Privacy Policy
This policy applies to individuals in the UK that are over 18 years of age.
Your privacy is very important to us.
Your personal data belongs to you, and you have the right to understand and control how it’s used. If you want to exercise your rights over your personal data, you can contact us any time at dpo@greenswanfinacial.com. If you share data with us, we'll let you know how we’re using it. We'll explain how we collect and use your personal data in our privacy notices, so you know what's happening. When we collect and use your data, it’s only to help us deliver exceptional services, improve your experience, and meet our regulatory and legal requirements.
This policy applies to all legal entities listed at www.greenswanfinancial.com/legal-entities, that are referred to as "Green Swan" in these policy documents.
The terms "app" and "website" are used interchangeably in this policy and some settings may be available on each or either channel depending on the products you have subscribed to.
We are committed to:
- always keep your personal data safe and private
- never sell your personal data
- allowing you to manage and review your marketing choices
1.0 About us
When Green Swan provides you with a product or service we will be responsible for processing your personal data for that product or service. Green Swan is known as the ‘controller’ of your personal data.
Green Swan may provide products and services to you through different companies. You can check out the Green Swan companies are responsible for your personal data at www.greenswanfinancial.com/legal-entities and at the specific Terms and Conditions for those services that you have applied for. This policy shall apply to both Green Swan Compliance Ltd and Green Swan Financial Ltd referred to as 'Green Swan' in this policy.
2.0 Why do I need to read this notice?
We collect your personal data when you use:
- our website at www.greenswanfinancial.com
- the Green Swan app
- any of the services available to you through the Green Swan app, website, social media, email, chat or telephone communications.
We may also collect your personal data from other people or companies. We explain how this can happen
in more detail in the What personal data do you collect about me? section below.
When we say ‘personal data’, we mean information which:
- we know about you
- can be used to personally identify you (for example, a combination of your name and postal address)
This notice explains what information we collect, how we use it, and your rights over your personal data.
Specific Green Swan products and services you use may have separate standalone privacy notices for example if you have funds on a card program or other product that is no longer active (dormant funds) in these instances the dormant fund's privacy policy shall take precedence in the event of a conflict between this policy and the dormant fund's policy for that product.
These notices:
- give you more detail about how Green Swan collects, uses, and protects your personal data when you
use specific products or services
- will be provided to you or made available to you through the Green Swann app/website when you start using relevant products or
services
- can be accessed at any time through the Green Swan website. Sometimes, we may also provide you with ‘just in time’ privacy explanations in the Green Swan app or website when you use a new Green Swan product or service for the first time, or we make an update to them.
- these explanations will help you to understand what specific personal data Green Swan collects, uses or shares about you for that product or service
- where relevant, you will be prompted to review your in-app/website privacy preferences
If you have concerns about how we use your personal data, you can contact dpo@greenswanfinancial.com.
3.0 What personal data do you collect about me?
The list below explains what personal data we collect and use.
Type of personal data Details - Information you give us We collect information you provide when you:
✓ fill in any forms
✓ correspond with us
✓ respond to any of our surveys
✓ register to use the Green Swan app
✓ open an account or use any of our services
✓ give us access to your other financial accounts (for example, through Open Banking)
✓ take part in online discussions or promotions
✓ speak with a member of our social media or customer support teams (either on the phone or through the Green Swan app/online chat)
✓ enter a competition or share information with us on social media
✓ contact us for other reasons
We will or may collect the following information - depending on the product or services you have with us:
✓ your name, address, and date of birth
✓ your email address, phone number and details of the device you use (for example, your phone, computer or tablet)
✓ your Green Swan username if one has been provided to you.
✓ your registration information
✓ details of your bank/payment account, including the account number, sort code and IBAN
✓ details of your Green Swan debit cards and credit cards (or other debit or credit cards you have registered with us) including the card number, expiry date and CVC (the last three digits of the number on the back of the card)
✓ copies of your identification documents (for example, your passport or driving licence) and any other information you provide to prove you are eligible to use our services
✓ your country of residence, tax residency information, and tax identification number
✓ information you provided when you applied for credit, including details about your, or your spouse’s, income and financial obligations
✓ records of our discussions, if you contact us or we contact you (including records of phone calls)
✓ your image in photo or video form, and facial scan data extracted from your photo or video (known as ‘biometric data’), to verify your identity during onboarding as part of our Know-Your-Customer (KYC) checks, to authenticate you as an authorised user of our services, or to detect and prevent fraud
✓ information about other people (such as a joint account holder, your spouse or family) when we ask you to give us this information to enable us to comply with our obligations under KYC, anti-money laundering and other laws and to assist with fraud monitoring If you give us personal data about other people (such as a joint account holder, your spouse or family), or you ask us to share their personal data with third parties, you confirm that you have brought this notice to their attention beforehand.
