Privacy Policy

Please read this privacy policy carefully. By viewing or using this site you agree that you have read and accepted this privacy policy (as amended and posted on this site from time to time) and our terms of use as set out on the site (of which this privacy policy forms part). You may only use this site if you consent to the use of your personal data as are set out in this privacy policy and if you agree to be bound by our terms of use.

Introduction
In this privacy policy (“Privacy Policy”), the expressions “we” and “us” means EBC Group. We take your privacy seriously and this Privacy Policy explains the steps we take to ensure information about you is kept secure and confidential. This document outlines the EBC approach to Data Privacy to fulfil our obligations under the EU General Data Protection Regulation (GDPR) 2018 of 25th May 2018. We also welcome it as an opportunity to reassure you of the importance we place on keeping your personal data secure, and of the strict guidelines we apply to its use.

The information we collect from you

Purposes for which we use your personal information

• Enabling access and use of the EBC website
• Manage and Administer your Pre-Paid Card
• Process your funds transfers and transactions
• Processing your account information
• Provide information regarding products and services that we feel may be of interest to you (see the “Marketing” section below)
• To comply with our legal obligations for the prevention of fraud, money laundering, counter terrorist financing or misuse of services
• Verifying your identity
• Contacting you regarding our service to you
• Where requested by law enforcement for investigation of crime

Our legal basis for proessing the personal data

• receipt of your consent
• performance of a contract where you are a party;
• legal obligations that EBC is required to meet;
• national law

Any legitimate interests pursued by us, or third parties we use, are as follows

• the prevention of fraud, money laundering, counter terrorist financing or misuse of services

Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified above. Consent is required for EBC to process personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

Consent for Children Under 16

If you are giving consent on behalf of a child under 16 then please be aware that Children need specific protection with regard to their personal data, as they may be less aware of the risks, consequences and safeguards concerned, and also of their rights in relation to the processing of personal data for the purposes of using these services. By consenting to this privacy notice on behalf of a minor you are giving permission for their data to be used for the purposes described above.

Withdrawal of Consent Conditions

You may withdraw consent from direct marketing at any time by contacting our Administrator / Compliance Administrator. Please note, where you have consented to your data being used for carrying out financial transactions, then the right to withdraw consent does not exist. As a payment service provider, EBC is obliged to retain data concerning financial transactions for 6 years in accordance with national law for the purpose of preventing, detecting and investigating, by the FIU or by other competent authorities, possible money laundering or terrorist financing

Disclosing information about you

EBC will only pass on your personal data to third parties, including internationally, once we have obtained your consent. Some of our service providers, like payment processors, risk management solutions and suppliers are based outside of the EEA. Where we authorize the processing or transfer of your personal information outside of the EEA, we require your personal information to be protected to data protection standards and we ensure that there are adequate safeguards in place for data protection. The GDPR prohibits transfers of personal data outside the European Economic Area to a third country that does not have adequate data protection. Where transfer occurs outside the EEA the following mechanisms are in place with the third parties:

• Data Protection clauses in our contracts and agreements with third-parties
• EU-US Privacy Shield
• Personal Information Protection and Electronic Documents Act (PIPEDA)

Marketing

We and/or our partners will only use the personal information obtained from you to enable us to provide you with information by email, telephone or post regarding products and services that we feel may be of interest to you if you have provided your consent for us to do so by ticking the relevant box(es) on this website where your personal information is collected.

If you wish to withdraw consent to use this information at any time for either us and/or our partners’, then you should contact the Administrator.

We may need to disclose your personal information if you breach this Privacy Policy and/or our terms of use or in connection with legal proceedings or potential legal proceedings or if otherwise required to do so by law or any other Governmental or law enforcement agency.

Retention period

EBC will process personal data for the duration of the contract for services and will store the personal data for 6 years after that date of termination of the contract.

Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. Your data relating to financial transactions, accounts or cards cannot be deleted due to national law associated with the prevention of fraud, money laundering, counter terrorist financing or misuse of services for crime.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organization.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

You have the right to complain as outlined below. All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data. You will find a copy of our Subject Access Request Form on our website.

Security

Keeping your personal information secure is very important to us. We will take appropriate and up-to-date measures to protect your personal information. However, no data transmission over the Internet can be guaranteed to be totally secure. As a result, whilst we strive to protect your personal information, we cannot ensure or warrant the security of any information which you send to us, and you do so at your own risk.

Transferring your information abroad

We may store, process and/or transfer the personal information you submit to us through use of the Site to countries outside of the European Economic Area including (without limitation) to the USA. Personal data transferred outside of the EEA will be stored and processed by our group companies or representative offices for business and management purposes, to perform a contractual obligation owed by us to you and/or to provide you with information or services that you have requested. By using this Site, you consent to us transferring your personal information to countries outside the EEA for our legitimate business purposes as outlined in this paragraph. We will take appropriate steps to protect your personal data.

Cookies

Cookies are small files on your computer, which can store information that you transmit when accessing the internet. They are transmitted via the web browser to the computer’s hard drive. Cookies cannot transmit any information from a computer system. They instead help to make a return visit to the Site as simple and user friendly as possible. Some cookies remain on the computer’s hard drive so that Partner recognises your computer on your next visit. You can change your browser options at any time to deactivate cookies. (Some functions are only accessible when cookies are enabled and we therefore recommend allowing cookies.)

Links

This web site contains links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. This privacy policy applies solely to information collected by this Site. 

Privacy related questions or complaints

If you have any questions relating to this Privacy Policy or how we use your personal information, or if you believe that we have not complied with this Privacy Policy with respect to your personal information, you may write to our Compliance Administrator at [email protected]. You should also use this address if you would like to request a copy of your personal information from us or to review or modify any part of your personal information at any time. We reserve the right to charge a fee for each copy request.

In your letter, please clearly set out your question or request or, if you have a complaint, describe in as much detail as possible the ways in which you believe that our Privacy Policy has not been complied with and we will investigate and provide you with a response.