Real Transfer Limited

Real Transfer Limited, a company incorporated in Northern Ireland, United Kingdom having its registered address at Office 8, Merrion Business Centre, 58, Howard Street, Belfast, Northern Ireland, BT1 6PJ, operating under the brand name ‘Aspora’ (formerly known as ‘Vance’) (“Aspora”, “we”, “us”, “Company”) is concerned with protecting the privacy of any personal information that you may choose to provide to us (“Personal Information”). Aspora will attempt to ensure that the use of your Personal Information is compliant with the Data Protection Act 2018 and General Data Protection Regulation (Regulation (EU) 2016/679) (“Data Protection Laws”). Accordingly, Aspora issues this policy to inform you of our use of your Personal Information.

We are committed to protecting your Personal Information. Please read the following terms of the Privacy Policy carefully to understand our practices and how we will treat your Personal Information.

1. Introduction

1.1. This Privacy Policy sets out the way in which Aspora collects and processes Personal Information, as well as the steps we take to protect such information.

1.2. By utilising our Services, you acknowledge that you have read, and agree to, the terms of this Privacy Policy and that you consent to the use by Aspora of your Personal Information for the purposes set out in paragraph 3 of this Privacy Policy. If you do not wish to provide your Personal Information on the basis set out in this Privacy Policy, you should not enter the relevant information on the Platform or provide your Personal Information to us otherwise. However, if you do not provide your Personal Information, you may not be able to use all or part of the Services we offer.

1.3. Capitalised terms not defined in this Privacy Policy shall be as defined in the Terms of Service.

1.4. This Platform – https://www.aspora.com/ – is operated by Aspora.

1.5. Definitions:

1.5.1. “You” means the user who is using the services of Aspora.

1.5.2. “Personal Data” means information that specifically identifies an individual or that is linked to information that identifies a specific individual.

1.5.3. “Visitor” means an individual other than a user, who uses the public area, but has no access to the restricted areas of the Platform or Service.

1.6. Principle. This policy is based on the following data protection principles:

1.6.1. The processing of personal data shall take place in a lawful, fair and transparent way;

1.6.2. The collecting of personal data shall only be performed for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;

1.6.3. The collecting of personal data shall be adequate, relevant and limited to what is necessary in relation to the purpose for which they are processed;

1.6.4. The personal data shall be accurate and where necessary, kept up to date;

1.6.5. Every reasonable step shall be taken to ensure that personal data that are inaccurate having regard to the purposes for which they are processed, are erased or rectified without delay;

1.6.6. Personal data shall be kept in a form which permits identification of the data subject for no longer than it is necessary for the purpose for which the personal data are processed;

1.6.7. All personal data shall be kept confidential and stored in a manner that ensures appropriate security;

1.6.8. Personal data shall not be shared with third parties except when necessary in order for them to provide services upon agreement;

1.6.9. Data subjects shall have the right to request access to and rectification or erasure of personal data, or restriction of processing, or to object to processing as well as the right of data portability.

2. Information that we collect

2.1 As part of providing you with the Services, we collect your Personal Information on registering an account. “Personal Information” means any information from which you can be personally identified:

2.1.1 We may collect, store and use information about your computer, mobile device or other item of hardware through which you access the Platform and your visits to and use of the Platform (including without limitation your IP address, geographical location, browser/platform type and version, Internet Service Provider, operating system, referral source/exit pages, length of visit, page views, website navigation and search terms that you use);

2.1.2 To the extent that we collect and process documentation on behalf of our partner banks to assist them with complying with various statutory requirements including without limitation anti-money laundering procedures, we may collect a copy of your passport, director and shareholder information, driving licence and evidence of proof of address. These documents contain various elements of personal and company information;

2.1.3 We collect payment information including your financial or payment instrument details (either debit/credit card) or bank account details to comply with our legal obligations and to provide you with our Services. Collection of this information is also necessary for us to collect payment for your use of our Services;

2.1.4 We collect recipient information including the recipient’s full name, postal address, phone number, depending on the disbursement method selected certain financial institution or financial account details such as bank account or mobile wallet account. If there is a dispute about whether money has been received by the recipient, we may ask you for additional information so we can verify their identity with our partner banks, financial institutions and payments partners. This information is necessary for us to comply with our legal obligations in relation to the Terms of Service and to provide our Services;

2.1.5 If you choose to subscribe to our service, you will be required to enter your email address;

2.1.6 You may be given opportunities to provide us with other information from time to time;

2.1.7 When you contact us by email or telephone or through any contact form provided on the Platform, we may ask you to provide some or all the following information:(a) your name;(b) your address;(c) your email address; and/or(d) details of any search effected by you and/or any transaction executed by you with any partner.

2.1.8 When you sign up to our waitlist for upcoming product launches, your name, address and email address will be collected to ensure you get notified of our product launches in a timely manner.

