Last updated 31 March 2021 (Version 1.3)
1. Protecting your data
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us.
- We will:
- Always keep your data safe,
- Never sell your data,
- Allow you to manage and review your marketing choices at any time
- Legal Basis for using your data:
- contractual or legal duty,
- legitimate interest,
- public interest,
- vital individual interest or,
2. Data Controller
Amaiz Ltd are the data controller responsible for your personal data and we are registered with the Information Commissioner’s Office with reference number ZA308506.
3. Data Protection Compliance Manager
We have appointed a data protection compliance manager, who has a number of important responsibilities including:
- Monitoring Amaiz’s compliance with the GDPR and other data protection laws;
- Raising awareness of data protection issues, training Amaiz staff and conducting internal audits; and
- Cooperating with supervisory authorities such as the ICO on our behalf.
You can contact our data protection compliance manager at: email@example.com
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us via email.
4. Information we collect about you
We will collect and process the following data about you:
a) Information you give us "Submitted Information": This is information you give us about you by filling in forms or on the App and/or the Site, or by corresponding with us (for example, by e-mail or). It includes information you provide when you register for an Amaiz account,, subscribe to any of our services, enter into any transaction (such as a Top Up, Instant Transfer, Amaiz Bank Transfer, Electronic Money Exchange), participate in discussion boards or other social media functions, enter a competition, promotion or survey and when you report a problem with your account, the Services, or the Site. If you contact us, we will keep a record of that correspondence, and may use redacted information for other services. The information you give us may include your name, address, date of birth, e-mail address, phone number, username, password and other registration information, financial, details of your account including the bank account number, sort code, IBAN, details of your debit and credit cards including the long number, relevant expiry dates and CVC, identification document numbers, copies of identification documents (for example, passport, driving licence and utility bill) personal description and photograph and any other information you provide us in order to prove your eligibility to use our Services.
b) Information we collect about you and your Device. Each time you visit the App or our Site we will automatically collect the following information:
(i) technical information, including the internet protocol (IP) address used to connect your computer or Device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, Device information and the type of mobile device you use, a unique Device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting "Device Information";
(ii) information about your visit, including the full uniform resource locators (URL), clickstream to, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse overs), methods used to browse away from the page, device information;
(iii) transaction information including date, time, amount, currencies used, exchange rate, beneficiary details, details and location of the merchant or ATMs associated with the transaction, IP address of sender and receiver, sender's and receiver's name and registration information, messages sent or received with the payment, device information used to facilitate the payment and the payment instrument used;
(iv) information stored on your Device, including if you allow Amaiz to access contact information from your address book, login information, photos, videos or other digital content, check ins (Content Information). The App will periodically recollect this information in order to stay up-to-date;
(v) details of your transaction details relating to your use of our services, including who you have sent money or electronic money to, foreign exchange transactions you have entered into, the time, date and location of the place the transaction was entered into.
c) location Information. We use GPS technology and your IP address to determine your location – this may be used when the App is running in the foreground and the background of your Device. This is used to prevent fraud, for instance if your mobile device is saying that you are based in the UK, but your card is being used to enter into an ATM Withdrawal or point of sale purchase in Spain, we may not allow that transaction to be processed. Our card protection and fraud-prevention measures require this personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling location permission for the Amaiz App within your device settings "Location Information".
d) Information to help us deliver our service to you. We work closely with third parties in order to help us deliver our Service to you. These third parties are business partners (such as those we partner with to offer additional Amaiz Services like credit), sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, fraud prevention agencies, customer service providers and developers. Information we may collect about you from such parties can include credit search information, information which helps us to verify your identity or information relating to your payment transactions. Please see the 'Disclosure of your Information' section for more information.
5. How we use your data
We use your information for the following purposes, the legal basis for which are:
- contractual or legal duty,
- legitimate interest,
- public interest,
- vital individual interest or,
To provide the Amaiz Services:
In order to register an Amaiz account, we must verify your identity. This includes collecting identity documents and carrying out electronic checks.
To carry out our obligations arising from any transactions you enter into with us, for example Top Ups, Instant Transfers, Amaiz Bank Transfers, Electronic Money Exchanges, ATM Withdrawals and Amaiz Card Purchases and to provide you with the information, products and services that you request from us.
To combat against fraud:
- To verify your identity to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our products and services; and
- To help us better understand your financial circumstances and behaviour so that we may make decisions about how we manage your Amaiz Account;
To help market and provide new products and services that interest you:
- To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- To make suggestions and recommendations to you and other users of our Site and the App about goods or services that may interest you or them; and
- To process applications for products and services available through us including making decisions about whether to agree to approve any applications.
To keep the Amaiz Services up and running:
- To administer our Site and the App for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to ensure that content from our site is presented in the most effective manner for you and for your computer;
- To allow you to participate in interactive features of our service, when you choose to do so;
- To notify you about changes to our service; and as part of our efforts to keep our Site and the App safe and secure.
To provide location-based Services:
Location-based services may be used to prevent your card being used fraudulently.
We use your data for marketing purposes and how you can ‘opt-out’ from receiving any marketing communications from us whenever you want.
We have established an Amaiz Subscription Centre, where you can view and make individual decisions about your personal data use concerning marketing emails. For push notifications, please see your mobile device setting for more details.
We may use your personal data (such as your Submitted Information, Location Information or transaction information) to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have signed up to and/or utilise the Amaiz Services and, in each case, you have not opted out of receiving marketing notifications.
Third-party Marketing: We will obtain your express opt-in consent before we share your personal data with any company outside the Amaiz group of companies for marketing or promotional purposes.
Opting Out: You can ask us or third parties to stop sending you marketing messages at any time by adjusting your marketing preferences by following the unsubscribe links on any marketing message sent to you.
