Privacy Policy

1. Data Controller

Currency Clear Limited (“we”, “us”, “our”) is the data controller responsible for your personal data. We are registered in England & Wales, Company Number 12192574, with our registered office at 3 Boxgrove Road, Guildford, England, GU1 2LX.

ICO registration: pending.

2. Data Protection Officer

Our Data Protection Officer can be contacted at contact us or by writing to Data Protection Officer, Currency Clear Limited, 3 Boxgrove Road, Guildford, England, GU1 2LX.

3. Information We Collect

We collect the following categories of personal data:

• Identity data: Full name, date of birth, nationality, government-issued identification documents (passport, driving licence, national ID).
• Contact data: Email address, postal address, telephone number.
• Financial data: Bank account details, transaction history, source of funds information.
• Technical data: IP address, browser type, device information, login timestamps.
• Compliance data: Sanctions screening results, PEP status, risk assessments, enhanced due diligence records.

4. How We Use Your Information

We use your information to provide and improve our services, process transactions, comply with legal and regulatory requirements (including anti-money laundering obligations), prevent fraud, and communicate with you about your account and our services.

5. Legal Basis for Processing

We process your personal data on the following legal bases:

• Contractual necessity: To perform our obligations under our agreement with you and provide our payment services.
• Legal obligation: To comply with the Payment Services Regulations 2017, Money Laundering Regulations 2017, and other regulatory requirements.
• Legitimate interests: For fraud prevention, service improvement, and the security of our systems.
• Consent: Where required, for example for marketing communications. You may withdraw consent at any time.

6. Data Sharing

We may share your information with:

• Payment partners and correspondent banks necessary to execute your transactions.
• Regulated Electronic Money Institutions that safeguard your funds.
• Regulatory authorities including the FCA, HMRC, and law enforcement agencies where required by law.
• Sanctions screening and identity verification providers.
• Professional advisers (auditors, legal counsel).
• Technology service providers who assist in operating our platform (subject to appropriate data processing agreements).

We ensure appropriate safeguards are in place when transferring data internationally, including standard contractual clauses approved by the ICO.

7. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction, including encryption, access controls, and regular security assessments.

8. Data Retention

We retain your personal data for as long as necessary to provide our services and comply with legal obligations. In accordance with the Money Laundering Regulations 2017, we retain customer due diligence records and transaction data for at least 5 years after our business relationship ends. Some records may be retained longer where required by law or for the establishment, exercise, or defence of legal claims.

9. Your Rights

Under the UK GDPR, you have the following rights:

• Right of access: To obtain a copy of the personal data we hold about you.
• Right to rectification: To have inaccurate personal data corrected.
• Right to erasure: To request deletion of your personal data (subject to legal retention requirements).
• Right to restriction: To restrict the processing of your personal data in certain circumstances.
• Right to data portability: To receive your personal data in a structured, commonly used format.
• Right to object: To object to processing based on legitimate interests or for direct marketing.

To exercise any of these rights, contact our Data Protection Officer at contact us. We will respond within one month of receiving your request.

10. Right to Complain

If you believe your data protection rights have been infringed, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

We would appreciate the opportunity to address your concerns before you contact the ICO. Please contact our Data Protection Officer first.

11. Cookies

Our website uses cookies. For full details on how we use cookies, please see our Cookie Policy.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date. Where changes are significant, we will notify you by email or through our platform.

Last updated: March 2026