Here, you’ll find all the important information about our terms, policies, and compliance standards. We’re committed to being transparent and ensuring our services meet the highest legal and regulatory standards to protect your business and data.
Welcome to MAAYAN’s Privacy Notice. This Privacy Notice is part of Our commitment to ensuring the privacy and security of your personal data.
In Our role as an electronic money institution, We handle various types of personal data, which necessitates adherence to stringent data protection regulations. This policy serves to inform you about the ways in which We handle your personal data – how it is collected, controlled, processed, and shared. Understanding this policy is crucial as it details both your rights and Our responsibilities regarding your personal data. Should you have any queries or concerns, we encourage you to contact Us. We are readily available to assist.
This policy outlines the personal data management practices of MAAYAN regarding the collection and use of personal data. It applies to Website visitors, Customers and all individuals who interact with Our Services.
By engaging with Our Website, Remote System, or utilising any of Our Services, you are consenting to the practices regarding personal data handling as detailed in this policy. We are committed to keeping you informed and may periodically revise this Privacy Notice. Any modifications will be promptly communicated through updates on our Website and Remote System.
If you are only a visitor of this Website, please carefully read section 3 Privacy Practices for Website Visitors of this policy and Our Cookie Policy found in the Legal section of the Website. If You do not agree to these policies, please do not access or use the Website.
If You are a Customer, We advise You to review this policy, especially before providing any personal data, to stay informed about any changes. If at any point You find Yourself disagreeing with the terms of this Privacy Notice or any of its updates, You have the option to terminate Your Agreement with Us. This can be done by closing Your Account, which can be requested via the Remote System or terminating Our Services as set out in the Our Terms and Conditions.
Personal data is collected, processed and stored by MAAYAN staff and contractors under the following applicable laws:
When you visit our Website, We collect information through cookies and similar technologies. Details of this collection are thoroughly described in Our Cookie Policy which governs the specific use of your personal information, with each application depending on the type of cookie involved.
Your personal data may be shared with the following parties:
Our staff, who are permitted to use the personal data only for their official duties, research purposes, and customer support. The personal data is not used for any unrelated purposes.
Our Website hosting service provider, who assists Us in maintaining and hosting Our Website.
We retain the personal data as outlined in Our Cookie Policy, with two exceptions:
If legal obligations necessitate longer retention, We will comply accordingly.
If the personal data is relevant to legal proceedings, it will be retained until the conclusion of those proceedings.
The principles governing the processing of Customers’ personal data form an integral part of the Terms and Conditions. We process personal data in accordance with this Privacy Notice and the applicable data protection laws, using the lawful bases described in this Privacy Notice, including where necessary for the performance of Our Agreement with You, compliance with Our legal obligations and for Our legitimate interests. Where We rely on Your consent to process personal data, We obtain this separately and You may withdraw Your consent at any time.
Upon establishing a business relationship with Us, by accepting the Terms and Conditions and this Privacy Notice You grant Us Your consent to process Your personal data in accordance with the provisions established by this Privacy Notice.
Failure to provide any personal data We may at any time request could result in the termination of Our Services under the provisions of the Terms and Conditions.
When You use Our Services, We shall request that You provide Us with personal data, including sensitive data, regarding You (if You are a legal person, this includes personal data of Your director(s), shareholder(s) and ultimate beneficial owner(s)), Your representative(s) and any third party You transact with using Our Services.
We may also collect the following data:
It is important to acknowledge that no method of data transmission over the internet or electronic storage is completely secure. As such, while We strive to protect Your personal data, We cannot assure or warrant its complete security. Any transmission of personal data is done at Your own risk. For any concerns or queries regarding Our security practices, please feel free to reach out to Us.
Consent: Where We rely on Your consent to process personal data, such as for the provision of Our Services, certain marketing communications or non-essential cookies, We will request Your consent separately. You may withdraw Your consent at any time without affecting the lawfulness of any processing carried out before its withdrawal.
By accepting the Terms and Conditions and this Privacy Notice, You enter into a business relationship with Us and may receive Our Services. We will process Your personal data as necessary to provide the Services, administer Your Account, fulfil Our obligations under the Terms and Conditions, comply with applicable legal and regulatory requirements, and for the other purposes described in this Privacy Notice.
We may use your personal data for:
Legal and Regulatory Compliance: to comply with applicable legal and regulatory requirements, including anti-money laundering, counter-terrorist financing, sanctions screening, fraud prevention, know your customer (KYC), know your transaction (KYT) and other obligations imposed by the Financial Conduct Authority (FCA) and applicable legislation.
Contract Fulfilment: personal data is used to the extent necessary to provide Our Services to You as per the Terms and Conditions, any applicable Service Agreement or other contractual arrangement entered into between You and Us.
Legitimate Interest: for the purpose of marketing Our Services to You (unless You opt out); and where this is necessary to ensure the security of Our network and information systems.
Legal Claims: for the purpose of exercising or defending any legal claims, or whenever courts or tribunals are acting in their judicial capacity.
Tailoring Services: Determining the suitability of Services.
Statistical Purpose: for compiling and maintaining statistics and historical records.
We engage in profiling and automated decisions. This includes:
Profile Creation: Based on age, location, financial data, transaction behavior and trends.
Automated decisions: To monitor transactions and activity for fraud prevention; to accept Customer biometric identification for Customer onboarding and continual monitoring.
Human intervention and monitoring is present, both in profile creation and automated decision making to ensure and check accuracy and effectiveness of these processes.
MAAYAN staff and third party contractors collect, process and store personal data as relevant to their functions and for their specific purpose.