7. Legal Basis for using your data
Legitimate Interest: this means the interest of ours as a business in conducting and managing Amaiz Ltd. to enable us to provide to you the Amaiz Services and offer the 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 the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Fulfilling a Contract: this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Our Legal Obligation: this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent: this means that we will only process your personal data for certain specific purposes if we obtain your consent before such processing, for example in order to collect and process your location data and/or to send you notifications about local merchants. We are also required, under the Payment Services Regulations 2017, to obtain your consent for the use of your personal data in order to provide our services to you. We normally ask for your consent at the point when you download our App or register for Amaiz Account. Please note that if you do not provide your consent for this purpose, or withdraw it at a later stage, we may be unable to provide our services to you.
8. Your rights
You have rights under data protection laws in relation to your personal data:
- Your right of Access:
You have the right to request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you. If you require this, then please reach out to our support team via the in-App chat function or email firstname.lastname@example.org
- Your right of rectification
You have the right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you require this, then please reach out to our support team via the in-App chat function or email email@example.com.
- Your right to erasure
You have the right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. As an FCA authorised firm, Amaiz is under certain obligations to retain certain data for a minimum of 6 years (see above). Please note that these retention requirements supersede any right to erasure requests under applicable data protection laws.
- Your right to object
You have the right to object to processing of your personal data. This is in situations where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights. As an FCA authorised firm, Amaiz is under certain obligations to process and retain certain data for compliance purposes. Please note that these requirements supersede any right to objection requests under applicable data protection laws. If you object to the processing of certain data, then we may not be able to provide the Amaiz Services and it is likely we will have to terminate your account.
- Request restriction of processing of your personal data.
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
a) if you want us to establish the data’s accuracy;
b) where our use of the data is unlawful, but you do not want us to erase it;
c) where you need us to hold the data 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 data, but we need to verify whether we have overriding legitimate grounds to use it. Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you (including the Amaiz Services). In this case, we may have to cancel your use of the Amaiz Services, but we will notify you if this is the case at the time.
- Request the transfer of your personal data to you or to a third party.
We will provide to you, your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. If you require this then please reach out to our support team via the in-App chat function or email firstname.lastname@example.org.
- Withdraw consent.
You can withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide the Amaiz Services to you. We will advise you if this is the case at the time you withdraw your consent.
Fees: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
9. Disclosure of your information
- Data processing partners:
We will disclose the data we collect from you to certain third parties who use personal data in delivering their services to us, they use data securely and confidentially and under strict contractual controls in accordance with data protection laws and enforced by Amaiz.
We send personal data to the following sets of data processors in order to perform the Amaiz Services:
- Fraud prevention agencies
This is in order to verify your identity, protect against fraud, comply with anti-money laundering laws and to confirm your eligibility to use our products and services;
- Cloud storage providers
This is in order to safely and securely store your data with Amaiz;
- Banking and financial services partners
Financial services providers that help us provide the Amaiz Services, Authorised Third Party Providers (as defined in our App terms and conditions) and other banking partners, banking intermediaries and international payments services providers;
- Card manufacturing/personalisation and delivery companies
For the purpose of creating your personalised Amaiz card and delivering this to you at your requested address;
- Advertisers and analytics providers
If we decide to engage advertisers to promote our products and services, the advertisers and their advertising networks may require anonymised personal data to serve relevant adverts to you and others. We will never disclose identifiable information about individuals to advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 700 men aged under 28 have clicked on their advertisement on any given day). We may also use such aggregate information to help our advertising partners provide a tailored and targeted campaign, relevant for a sub-section of our users (for example, women in Manchester). In some instances, we may use personal data we have collected from you to enable our advertising partners to display their advertisement to their target audience; We also use analytics and search engine providers that assist us in the improvement and optimisation of our site;
- Companies within the Amaiz group
In order to provide a unified service across all of our products and services, we may disclose your personal information to any member of the Amaiz group, which means any of our subsidiaries or related entities. Companies in the Amaiz group will be acting as joint controllers or processors in order to provide the Amaiz Services.
- We may also disclose your personal information in the following circumstances:
If Amaiz or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. We will ensure that any information disclosed in the course of due diligence and/or negotiations for sale is pseudonymised and in the event disclosure is necessary for the purpose of such anticipated transaction, the personal data disclosed is limited to what is absolutely necessary for the purpose of such transaction.
If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
In order to:
(i) enforce or apply the General Terms of Service and/or the Business Terms and/or any other agreements between you and us or to investigate potential breaches; or
(ii) protect the rights, property or safety of Amaiz, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Third party services partners
From time-to-time, we may partner with certain third parties in order to offer you co-branded services or promotional offers. In order to provide these services to you and to allow us and any associated third party to optimise their/our offering to you, we will share some of your personal data with such third parties. We will obtain your express opt-in consent before we share your personal data with any company outside the Amaiz group of companies for these purposes.
You can withdraw your consent at any time after giving your explicit opt-in consent by contacting support via in-App chat and letting us know.
10. Storing and transferring your data
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology or a secure virtual private network. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App and/or our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our App or our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
11. Data retention
Amaiz is obligated under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692) to retain personal data about you and your Amaiz Transactions for a period of five years from the last transaction or end of the business relationship. Also, as an FCA authorised e-money institution, we are under further regulatory obligations to retain your data for a certain amount of time. Under the E-Money Regulations 2011 you have the right to redeem your e-money up to six years after termination of your Amaiz Account. We therefore use this retention requirement as a benchmark for all personal data that we receive from you. To not hold your information for longer than is strictly necessary we will not hold any of your personal data for more than 6 years after the termination of our business relationship. Although we reserve the right to hold your personal data for longer if we are compelled to by a regulatory body or law enforcement agency.
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance at email@example.com.
14. Contact us