1. Overview
In order for Millbank FX to provide you with payment services we need to collect certain information about you and/or your company. We will endeavour not to be intrusive and refrain from asking any unnecessary questions. When we collect this information we are regulated under the General Data Protection Regulations, which apply throughout the European Union and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Please read this notice carefully along with our terms and conditions and any other document referred to in it.
2. What information do we collect?
During the course of our interactions by telephone, email or our online portal and your visits to our website we will collect information on you that includes:
- Contact information including your name, address, email address, telephone number, nationality, date of birth and signature.
- Identity information may include a copy of your driving licence, passport, and/or a recent utility bill, or other information verifying your identity and address, or to answer additional questions to help verify your information.
- Interaction with our website. We collect information about the device you are using, such as the type of device, operating system and platform, the type and version of browser, browser plug-in types and versions, the times you access our website/app and the time zone setting, mobile network information and unique device identifier, which may include your Device’s IMEI number and/or MAC address, or the mobile phone number used by the Device. We do not capture GPS information about you.
- Contact and Call History. Information on when, how and why dialogue has taken place between Millbank and you as a client. We may monitor communications such as emails and telephone calls for quality assurance, training, fraud prevention and compliance.
- Transactional Information. This includes the amount, currency and type of the transaction, source of funds, exchange rate, recipient name and bank details, recipient address for some jurisdictions and, optionally, the recipient’s email address and phone number.
Providing data is optional however in order qualify for certain services Millbank FX may be required by law. If you are unable to provide your information we may not be able to provide you with the requested service.
3. How do we use your personal information?
Our primary purpose in collecting your information is to provide you with a smooth, safe and seamless service. We use your information as follows:
- We will use your information in order to furnish you with critical service updates, respond to customer service requests, resolving customer complaints, conducting customer surveys, enabling the provision of services, confirm opening of a Millbank FX account, send notices and other disclosures as required by law, sending you notices of money transfers carried out through Millbank FX.
- We would like to send you information about products, services and our business that may be of interest to you. From time to time we would like to send you information on the currency market events and news. We will ask you your preference on receiving this information if and when you sign up to trade with us. If you do opt in to receive such information you may opt out at any time by emailing privacy@millbankfx.com
- Compliance and risk management. As an authorised financial institution we are duty bound to carry out background checks on individuals, companies, our counterparties and also to monitor ongoing transactions. This is to prevent money laundering and fraud and includes helping Millbank FX to protect clients from fraudulent activity on their accounts. We carry out checks to ensure we do not deal with countries, entities or individuals that are subject to sanctions, to comply with counter-terrorist financing and anti-money laundering regulations and to identify high-risk individuals where we need to add additional controls. We also conduct investigations into actual or suspected violations of our Terms of Use.
4. Cookies
The Millbank FX website uses cookies, including third party cookies, for different purposes. This is to provide you with a good experience when you browse our website and will help us build a profile of our users. You can set your browser not to accept cookies but this may result in some of the website features may not function as a result.
5. Information sharing
At no point will Millbank FX sell, lease rent or giveaway any of your information. The information that we collect from you may be transferred to, and stored in, a country outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for our suppliers. These staff may be engaged in the fulfilment of your request, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. By submitting your information and making use of Millbank FX, you agree to such transfers, storing or processing. In instances where we share your information, we require the companies to comply with appropriate privacy and confidentiality requirements, and security standard best practices.
6. Third Party Processors
Our carefully selected partners and service providers may process personal information about you on our behalf as described below:
Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:
(i) Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.
7. Law enforcement and Credit referencing
We may share your information with Credit reference agents and Law enforcement agencies in connection with any investigation to help prevent unlawful activity. We will not share your personal information with any other third parties.
8. Security
Millbank are committed to ensuring security measures are in place to protect client data. These measures and in place to prevent data loss, misuse of data and unlawful disclosure. All Millbank FX employees who have access to client personal data are required to comply with our policy. Measures include locked doors and file cabinets, secure disposal of private information, use of anti-malware, encryption, firewalls and secure communications software. Our systems are regularly tested by external security experts in order to stay at the pinnacle of information security technology developments.
9. Customer Rights
Under the GDPR, you have a number of free of charge rights. These include:
- Rectify any incorrect information we hold about you
- Require the deletion of personal information concerning you (right to be forgotten) when we no longer have reason to hold it
- Access to your personal information and to ask us not to process information where you previously gave consent
- Object to decisions being taken by automated means and profiling
- Object to us using your information for marketing purposes as specified under marketing.
In order to exercise any of these rights you may do so by emailing us at privacy@millbankfx.com or by calling your account manager.
10. Contacting us
Millbank FX is the controller of your personal information. You can contact us at any time by email to privacy@millbankfx.com or in writing to Millbank FX Ltd, 46 Gresham Street, London, EC2V 7AY.
You also have the right to lodge a complaint with the UK information Commissioners Office if you believe we have not handled your request or complaint in an efficient manner.
11. Children's Policy
Millbank FX remain in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act) We respectfully ask that minors, or people under the age of 18 do not submit any information to us. Our website and services and not directed or aimed at minors under the age of 18.
12. Changes to Millbank FX privacy policy
From time to time we may update the Millbank FX privacy policy. We will inform you if there are any material changes. Your continued use of our website after posting of a new policy will constitute your acceptance and agreement of any changes.