Information collected from your use of our products and services whenever you use our website or the Green Swan app, we collect the following information:
✓ technical information, including the internet protocol (IP) address used to connect your computer to the internet, your login information, the browser type and version, the time zone setting, device language, the operating system and platform, the type of device you use, whether your device uses a virtual private network (VPN), a unique device identifier (for example, your device's IMEI number, or the mobile phone number used by the device), mobile network information, your mobile operating system and the type of mobile browser you use
✓ information about your visit, including the links you’ve clicked on, through and from our website or app (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 and clicks), and methods used to browse away from the page
✓ information on transactions and your use of Green Swan products (for example, payments into and out of your account), including the date, time, amount, currencies, exchange rate, beneficiary details, details of the merchant or ATMs associated with the transaction (including merchants’ and ATMs’ locations), IP address of sender and receiver, sender's and receiver's name and registration information, messages sent or received, details of device used to arrange the payment and the payment method used
✓ information stored on your device, including if you give us access to contact information from your contacts list. The Green Swan app will regularly collect this information in order to stay up to date (but only if you have given us permission)
Information about your location
✓ If you turn location services on in the Green Swan app, we track your location using GPS technology.
✓Information from others We collect personal data from third parties or other people, such as credit reference agencies, financial or credit institutions, official registers and databases, as well as joint account holders, fraud prevention agencies and partners who help us to provide our services.
✓ This includes your credit record, information about late payments, information to help us check your identity, information about your spouse and family (if applicable in the context of an application for credit that you make), and information relating to your transactions.
✓ When you ask us to, we’ll also collect personal data from accounts you hold with third-party financial institutions (when you create a linked account by activating Open Banking in the Green Swan app).
Occasionally, we’ll use publicly available information about you from selected social media websites or apps to carry out enhanced due diligence checks. Publicly available information from social media websites or apps may also be provided to us when we conduct general searches on you (for example, to comply with our anti-money laundering or sanctions screening obligations).
Information from publicly available sources)
We collect information and contact details from publicly available sources, such as media stories, online registers or directories, and websites for enhanced due diligence checks, security searches, and KYC purposes.
4.0 What is your legal basis for using my personal data?
✓ We must have a legal basis (a valid legal reason) for using your personal data. Our legal basis will be one
of the following:
✓ Keeping to our contracts and agreements with you
We need certain personal data to provide our services and cannot provide them without this
personal data.
✓ Legal obligations
In some cases, we have a legal responsibility to collect and store your personal data (for example,
under anti-money laundering laws we must hold certain information about our customers).
✓ Legitimate interests
We sometimes collect and use your personal data because we have a legitimate reason to use it
and this is reasonable when balanced against your human rights and freedoms.
✓ Substantial public interest
Where we process your personal data, or your sensitive personal data (sometimes known as
special category personal data), to adhere to government regulations or guidance, such as our
obligation to prevent fraud or support you if you are or become a vulnerable customer.
Consent
Where you've agreed to us collecting your personal data, or sensitive personal data, for example
when you tick a box to indicate you’re happy for us to use your personal data in a certain way.
We explain more about how we use your personal data in the How do you use my personal data? section
below.
5.0 How do you use my personal data?
What we use your personal data for and our legal basis for using your personal data
✓ Checking your identity whenever you sign up with Green Swan, we’ll use your personal data to check your identity or the identity of joint account
holders if relevant (as part of our KYC process).
✓ This may include facial scan data extracted from any photo or video you submit (known as ‘biometric data’).