Section 2 of Our Terms and Conditions refer to Our third party arrangements. We may collect and disclose personal data to third parties as explained in this Privacy Notice, for the purpose of providing Our Services as set out in the Terms and Conditions.
MAAYAN has in place adequate data sharing arrangements and safeguards for all personal data it shares with its third party contractors to ensure protection and security of the personal data.
Specifically, Your personal data may be shared with any of the following third party contractors (or their subcontractors), in which case their corresponding privacy policies are also applicable to any personal data of Yours that may be shared with them:
If you can not access any of the privacy policies of any of the above third parties, please contact Us to request these.
Your personal data may further be shared with any third-party intermediary involved in the payment chain of any Payment Order You may authorise MAAYAN to make.
MAAYAN may also share data with its regulatory authorities, the Financial Conduct Authority (FCA) and the Information Commissioners Office (ICO); or any other public authority, agency or body who has jurisdiction or authority over MAAYAN or any person or contractor that may process the data.
MAAYAN has in place appropriate technical and organisational safeguards to protect personal data. These safeguards include:
If You would like further information about who We have shared your personal data with, what personal data We have shared and the arrangements and safeguards in place to ensure the security of the personal data, You may request this information from MAAYAN’s Data Protection Officer (DPO).
We reserve the right to transmit information or personal data about You as well as activity in Your Account to law enforcement institutions, state authorities and financial institutions, if this is necessary to comply with relevant legislation, and in order to demonstrate that the Terms and Conditions and applicable legislation have not been violated.
Closing your Account does not automatically result in the deletion of the personal data We hold about You.
We will retain your personal data for a minimum period of 5 (five) years from the date of termination of Our relationship with You, unless otherwise required for legal purposes.
All transaction history data is retained for a period of 10 (ten) years from the date of the relevant transaction.
Data protection legislation offers You certain rights related to Your personal data. Provided all processing of personal data is lawful and uncontested, these rights are not absolute and may be subject to certain exceptions and limitations. Nevertheless, they can be summarised as follows:
Right of access and information; being the right to receive confirmation from Us that certain personal data relating to You is being processed, the purpose and details of the processing.
Right to rectification of inaccurate or incomplete data that We hold about You, though We may need to verify the accuracy of the new data You provide to Us.
Right to erasure of Your personal data. This provides You the right to be forgotten where the personal data is no longer necessary for the purpose for which it was collected, or You withdraw Your consent to its processing.
Right to request the restriction or suppression of processing of Your personal data, for example where You have requested the correction of any inaccurate data, pending Our verification of its accuracy or correction.
Right to data portability to obtain Your personal data by automated means and/or request Us to transmit it directly to another service provider of Your choice.
Right to object to any processing of Your personal data, where such processing is performed by Us on the basis of a legitimate interest.
Right to contest automated decision-making; You have the right to request information regarding automated decisions made; to make representations regarding such decisions; to request human intervention in relation to such decisions and to contest these decisions.
Right to withdraw Your consent at any time where We are relying on Your consent to process Your personal data. However, this will not affect the lawfulness of any processing carried out before You withdrew Your consent. If You withdraw Your consent, We may not be able to provide certain Services to you. We will advise You if this is the case at the time We receive You request.
If you wish to exercise any of the rights set out above, please contact MAAYAN’s Data Protection Officer (DPO).
You will not generally have to pay a fee to exercise Your rights set out above. However, We may charge a reasonable fee (based on administrative costs) if for example You require further copies of copies already provided to You; or if We consider Your request to be unfounded, repetitive or excessive.
We may need to request specific information from You to help us confirm Your identity and to more effectively assess Your request. This is a security measure to ensure that rights are not exercised by persons that have no rights to that personal data; and correct data is not adversely manipulated.
We try to respond to all legitimate requests within 30 (thirty) days. Occasionally it could take Us longer if Your request is particularly complex or You have made a number of requests. In this case, We will notify You and keep You updated.
If We consider Your request to be clearly unfounded, repetitive or excessive, We could refuse to comply with Your request in these circumstances.
If We cannot comply with Your request due to legal restrictions, such as Our data retention obligation We will notify You accordingly.
We shall communicate any rectification or erasure of personal data or restriction of processing carried out to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort.
At MAAYAN, we adhere to widely recognised industry standards to safeguard Your personal data, implementing organisational and technical security measures to prevent accidental loss, unauthorised access, modification, or disclosure of Your personal data.
In the event of a suspected or known personal data breach, We shall notify You promptly and keep You informed of the activities taken to fix and eliminate the incident.
Our Website and Remote System feature links to external websites, which have their own privacy practices that may differ from this Privacy Notice. When you provide data to those third-party websites directly, it is subject to their respective privacy policies. MAAYAN bears no responsibility or liability for the privacy policies of those external websites, nor for any data that You may have provided directly to them or that may be collected and processed by those external websites during Your visit to them. We recommend that you review the privacy policies of all external websites that You interact with.
Furthermore, this Privacy Notice does not extend to the practices of third-party entities You may engage with while using Our Services. This includes entities such as mobile network operators or other users of Our Services. We advise contacting these third parties directly to understand their privacy policies before sharing Your data with them.
MAAYAN is the controller of Your personal data for the purpose of providing the Services.
You may contact Our Data Protection Officer (DPO) at the following contact details:
E-mail [email protected]
All communication and information shall be provided by electronic means, where possible, unless You request otherwise.
If You feel Your personal data rights have been infringed You have the right to:
12.1 make a complaint to MAAYAN’s Data Protection Officer (DPO)
12.2. lodge a complaint with the Information Commissioners Office (ICO).
Please refer to this ICO link to make a complaint: https://ico.org.uk/make-a-complaint/data-protection-complaints/
12.3. alternatively, You may view Our Complaints Policy.