:
- Access the personal data we hold about you, or to get a copy of it.
- Make us correct inaccurate data.
- Ask us to delete, “block” or suppress your data, though for legal reasons we might not always be able to do it.
- Object to us using your data for direct marketing and in certain circumstances “legitimate interests”, research and statistical reasons.
- Withdraw any consent you’ve previously given us.
To do so, please contact us through the website or by emailing email@example.com.
Where we store your data
We might transfer and store the data we collect from you outside the European Economic Area (“EEA”). People who work for us or our suppliers outside the EEA might also process your data. We may share data with organisations and countries that:
- The European Commission say have adequate data protection.
- We’ve agreed standard data protection clauses with.
Being regulated financial institution obliges us to maintain secrecy of your information entrusted to SnapSwap while using the Everest Project. However, such secrecy requirement ceases where the disclosure of your information is authorised or required by legislation or public authorities.
How to make a complaint
If you have a complaint, please contact us through the website or by emailing firstname.lastname@example.org and we’ll do our best to resolve the issue in the most efficient way. If you’re still not happy, you can refer your complaint to the The National Data Protection Commission (Commission Nationale pour la Protection des Données). For more details you can visit their website athttps://cnpd.public.lu/.
Changes to this policy
We’ll post any changes we make to our privacy notice on this page and, if they’re significant changes we’ll let you know by email.