✓ Legal obligations
✓ Substantial public interest
✓ Consent (where required by law)
✓ Providing our services
✓ Whenever you apply for or use a Green Swan product or service, we’ll use your personal data to:
✓ decide whether or not to approve your application or payments
✓ meet our contractual and legal obligations relating to any products or services you use (for example, making payments into and out of your Green account, withdrawing cash or making payments with your Green Swan payment account or card if this has been issued to you or a thrid party)
✓ help to understand your spending behavior, how you use Green Swan products and services, and to help you save money or donate money to permitted charities more efficiently (for example, by providing you with product usage and spending insights)
✓ send money to you are legally due (e.g from a dormant card programme), recover debt and exercise other rights we have under any agreement with you
✓ provide you with customer support services. We may record and monitor any communications between you and us, including but not limited to phone calls, to maintain appropriate records, check your instructions, analyse, assess and improve our services, and for training and quality control purposes
✓ Keeping to contracts and agreements between you and us
✓ Legitimate interests (we need to be efficient about how we meet our obligations and we want to provide you with good products and services)
✓ Legal obligations
✓ Record where you have elected to donate money to one or more charities.
✓ Record where we have actively attempted to contact you using the data available to us and the times and methods we have done this by.
We use your personal data to check your address and identity,
protect against fraud, keep to financial crime laws and to confirm that you’re eligible to use our services. We also use it
to help us better understand your financial circumstances and manage fraud risks related to your Green Swan account.
- Legitimate interests (to develop and improve how we deal with financial crime and meet our legal responsibilities)
- Substantial public interest
- Consent (where required by law)
- Legal obligations
Marketing and providing products and services that might interest you - including but not limited to charity donations.
We may use your personal data to do the following:
- to personalise your in-app experience and marketing messages about our products and services so they’re more relevant and interesting to you(where allowed by law). This may include analysing how you use our products, services and your transactions
- if you agree, provide you with information about our partners’ promotions or offers which we think you might be interested in
- if you agree, allow our partners and other organisations to provide you with information about their products orservices
- ask your opinion about our products or services
- You can ask us to stop sending you marketing information by adjusting your marketing choices or unsubscribing from email communications.
- Legitimate interests (to send directmarketing, ensure our directmarketing is relevant to your interests, develop our products and services, and to be efficient about how we meet our legal and contractual duties)
- Consent (where we’re legally required to get your consent to send you direct marketing about our products or services, or partners’ promotions or offers, or for you to receive marketing from other organisations)
To keep our services up and running
We use your personal data to manage our website and the Green Swan app, (including troubleshooting, data analysis, testing,research, statistical and survey purposes), and to make sure that content is presented in the most effective way for you and your device.
- Keeping to contracts and agreements between you and us
- Legitimate interests (to be efficient about how we meet our obligations and keep to regulations that apply to us and to
We also use your personal data to:
- authenticate you as an authorised user of our services when necessary (for example, if you contact our customer support or social media teams)
- allow you to take part in interactive features of our services
- tell you about changes to our services
- help keep our website and the Green Swan app safe and secure by presenting content as effectively as possible for you)
- Consent (where required by law) Helping with social interactions
- We may use your personal data to help with social interactions through our services or to add extra functions in order to provide a better experience.
For example, if you give us permission, we'll use the contacts list on your phone so you can easily make payments to, or message, your contacts using the Green Swan app.
- Legitimate interests (to develop our products and services and to be efficient in meeting our obligations)
- Consent (to access information held on your phone, for example, contacts in your contacts list, totrack you when you have location services switched on)
Providing location-based services If you turn location services on in the Green Swan app, we use your personal data to:
- provide you with products and services
- provide relevant advertising to you (for example, information about nearby merchants)
- protect against fraud
- Keeping to contracts and agreements between you and us
- Legitimate interests (to develop and market our products and keep to regulations that apply to us as well as regulations that in our reasonable opinion may be deemed to apply to us either now or in the foreseeable future - for example as indicated by publically proposed draft legislation)
- Consent (to track you when you have location services switched on)
Preparing anonymous statistical datasets
We prepare anonymous statistical datasets about our customers’ spending/usage patterns:
- for forecasting purposes
- to understand how customers use Green Swan
- to comply with governmental requirements and requests
These datasets may be shared internally or externally with others, including non-Green Swan companies. We produce these reports using information about you and other customers. The
- Legitimate interests (to conduct research and analysis, including to produce statistical research and reports)
- Legal obligations
information used and shared in this way is never personal data and you will never be identifiable from it. Anonymous statistical data cannot be linked back to you as an individual. For example, some countries have laws that require us to report spending statistics and how money enters or leaves each country. We’ll provide anonymised statistical information that explains the broad categories of merchants that Green Swan customers in that country spend their money with. We’ll also provide information about how Green Swan customers top up their
accounts and transfer money. However, we won’t provide any customer-level information. It will not be possible to identify
any individual Green Swan customer.
