Privacy and Cookies Policy
Who We Are
Oya is a trade name of Volopa Financial Services (Scotland) Limited, authorised by the Financial Conduct Authority FCA FRN 554549 as a ‘Payment Institution’ (Company No SC399401) and referred to as “Oya”in this policy. Volopa’s registered office is at Maclay Murray & Spens LLP, 1 George Square, Glasgow, G2 1AL. We are a company registered in England and Wales under company number SC399401. We are registered on the Information Commissioner’s Office Register; registration number Z2993099. If you have any concerns regarding this policy, please contact our Data Protection Officer by email at email@example.com.
Your privacy and security are important to us. This Policy sets out how we store and use the personal information we collect from individuals and is intended to help you understand how we deal with any personal information we may obtain from you and how you may access, alter, rectify and/or remove it. Under data protection legislation we are the ‘data controller’, and as the data controller we are required to notify you of the information contained in this Policy. It is important that you read this Policy so that you are aware of how and why we are using your personal information.
This Policy relates to the collection, protection, disclosure and use of personal data belonging to individuals who visit www.oyamoneytransfer.com (“Site”),use the Oya App(“App”), contact our customer support team or otherwise provide us with their personal information. We will use your personal information only for the purposes for which it was collected.
This Policy has been prepared to meet the requirements of all relevant laws and regulations relating to data protection including (i) the Data Protection Act 2018 (ii) the Privacy and Electronic Communications Regulations (EC Directive) Regulations 2003 and the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2018, (iii) the General Data Protection Regulation ((EU) 2016/679) (the “GDPR”) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time in the UK unless and until the GDPR is no longer directly applicable in the UK and then (iv) any successor legislation to the GDPR (the “Acts”).
By providing your personal information to us, you agree that we may collect and use all personal information you provide to us in the ways described in this Policy. If you do not agree with the terms of this Policy, please do not provide personal details to us.
Please note that we may need to update this Policy from time to time to reflect changes in the law. Any changes we may make to our Policy in the future will be posted on the Siteand, where appropriate, notified to you by e-mail. We recommend that you check this Policyregularly to ensure that you understand the most recent version.
1. Information That We Collect
1.1. Personal information (or ‘personal data’) means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We process your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information other than as specified in this Policy.
1.2. The information we may collect from you includes, but is not limited to:
- 1.2.1. Correspondence, or a record of it if yous hould contact us;
- 1.2.2. Personal contact details such as name, title, address, telephone number, email address, date of birth, photograph of personal identification document and selfie;
- 1.2.3. Details of your visits to the Site;
- 1.2.4. Details of your usage of the App.
1.3. It is important that the personal information we hold about you is accurate and current. Please advise us if your personal information changes during your relationship with us. If you provide information about another person (e.g. a recipient), you should direct them to this Policy.
2. How we may collect your personal information
2.1. Ways in which you may provide us with personal information include, for example:
- 2.1.1. Submitting information on the Site;
- 2.1.2. Submitting information on the App;
- 2.1.3. Contacting us with an enquiry;
- 2.1.4. Signing up to receive our blog, newsletter, news, events and/or exclusive offers;
- 2.1.5. Reporting an issue; and/or
- 2.1.6. Giving us feedback.
3. How We Use Your Personal information
3.1 We take your privacy and security very seriously and will never disclose, share or sell your personal data without your consent; unless required to do so by law,by court order, by any statutory, legal or regulatory requirement, by the police or any other competent authorities in connection with the prevention or detection of crime or to help combat fraud, money laundering and terrorism financing. We may also report suspicious activity to appropriate competent law enforcement or government authorities. We will only use personal information collected from you for the purposes for which it was collected (or for related purposes), to provide specific services that you request and to provide additional services that may be of interest to you, or in the following circumstances:
- 3.1.1 Ease of Use – To ensure that content from the Site and the App is presented in the most effective manner for you and the electronic device you are using.
- 3.1.2 Communication – To notify you about changes to information we place on the Site, changes to the App or to our services.
- 3.1.3 Compliance – To comply with a legal duty or regulatory obligation to which we are subject (for example to provide you with the Oya money transfer account in accordance with Financial Conduct Authority and HMRC requirements).
- 3.1.4 Legitimate Interests – Where it is necessary for our legitimate interests, and when your interests and fundamental rights do not override those interests. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by any adverse impact on you (unless we have your consent or are otherwise required or permitted to by law).
- 3.1.5 Required checks – To carry out any checks as we deem appropriate to ensure the transaction is not being carried out in a fraudulent manner or is in contravention of any legal or regulatory requirements either in the UK, Nigeria, or any overriding governance requirements of any country or body that may be involved.
3.2 Any information or statistics relating to our business that we may disclose to others shall not identify you personally.
4 Change of purpose
4.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
4.2 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5 Opting out
Where you have consented to us providing you with promotional offers and marketing messages, you can withdraw this consent at any time by opting out of these using the App.
6 Links to other websites
The Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
7 How and where we store your personal information
7.1. All personal information we collect from you is stored on secure servers.
7.2 Personal information in the European Economic Area (“EEA”) is protected by the GDPR but countries outside the EEA may not necessarily have the same standard of protection for your personal information. By providing your personal information to Oya you acknowledge and accept your personal information may be transferred outside of the EEA.
7.3 If the personal information we collect from you is transferred to and stored at a destination outside the EEA, it may also be processed by third parties operating outside the EEA..
7.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the App; any transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorised access.
