Privacy Policy

Last updated: May 25, 2018

  1. Introduction

 This Privacy Policy explains what you can expect from us and what we need from you in relation to your personal data. The data controller is Segovia Technology UK Limited at 41 Corsham Street, London, N1 6DR. Our registration number with the Information Commissioner’s Office UK is ZA282361. If you have any questions about how we protect or use your data, please email us at privacy@thesegovia.com.

Segovia Technology UK Limited (“Segovia”) offers a software platform and services to help businesses and individuals send money to emerging markets. We collect data about our customers and their payees (“Data”) when they use our platform, our services, and our websites (collectively, “Services”). This privacy policy describes how we collect, use and disclose Data.

In this privacy policy, we sometimes refer to “You”. “You” may be a Visitor to one of our websites, a customer of one or more of our Services (“Customer”), or a payor / payee of a Customer (“Payee”). This policy does not apply to third-party websites, products, or services even if they link to our Services, and you should consider the privacy practices of those third-parties carefully. If you object to the practices described in this policy, you should (a) remove cookies from Your computer after leaving our website, and (b) discontinue your use of our Services.

We may change this Privacy Policy from time to time. We will post any changes, and such changes will become effective when they are posted. Your continued use of our Services following the posting of any changes will mean you accept those changes. We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.

  1. How we handle your data

We receive Data from Visitors to our website, and Customers using our Services. The collection and use of data is crucial to providing our Services and keeping the Services safe. Data helps us increase the safety of your online payments, while reducing the risk of fraud, money laundering and other harmful activity. Generally, Data can be categorized into data that directly identifies you individually or the legal entity with whom you are affiliated (“Personal Information”) and data associated with your activities (“Activity Information”).

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using Transport Layer Security technology. You are responsible for keeping confidential any passwords we give you. We ask you not to share this password with anyone else and not to use this password for other services or products.

  1. Collecting Personal Information

You may have to provide us with Personal Information to sign up for, or make use of, our Services. This data includes the following, for yourself and your recipient:

We may collect Personal Information about you from other sources. For example, we may

  1. Collecting Activity Information

We also automatically collect Activity Information based on your use of our Services. This data would include your activities on our website, or actions performed on our payment platform. For example, we may collect:

Our Website also uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you use our Website and also allows us to improve our Website. By continuing to use our Website, you are agreeing to our use of cookies.

Personal Information and Activity Information we collect is stored in compliance with our various regulatory obligations for anti-money laundering and fraud purposes.

  1. Data Use

When you sign up for an e-money account to effectuate payments through our Service, you enter into a contract with us to make these payments on your behalf. We must process your Data to fulfil this contract. Further, we are required by law to collect, process, and retain your Data, in fulfilment of our anti-money laundering regulatory obligations. We use your Data in the following ways:

We may combine information from the Services together and with other information we obtain from our business records or from third party sources.

  1. Data Sharing

We may share Data to ensure that we can continue providing you with the Services you have contracted.

Segovia may share your Personal Information and Activity Information with:

Segovia may share only Activity Information (and not Personal Information) with:

  1. How We Protect Your Data

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using Transport Layer Security technology. We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. If you feel your interaction with us is no longer secure (e.g., you believe your account has been compromised), please contact us immediately.

  1. Your Rights

Customers in the European Union (EEA) and Switzerland. If you are a resident of the EEA or Switzerland, the following information applies to your Personal Information that we have processed or collected.

Purposes of processing and legal basis for processing: As explained above, we process Personal Information in various ways depending upon your use of our Services.  We process Personal Information on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services; and (3) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedom related to data privacy.

Right to lodge a complaint: Users that reside in the EEA or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.

Transfers: Personal Information that we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates, subcontractors, or partner payment processors maintain facilities. The laws in the U.S. and other countries regarding personal information may be different from the laws of your state or country.  Any such transfers will comply with safeguards as required by relevant law. It may also be processed by staff operating outside the EEA who work for us or for one of our payment processors. Such staff maybe engaged in, among other things, the fulfilment of your payment order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.

Individual Rights: If you are a resident of the EEA or Switzerland, you are entitled to certain rights under the General Data Protection Regulation (“GDPR”) over Personal Information that we have processed or collected. We have listed below how these rights operate in the context of using Segovia’s Services. You may contact us at privacy@thesegovia.com to request the exercise of these rights. We will make every effort to respond promptly, and in any case within 30 days of your request. We may take measures to verify your identity before processing a request.

  1. Our Partners

Our Services 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.

  1. Changes to this Policy

Any changes we may make to our Privacy Policy will be posted on this page and, where appropriate, notified to you by e-mail or in your Segovia account. Please check back frequently to see any updates or changes to our privacy policy.

Contact us

If you have any questions about this Privacy Policy, please email us at privacy@thesegovia.com. If you feel that we have not addressed your questions or concerns adequately, you may make a complaint with the Information Commissioner’s Office in the United Kingdom. You may access their details via https://ico.org.uk/global/contact-us/.