Improving our products and services
We use your personal data to help us develop and improve our current products and services. For example, we may include you in a focus group to test and develop new products because we think you will be interested based on how you
spend or use other Green Swan products. This allows us to continue to provide products and servicesthat our customers want to use.
- Legitimate interests (to understand how customers use our products so we can develop new products and improve theproducts we currently provide)
Meeting our legal obligations, enforcing our rights, protecting our business and other legal uses
We use your personal data:
- to share it with other organisations (for example, government authorities, law enforcement authorities, tax authorities, fraud prevention agencies)
- if this is necessary to meet our legal or regulatory obligations
- to identify and support vulnerable customers by letting you tell us if you need help or analysing your behaviour in the
Green Swan app, customer support communications and through transactions (for example, we will try to identify whether you are potentially vulnerable so we can provide you with enhanced support. Identifying and supporting vulnerable customers is a legal requirement for us in some countries)
- Legitimate interests (for example, to protect Green Swan during a legal dispute)
- Substantial public interest (if we process your sensitive personal data to keep to legal requirements
that apply to us)
- Legal obligations
- to protect ourselves, including our rights, property, personnel or products
- to help prevent and fight harmful or unlawful behaviour and spam communications (in line with Green Swan's Community Standards)
- in connection with legal claims
- to help detect or prevent crime
You can find out more in the Do you share my personal data
with anyone else? section below.
Sometimes, we’re legally required to ask you to provide information about other people. For example, we might ask you to explain:
- your relationship with a joint account holder or somebody who pays money into your Green Swan account
- how somebody got the money in the first place to pay it into your Green Swan account
- in the event that money is to be returned to you to establish that you are the legitimate recipient of funds and that the money is being returned to an account in your name that is legally owned by you. Under these circumstances, we may require an audio or live video call to verify details, depending on our risk assessment of the situation.
6.0 Do you make automated decisions about me?
Depending on the Green Swan products or services you use, we may make automated decisions about you.
This means that we may use technology that can evaluate your personal circumstances and other factors
to predict risks or outcomes. This is sometimes known as profiling. We do this for the efficient running of
our services and to ensure decisions are fair, consistent and based on the right information.
Where we make an automated decision about you, you have the right to ask that it is manually reviewed
by a person. You can find out more about this in the What are my rights? section below.
For example, we may make automated decisions about you that relate to:
- Determining if you are inclined to donate residual balances on dormant accounts to charity.
- Setting monthly limits on charity donations
Opening accounts (or sub-accounts):
- KYC, anti-money laundering and sanctions checks
- identity and address checks
Detecting fraud:
- monitoring your account to detect fraud and financial crime
Our legal basis is one or more of the following:
- keeping to contracts and agreements between you and us
- legal obligations
- legitimate interests (to develop and improve how we deal with financial crime and meet our legal
responsibilities)
7.0 Do you run credit checks on me?
No. We do not offer credit facilities and we do not therefore run credit checks on you.
8.0 How do you use my personal data for marketing?
If you sign up to our services (or your account is transferred to our servics, and where national laws allow, we’ll assume you want to be contacted by
post, push notification, email and text message with information about Green Swan products, services, offers and promotions. Where national laws require us to get your consent to send marketing messages, we’ll do so in advance.
We may use your personal data to personalise marketing messages about our products and services so theyare more relevant and interesting to you (where allowed by law). This may include analysing how you use our services and your transactions.
You can object to profiling for direct marketing purposes. You can also adjust your preferences or tell us you don't want to receive direct marketing at any time. Just use the privacy settings in the Green Swan app or tap the unsubscribe links in any marketing message we send you.
If you do not want to receive personalised marketing messages and opt-out from receiving them, you will not receive any marketing communications. However, you may still receive generic information about our products and services in the Green Swan app.
We won't pass your details on to any organisations outside the Green Swan companies listed on our website for their marketing purposes without your permission. You can find out more in the Do you share my personal data with anyone else? section below.
Our legal basis is:
- consent (where we are required by law to collect your consent)
- legitimate interests (to send you marketing and to provide information relevant to your interests)
9.0 What are my rights?
Your right and what it means
You have the right to be told how we use your personal data. We provide this privacy notice to explain how we use your personal data.