2.2 Not all the personal information we hold about you will come always directly from you. We may also collect information from third parties such as our partner, service providers, vendors, publicly available websites (i.e., Facebook, Google, Twitter, Instagram, LinkedIn), to comply with our legal and regulatory obligations, offer Services we think may be of interest, to help us maintain data accuracy and provide and enhance the Services.

3. Usage of your personal information by us

3.1 We will process your Personal Information in accordance with the Data Protection Laws and to provide you with the Services. We will process your Personal Information to enable us to:

(a) provide our services to you on the Platform;

(b) assist our partner banks, financial institutions and payments partners with providing their services to you;

(c) manage and administer the Platform;

(d) enable you to use the Platform;

(e) send you newsletters and other relevant and targeted promotional communications;

(f) notify you of changes we have made or plan to make to the Platform;

(g) invite you to our waitlist. In particular, we might send you a link to download and sign up to the waitlist;

(h) send you email and trade confirmations and a welcome email as necessary;

(i) request feedback from you on any transaction effected by you through the Platform;

(j) deal with enquiries, complaints and feedback from you and our service providers;

(k) provide third parties with statistical anonymised information about our users;

(l) analyse and improve the services offered on the Platform.

3.2 If at any time you wish us to stop processing your Personal Information for the above purposes, then you must contact us and we will take the appropriate steps to stop doing so. Please note that this may mean that your Account will be closed. You may contact us by sending an email to dpo@aspora.com.

3.3 To ensure a good quality of service we may monitor any communication you have with us whether in writing or by electronic mail (“Recordings”) or any inbound and outbound calls done by any member of Aspora team. Any recordings remain the property of Aspora and will be used only for the purposes listed above.

3.4 In the event that the purposes for processing change, then we will notify you as soon as practicable and seek any additional consent that may be required.

4. Disclosure of your personal information

4.1 Except as described in this Privacy Policy, we will not intentionally disclose the Personal Data that we collect or store on the Service to third parties without your prior explicit consent.

4.2 Except to the extent required by any applicable law or governmental or judicial body, we will only disclose such of your Personal Information to our partner banks, financial institutions and payments partners as is required for us or them to perform our or their services to you.

4.3 We will use all reasonable endeavours to ensure that any partner banks, financial institutions and payments partners to whom we disclose your confidential information is compliant with the Data Protection Act 2018 (or an equivalent standard) as regards its use and storage of your Personal Information.

4.4 Personal Information and transactional information may be used by us, the partner banks, financial institutions and payments partners for the following reasons:

(a) to track the amount of commission payments, if any due to us from the broker;

(b) to monitor the Transaction;

(c) to contact you to request feedback on the transaction; and

(d) to improve our services to you by tailoring the Platform to your requirements.

4.5 In the event that we sell or buy any business or assets, we may disclose your Personal Information and transaction data to the prospective seller or buyer of such business or assets. If substantially all of the assets of Aspora are acquired by a third party, personal data and transaction data held by it about its customers will be one of the transferred assets.

4.6 We will disclose your Personal Information if we are under a duty to disclose or share your personal data and transaction data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and other agreements; or to protect the rights, property, or safety of Aspora, the Platform, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

4.7 If at any time you wish us to stop processing your Personal Information for the above purposes, then you must contact us and we will take the appropriate steps to stop doing so. Please note that this may mean that your Account will be closed. You may contact us dpo@aspora.com.

5. Data subject rights

5.1 We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. Your principal rights under the Data Protection Laws are as follows:

(a) the right for information (a monetary charge may be levied on you to meet our costs in providing you with the details we hold about you);

(b) the right to access;

(c) the right to rectification;

(d) the right to erasure; the right to be forgotten;

(e) the right to restrict processing;

(f) the right to object to processing;

(g) the right to data portability;

(h) the right to complain to a supervisory authority; and

(i) the right to withdraw consent.

5.2 If you wish to access or amend any other Personal Data we hold about you, or to request that we delete any information about you, you may contact us by sending an email to dpo@aspora.com. We will acknowledge your request within seventy-two (72) hours and handle it promptly. Aspora will respond to these requests within a month, with a possibility to extend this period for particularly complex requests in accordance with Applicable Law. We will retain your information for as long as your account is active, as needed to provide you Services, or to comply with our legal obligations, resolve disputes and enforce our agreements.

5.3 You may update, correct, or delete your Account information and preferences at any time by accessing your Account. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

5.4 You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some or all of the features and functionality of the Service.

5.5 At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by Applicable Law.

5.6 In accordance with Applicable Law, we reserve the right to withhold personal data if disclosing it would adversely affect the rights and freedoms of others. Moreover, we reserve the right to charge a fee for complying with such requests if they are deemed manifestly unfounded or excessive. Aspora may charge a reasonable administrative-cost fee if further copies are requested.

