Privacy Policy

Redbanx Ltd (“Redbanx”, “we”, “us”, “our”) is committed to protecting and respecting your personal data.

This Privacy Policy explains:

• What information we collect
• How we use that information
• Who we share it with
• How we protect it
• Your rights

By using our website, contacting us, or using our services, you acknowledge that your personal data will be processed in accordance with this Privacy Policy

1. What Information We Collect

1.1 Information You Provide to Us

You may provide personal information when you:

• Use our website
• Apply for an account
• Enter into a contract with us
• Communicate with us by phone, email or otherwise

1.1.1 Initial Information

To use Redbanx services, you may be required to provide:

• Full name
• Residential or business address
• Email address
• Telephone number

We may also request identification documents such as:

• Passport or driving licence
• Proof of address (e.g. utility bill)

1.1.2 Additional Verification Information

We may request additional information where:

• We are unable to verify your identity
• A query arises from background or screening checks
• You carry out higher-risk or higher-value transactions
• It is required under applicable financial crime regulations

This may include:

• Additional identity documents
• Source of funds or source of wealth evidence
• Business activity information
• Supporting documentation (e.g. bank statements, contracts, transaction records)

1.1.3 Communications

When you communicate with us, we may retain:

• Emails and correspondence
• Records of conversations
• Call recordings

Calls may be recorded for:

• Training and quality assurance
• Transaction evidence
• Regulatory compliance

1.1.4 Transaction Information

When you use our services, we collect information relating to transactions, including:

• Payment amounts and currencies
• Exchange rates
• Source of funds
• Beneficiary name and bank details (e.g. account number, IBAN, SWIFT)
• Payment purpose
• Recipient details (where required by jurisdiction)

1.2 Information Collected When You Use Our Website

We may collect:

• IP address and device identifiers
• Browser type and version
• Pages visited and time spent on the site
• Navigation behaviour and interaction data

This helps us:

• Improve website functionality
• Monitor performance
• Detect and prevent fraud

1.3 Information from Third Parties

We may receive information from:

1.3.1 Identity Verification Providers

We verify your identity using third-party providers.

This may include checks against:

• Credit reference agencies
• Identity databases

These checks may leave a record on your credit file.

1.3.2 Financial Crime and Background Checks

We conduct checks on:

• Individuals
• Businesses
• Directors, shareholders and beneficial owners

This may include data obtained from:

• Screening providers
• Public records
• Regulatory databases

1.3.3 Other Sources

We may receive information from:

• Business partners
• Payment and banking partners
• Analytics and technology providers

Where applicable, we will only use such data for marketing where consent has been provided.

1.4 Sensitive Data

We do not intentionally collect special categories of personal data.

If such data is provided, it will be processed only where necessary and in accordance with applicable law.

2. How We Use Your Information

We use your information for the following purposes:

2.1 Providing Services

• To provide payment and electronic money services
• To process transactions
• To manage your account

2.2 Compliance and Risk Management

As a regulated Electronic Money Institution, we are required to:

• Conduct customer due diligence (KYC / KYB)
• Monitor transactions on an ongoing basis
• Screen against sanctions, PEP and adverse media databases
• Prevent fraud, money laundering and terrorist financing

We may also investigate:

• Suspicious activity
• Breaches of our terms or policies

2.3 Communication and Customer Service

We use your information to:

• Respond to enquiries
• Confirm account and transaction details
• Manage complaints
• Provide service updates

Some communications are mandatory and cannot be opted out of.

2.4 Marketing

Where permitted, we may use your data to:

• Provide updates on services
• Share relevant insights or offers

You can opt out of marketing communications at any time.

2.5 Service Improvement and Account Management

We use your data to:

• Verify identity and maintain account accuracy
• Detect, prevent and investigate fraud
• Improve our services and systems
• Maintain the security of our platform

2.6 Use of Third-Party Data

We may combine third-party data with information you provide to:

• Assess risk
• Make onboarding decisions
• Monitor account activity

3. Cookies

We use cookies to:

• Enable website functionality
• Improve performance
• Analyse usage

You can manage cookies through your browser settings.

4. Sharing Your Information

We may share your information with:

4.1 Service Providers

Including:

• Identity verification providers
• Technology and infrastructure providers
• Fraud and screening services

4.2 Banking and Payment Partners

To process transactions, we may share data with:

• Banks and safeguarding institutions (including ClearBank Limited)
• Payment service providers
• Correspondent banks

4.3 Financial Crime and Risk Management

We share data to:

• Conduct AML and sanctions screening
• Prevent fraud and financial crime

4.4 Regulators and Legal Authorities

We may disclose data to:

• The Financial Conduct Authority
• Law enforcement
• Other authorities where required by law

5. International Transfers

Your data may be transferred outside the UK.

Where this occurs, we ensure appropriate safeguards are in place.

6. Data Retention

We retain data:

• For at least 5 years to meet regulatory obligations
• Longer where required (e.g. legal or regulatory investigations)

7. Data Security

We use appropriate safeguards including:

• Encryption
• Secure systems and infrastructure)
• Access controls

8. Your Rights

You have the right to:

• Access your data
• Correct inaccurate data
• Request deletion (where applicable)
• Object to processing
• Request data portability
• Withdraw consent

9. Contact

Redbanx Ltd
1 Great Cumberland Place, London

Email: info@redbanx.com

Complaints

You may contact the Information Commissioner’s Office (ICO).

10. Changes to This Policy

We may update this Privacy Policy from time to time.