DT&T Mobile App
DT&T Corporation










Effective from 25 May 2018

 

POLICY

 

1. This policy together with
our Terms and Conditions (as applicable) apply to your use of:

·      
our
websites at
www.dttcl.com and www.dttmt.com (the “Sites”);

·      
the
DT&T Mobile App (“App”) once you have downloaded a copy of the App on to
your mobile telephone or handheld device; and

·      
any
of the services accessible through the App or the Sites

 

2. This privacy policy describes how DT
&T Corporation Ltd collects and uses your personal information, including
the information you provide on the websites, owned and operated by DT &T
Corporation Ltd (“DT&T” “we”, “us” or “our”) or our mobile application.

 

It describes the choices available to you
regarding our use of your personal information, and how you can access and
update this information. 

 

Controller

 

DT &T Corporation Ltd is registered as a
data controller with the UK Information Commissioner’s Office with a
registration number Z3598016.

 

Data Protection Officer

We have appointed a data protection officer
("DPO"). Our DPO has a number of important responsibilities
including:

·      
Monitoring DT&T’s compliance with the GDPR and
other data protection laws;

·      
Raising awareness of data protection issues,
training DT&T staff and conducting internal audits; and

·      
Cooperating with supervisory authorities such as
the ICO on our behalf.

If you have any questions about this privacy
notice, including any requests to exercise your legal rights, please contact us
in writing.

 

INFORMATION WE COLLECT ABOUT AND USES

We will collect and process the following data
about you:

1.      Information
you give us "Submitted Information":
This is information you give us about you by filling in forms on the Websites,
App, at our business locations or by corresponding with us (for example, by
e-mail or via the chat functions on the App and/or the Site).   This includes information you
provide when you register to use the website, App, download or register the
App, subscribe to any of our services, enter into any transaction on the App or
the Site (such as a remittance order), participate in discussion boards or
other social media functions on the App or the Site, enter a competition,
promotion or survey and when you report a problem with an App, the Services, or
the Site.   If you contact us, we will keep a record
of that correspondence.   The information you give us may include
your name, address, date of birth, e-mail address, phone number, the Device’s
phone number, username, password and other registration information, financial,
details of your bank account including the bank account number, bank sort code,
IBAN, details of your debit and credit cards including the long number,
relevant expiry dates and CVC, identification document numbers, copies of identification
documents (for example, passport, driving licence and utility bill) personal
description and photograph and any other information you provide us in order to
prove your eligibility to use our services.

 

2.     Information
we collect about you and your device. Each time you visit the App or our Site
we will automatically collect the following information:

·       Technical information,
including the internet protocol (IP) address used to connect your computer to
the Internet, your login information, browser type and version, time zone
setting, browser plug-in types and versions, operating system and platform,
device information and the type of mobile device you use, a unique device
identifier (for example, your Device’s IMEI number, the MAC address of the Device’s
wireless network interface, or the mobile phone number used by the Device),
mobile network information, your mobile operating system, the type of mobile
browser you use, time zone setting "Device Information";

 

·        Information about your
visit, including the full uniform resource locators (URL), clickstream to,
through and from our site (including date and time), services you viewed or
searched for, page response times, download errors, length of visits to certain
pages, page interaction information (such as scrolling, clicks, and
mouse-overs), methods used to browse away from the page, device information;

 

 

·        Transaction information
including date, time, amount, currencies used, exchange rate, beneficiary
details, details and location of the merchant associated with the transaction,
IP address of sender and receiver, sender’s and receiver’s name and
registration information, messages sent or received with the payment, device
information used to facilitate the payment and the payment instrument used;

 

·        Information stored on
your Device, including if you allow DT&T access contact information from
your address book, login information, photos, videos or other digital content
(Content Information).  The App will
periodically recollect this information in order to stay up-to-date;

 

 

·       Details of your use of
our App or your visits to our Site including transaction details relating to
your use of our services, including whom you have sent money or electronic
money to, foreign exchange transactions you have entered into, the time, date
and location of the place the transaction was entered into.

3.     Location
Information. We use GPS technology and your IP address to determine your
location – this may be used when the App is running in the foreground and
the background of your Device. This is used to prevent fraud, for instance if
your mobile phone is saying that you are based in the UK but your account is
being used in France, we may not allow that transaction to be processed. Our
account protection and fraud-prevention measures require this personal data for
the feature to work. If you wish to use the particular feature, you will be
asked to consent to your data being used for this purpose. You can withdraw
your consent at any time by disabling location permission for the DT&T App
within your device settings "Location
Information
".

 

4.     Information
to help us deliver our service to you. We work closely with third parties in
order to help us deliver our Service to you. These third parties are business
partners, sub-contractors in technical, payment and delivery services,
advertising networks, analytics providers, search information providers, fraud
prevention agencies, customer service providers and developers. Information we
may collect about you from such parties can include information that helps us
to verify your identity or information relating to your payment transactions.

 

5.     If
you allow us to, we will collect friends lists from Facebook and similar
information from other third parties such as Twitter and Google – the App
will periodically re-collect this information in order to stay up-to-date.

 

We use information
held about you in the following ways:

  1. To perform our
    contract with you for the relevant services:

 

·       Register you with an
account;

·       To take steps at your
request prior to entering into it;

·       Provide the Services as
described in our 
terms and conditions;

·       To manage and perform
that contract;

·       Fulfil your Transaction
Request;

·       Send you a confirmation;

·      
To notify you about changes to our service;

·       To update our records;
and

·       To trace your
whereabouts to contact you about your account.