8 How Long We Keep Your personal information
8.1 Oya will only ever retain your personal information for as long as is necessary for the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements, and for the uses set out in this Policy. We have strict review and retention policies in place to meet these obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. We are required under UK tax law to keep your basic personal information (including name, address, contact details) for a minimum of six years after which time it will be destroyed. Where you have consented to us using your details for direct marketing, we will keep such information until you notify us otherwise and/or withdraw your consent.
9 Sharing and Disclosing Your Personal Information
9.1 We do not share or disclose any of your personal information, other than for the purposes specified in this Policy or where there is a legal requirement.
9.2 We may disclose your personal information:
- 9.2.1 to third parties to assist us in connection with any of our administrative or business functions;
- 9.2.2 In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer;
- 9.2.3 If Oya, or substantially all of its assets, are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets;
- 9.2.4 If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, for example, when the data subject is part of a public consultation process; or
- 9.2.5 To protect the rights, property, or safety of Oya, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of verification, anti-money laundering and fraud prevention.
10 Safeguarding Measures
10.1 Oya takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal information and to prevent your information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We do this using information technology data security techniques and internal operating procedures.
10.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
11 Your Rights
11.1 Under the GDPR you have the right to access personal information that Oya holds about you (commonly known as a “data subject access request”), including:
- (a) Personal information we hold about you;
- (b) The purposes of the processing;
- (c) The categories of personal data concerned;
- (d) The recipients to whom the personal information has/will be disclosed;
- (e) How long we intend to store your personal information for; and
- (f) If we did not collect the information directly from you, information about the source.
If you would like a copy of this information, please email us at firstname.lastname@example.org.
11.2 If you believe that we hold any incomplete or inaccurate information about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified. We may need to verify the accuracy of the new information you provide to us. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.
11.3 You also have the right to request erasure of your personal information or to restrict processing (where applicable) in accordance with the Acts where there is no good reason for us continuing to process it. You have the right to ask us not to process your personal information for marketing purposes. You can exercise this right at any time by opting out of marketing in the App. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.
11.4 Where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. You are not obligated to provide your personal information to Oya, however, as this information is required for us to provide you with the Oya money transfer service, we may not be able to offer the service without it. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. To withdraw your consent, please contact us on email@example.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose you originally agreed to, unless we have another legitimate basis for doing so in law.
11.5 Under certain circumstances you also have the right to;
- 11.5.1 Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- 11.5.2 Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios:
- (a) If you want us to establish the information’s accuracy;
- (b) Where our use of the information is unlawful but you do not want us to erase it;
- (c) Where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- (d) You have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
11.5.3 Request the transfer of your personal information to you or to a third party. If you want to contact us with regards to the information we hold about you as above, please do so by emailing us at firstname.lastname@example.org.
11.6 You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
11.7 If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure your right to access the information and that your information is protected and kept secure.
11.8 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.
12 Cookies Policy
12.1 The Site, like most websites, uses “cookies”. A “cookie” is a small text file that your web browser accepts and stores on your computer whenever you’re browsing a website. Cookies allow the website to recognise your computer. A cookie can identify the pages that are being viewed and this can assist us to select the pages that the visitor sees.
12.2 In addition to using cookies, we might also use GIFs and other web tools, such as Google Analytics, to collect information about your browsing activities whilst on the Site. In this respect the information that is provided is similar to the information supplied by cookies, and we use it for the same purposes.
12.3 Any information that we acquire about you using cookies, GIFs, or other web tools is subject to the same restrictions and conditions as any other information we collect about you, as outlined in this Policy.
- 12.4.1 “Session” cookies only exist whilst visitors are online on a specific occasion. These are temporary cookies that assist you in your journey around the Site and remember the preferences you have selected during your “session” on the Site. These cookies help us ‘remember’ you, so that every time you use the Site, your experience is a little bit smoother. Don’t worry, we don’t store any personally identifiable information that we haven’t asked you for.
- 12.4.2 Cookies make sure we don’t treat you like every other user. We understand your interests, suggest the right things to you and ensure that your time on the Site is always tailored to your specific needs. If it weren’t for cookies, we’d have to treat you and every other user like you’d never been on the site before.
- 12.4.3 “Persistent” cookies, which are not session-based, remain on a visitor’s computer, so that you can be recognised as a previous visitor when you next visit the Site. This allows us to collect information about your browsing habits whilst on the Site, and this can be useful in assisting us to monitor and improve our services. These cookies help us see the way our users use this Site. By studying these patterns, we know how to make the content more user friendly, and if need be, how to prevent any potentially fraudulent activity.
12.5 By continuing to use the site, you’re agreeing to let us place Cookies on your device so we can access them the next time you’re on the Site.
12.6 Cookies we use:
12.6.1 Cookies to measure web usage
Cookies we use when we’re trying to understand how many people visit the Site, which pages are popular and which pages are not. These cookies help us make sure your experience of the site only gets better.
12.6.2 Cookies from social networks
In order to make sure you can use your social networks without interruption when you’re on the site we allow them to send cookies. We can’t see what their cookies read, and they can’t see what our cookies read. We only allow them so that they can understand the way you use their sites, in the same way we use our cookies to understand how you use the site.
12.6.3 Cookies for ads
12.6.4 Cookies for content
12.7 How to delete cookies
If you want to restrict or block the cookies we use you can do so by deleting the temporary internet files and/or cookies from the settings in your browser. If you want to delete the cookies from a browser on a mobile device you should check your device manual.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
14 Learn More
© 2019 Oya. All Rights Reserved. Updated December 2019