5.7 We may use your Personal Data for the purposes of automated decision-making when displaying your activity and offers based on your trends and interest. When such processing takes place, we will request your explicit consent and provide you with the option to opt-out. We may also use automated decision making in order to fulfil obligations imposed by law, in which case we will inform you of any such processing. You have the right to object to the processing of your personal data for automated purposes at any time by contacting us at dpo@aspora.com.

6. Contact us

6.1 For full details about the Aspora group members and where they operate, please contact us at: dpo@aspora.com.

6.2 If at any time you believe that we have not adhered to this Privacy Policy, please contact us at dpo@aspora.com and we will seek to promptly determine and correct the problem.

7. Data protection authority and DPO details

For UK residents:

• Data Protection Authority: Information Commissioner’sOffice (ICO)
• Data Protection Officer (DPO) at Aspora: dpo@aspora.com

8. Advertising and use of cookies

8.1 We collect browser and cookie information when you first navigate to our websites. We use cookies to give you a better customer experience and for use of access. Certain cookies will allow you to leave and re-enter the Platform without re-entering your password. This will be monitored by a web server.

8.2 Cookies are text files stored, either on a temporary or persistent basis on the hard drive of your computer. Cookies are used for authenticating, session tracking and maintaining specific information about the use and users of the Platform (including user site preferences or the contents of electronic shopping carts). Cookie files may also be placed on your computer by Google Analytics for the purposes as set out in this paragraph.

8.3 The data collected by cookies is anonymous. You can delete all cookies that are already on your computer’s hard drive by searching for files with “cookie” in it and deleting them. In addition, if you want to stop cookies from being stored on your computer, you can edit your browser settings so that cookies are blocked. Unfortunately, if you block cookies, you may not be able to use the full functionality of the Platform.

8.4 Web beacons consist of a small string of software code that represents a graphic image request on a Web page or email. There may or may not be a visible graphic image associated with the web beacon and often the image is designed to blend into the background of a Web page or email. Web beacons can be used for many purposes – including site traffic reporting, unique visitor counts, advertising auditing and reporting, and personalization. Web beacons used by Aspora collect only anonymous data.

8.5 In order to improve the Platform and the Services, we use (temporary and persistent) cookies, authorised third parties cookies, web beacons and/or other technologies to collect non-personally identifiable data. This non-personally identifiable data helps us to track browsing behaviour, to create specific or tailor-made offers or advertisements, and to monitor and record the visits and use of the Platform.

8.6 In order to understand how people use the Platform and for marketing analysis and quality improvement purposes, we (and/or third party service providers) may collect, record, process and use on an anonymous basis certain information (including the total number of transactions, viewed web pages, referring/exit pages, platform type, date/time stamp information and details like the number and location of mouse clicks on a given page, mouse movements, scrolling activity and the search words you use while being on and using the Platform).

8.7 If you register with us or if you continue to use the Platform, you agree to our use of cookies. You further agree to use the Platform only for lawful purposes.

8.8 From time to time you may find links to third party websites on the Platform. These links are provided for your information only and are not recommended by Aspora. Aspora has no control over the content of third party sites and accepts no responsibility or liability for them or for any loss or damage that may arise from your use of them. When accessing a third party website, you are advised to check such website’s terms of service and privacy policy to ensure compliance with applicable laws.

9. Minors and children’s privacy

Protecting the privacy of minors is especially important. Our Service is not directed to children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18. If you are under 18 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Data has been collected on the Service from persons under 18 years of age, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained an Account on the Service, then you may alert us at dpo@aspora.com and request that we delete your child’s Personal Data from our systems.

10. Security

10.1 We take appropriate security measures to protect against loss, misuse and unauthorized access, alteration, disclosure, or destruction of your information. Aspora has taken steps to ensure the ongoing confidentiality, integrity, availability, and resilience of systems and services processing Personal Information, and will restore the availability and access to information in a timely manner in the event of a physical or technical incident.

10.2 No method of transmission over the internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or organisational safeguards. If you believe your Personal Data has been compromised, please contact us at dpo@aspora.com.

11. Data retention and international transfers

11.1 The data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom (UK). It may also be processed by staff operating outside the UK who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

11.2 All information you provide to us are stored on our secured servers.

11.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted through our Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

11.4 We transmit Personal Information using Secure Sockets Layer (SSL) software which encrypts information you input. Further, to the extent that we collect any credit card or bank account information from you, we will only reveal the last four digits of your credit card number when confirming an order. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

12. Changes to this Privacy Policy

Please note that this Privacy Policy may change from time to time. If we change this Privacy Policy in ways that affect how we use your Personal Information, we will advise you of the choices you may have as a result of those changes. We will also post a notice that this Privacy Policy has changed.