  1. For
    our own legitimate interests or those of other persons and organisation:

·       For good governance,
accounting, and managing and auditing our business operations;

·       To monitor emails,
calls, other communications, and activities on your account;

·       For market research,
analysis and developing statistics; and

·       For send marketing
communications and for marketing to you in our business locations.

  1. To comply with a
    legal obligation:

·       When you exercise your
rights under data protection law and make request;

·       For compliance with
legal and regulatory requirements and related disclosures;

·       For establishment and
defence of legal rights;

·       To verify your identity
to protect against fraud, comply with financial crime laws and to confirm your
eligibility to use our products and services;

  1. Based
    on your consent:

·       When you request us to
disclose your personal data to other people, organisations, or otherwise agree
to disclosures in writing;

·       To send you marketing
communications where we have asked for your consent to do so.

MARKETING

We use your data for marketing purposes and you can
‘opt-out’ from receiving any marketing communications from us whenever you
want.

We have provided you
with choices regarding certain personal data uses, particularly around
marketing and advertising. We have established a ‘Privacy’ section within the
‘Profile’ section of your account where you can view and make certain decisions
about your personal data use in relation to marketing emails and push
notifications. Please see the ‘Privacy’ section within the ‘Profile’ section on
your account for more details.

 

 

 

Choice/Opt-Out

You can ask us to stop sending you marketing
messages at any time by adjusting your marketing preferences via ‘Privacy’
section found within the ‘Profile’ tab on your account or by following the
unsubscribe links on any marketing message sent to you.

We will also send you service related email announcements on rare occasions
when it is necessary to do so.  For
instance, if our service is suspended for maintenance, we might send you an
email. You do not have an option to opt out of these emails, which are not
promotional in nature.

 

Opt-In

We will obtain your express opt-in consent before we share your personal
data with any company outside the DT&T group of companies for marketing or
promotional purposes.

 

DICLOSURE
OF YOUR INFORMATION

We will disclose the data we collect from you to
certain third parties who use personal data in delivering their services to us,
they use data securely and confidentially and under strict contractual controls
in accordance with data protection laws and enforced by DT&T.

We send personal data to the following sets of data
processors in order to perform the DT&T Services:

1.     Fraud
prevention agencies. This is in order to verify your identity, protect against
fraud, comply with anti-money laundering laws and to confirm your eligibility
to use our products and services;

2.     Banking and
financial services partners that help us to provide our services;

3.     Cloud storage
providers where your data is stored safely and securely within DT&T
environment;

4.     If DT&T or
substantially all of its assets are acquired by a third party, in which case
personal data held by it about its customers will be one of the transferred
assets;

5.     When we are
under a duty to disclose or share your personal data in order to comply with
any legal or regulatory obligation or request;

6.     In response to
lawful requests by public authorities, including to meet national security or
law enforcement requirements;

7.    
When we believe in good faith that disclosure is
necessary to protect our rights, fulfil our legal or compliance obligations,
protect your safety or the safety of others, investigate fraud, or respond to a
governmental or regulatory request;

8.     To any other
third party with your prior consent to do so.

We may
transfer your personal information overseas and to jurisdictions, which may
offer a level of legal protection to your information, which does not meet
European legal standards. In such cases, we take steps to protect your
information and only make such transfers in compliance with the Data Protection
Act.

 

YOUR PERSONAL INFORMATION

Correcting
and Updating

Upon
request, DT&T will provide you with information about whether we hold any
of your personal information.  
You may request to review, delete or update your personal information to
ensure it is accurate, by contacting us in writing. We aim to respond to your
request for access within 30 days.

You will not
have to pay a fee to access your personal data (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request is clearly
unfounded, repetitive or excessive. Alternatively, we may refuse to comply with
your request in these circumstances.

 

Retaining

We will
retain your information for as long as your account is active or as needed to
provide you services, including a record of your Transactions on our
website.  If you wish to cancel your
account or request that, we no longer use your information to provide you
services contact us in writing. We will retain and use your information as
necessary to comply with our legal obligations, resolve disputes, and enforce
our agreements and will securely delete your information when we no longer have
a need to retain it.

 

COOKIES POLICY

We use
cookies to remember users’ settings, for authentication and for enhanced user
experience. Users can control the use of cookies at the individual browser
level. This helps us to provide you with a good experience when you use the App
or browse our Site and allows us to improve the App and our Site.

If you
reject cookies, you may still use our website, but your ability to use some
features or areas of our website may be limited.

We
use the following cookies:

·      
Necessary cookies: these cookies enable the
basic use of our Service 
e.g. enabling content reserved for registered users

·      
Personalisation cookies: these cookies allow
our Service to be personalised for you 
e.g. remembering your preferred language or sending country

·      
Analytical cookies: these cookies allow us to
see how people use our Service so that we can understand how to improve
it 
e.g. seeing how many people are logged in at a given time of day

 

 

CHANGES TO PRIVACY POLICY

Any changes
we may make to our privacy policy in the future will be posted on this page
and, where appropriate, notified to you by SMS by e-mail and/or when you next
start the App or log onto the Site. The new terms may be displayed on-screen
and you may be required to read and accept them to continue your use of the App
or the Services.

 

 

CONTACT INFORMATION

You can
contact us about this privacy policy by writing or email us at the address
below:

DT & T Corporation
Ltd, 3 Harbour Exchange Square, Canary Wharf, London E14 9GE

Email: privacy@dttcl.com

Phone: +44 (0)20 8806
6444