You have the right to ask us for a copy of your personal data. If you ask, we’ll provide a copy of the personal data we hold about you. We can’t give you any personal data about other people, personal data that is linked to an ongoing criminal or fraud investigation, or personal data which is linked to settlement negotiations with you. We also won't provide you with any communication we've had with our legal advisers.
You can ask us to correct your personal data if you think it's wrong.
You can have incomplete or inaccurate personal data corrected. Before we update your file, we may need to check the accuracy of the new personal data you have provided.
You can ask us to delete your personal data if:
✓ there's no good reason for us to continue using it
✓ you gave us consent (permission) to use your personal data and you have now withdrawn that consent
✓ you have objected to us using your personal data
✓ we have used your personal data unlawfully
✓ the law requires us to delete your personal data
Just to let you know, we may not be able to agree to your request. As a regulated financial services provider, we must keep certain customer personal data even when you ask us to delete it (we've explained this in more detail below). If you've closed your account, we may not be able to delete your entire file because these regulatory responsibilities take priority. We’ll always let you know if we can't delete your
personal data.
You can object to us processing your personal data for marketing purposes
- You can tell us to stop using your personal data, including profiling you, for marketing.
- You can object to us processing other personal data (if we’re using it for legitimate interests)
- If our legal basis for using your personal data is 'legitimate interests' and you disagree with us using it, you can object. However, if there is an overriding reason why we need to use your personal data, we will not accept your request.
- If you object to us using personal data that we need to provide our services, we may need to close your account as we won’t be able to provide the services.
You can ask us to restrict how we use your personal data
You can ask us to suspend using your personal data if:
✓ you want us to investigate whether it’s accurate
✓ our use of your personal data is unlawful but you don’t want
us to delete it
✓ we no longer need your personal data, but you want us to
continue holding it for you in connection with a legal claim
✓ you have objected to us using your personal data (see
above), but we need to check whether we have an overriding
reason to use it
You can ask us to transfer personal data to you or another company If we can, and are allowed to do so under regulatory requirements, we’ll provide your personal data in a structured, commonly used, machine-readable format.
You can withdraw your permission If you’ve given us the consent we need to use your personal data, you can withdraw it at any time by changing your privacy settings in the Green Swan app or sending an email to dpo@greenswanfinancial.com.
(Please note, it will have been lawful for us to use the personal data up to the point you withdraw your permission.)
You can ask us to carry out a human review of an automated decision we make about you
If we make an automated decision about you that significantly affects you, you can ask us to carry out a manual review of this decision.
Your ability to exercise these rights will depend on a number of factors. Sometimes, we won’t be able to agree to your request (for example, if we have a legitimate reason for not doing so or the right does not apply to the particular information we hold about you).
10. How do I exercise my rights?
To exercise any of your rights set out in the previous section, you can send us an email at dpo@greenswanfinancial.com.
For security reasons, we can't deal with your request if we’re not sure of your identity, so we may ask you for proof of ID.
If a third party exercises one of these rights on your behalf, we may need to ask for proof that they’ve been authorised to act on your behalf.
When you exercise one of your rights, or update your privacy settings in the Green Swan app, it may take us up to one month to respond or implement your changes.
Green Swan will usually not charge you a fee when you exercise your rights. However, we’re allowed by law to charge a reasonable fee or refuse to act on your request if it is manifestly unfounded or excessive.
If you’re unhappy with how we’ve handled your request you can complain to your local data protection authority. In the United Kingdom, this is the Information Commissioner’s Office (website).
11. Do you share my personal data with anyone else?
Green Swan group companies
We share your personal data within the Green Swan group of companies to:
- provide you with the best service
- protect you, other customers and our systems from fraud or harmful behaviour
- facilitate you quickly signing up to use other Green Swan products or services
- improve existing, or develop new, products or services
- send you information about Green Swan products and services we think you’ll be interested in hearing
about
We may use technological safeguards to ensure a ‘trusted contact’ is somebody you already know and who knows you (for example, you have each other saved in each other’s mobile phone contacts lists or have already received or given money through a peer-to-peer payment with them).
People or companies that transfer money to you
When you receive a payment we’ll provide the payer with your details (for example, your name, account number/IBAN). This is necessary to confirm that the payment has been made to the correct account.
Suppliers
The table below explains which suppliers we normally share your personal data with:
Type of supplier Why we share your personal data Suppliers who provide us with IT, payment and delivery services
To help us provide our services to you
- Our banking and financial
- services partners and
- payments networks, including
- Visa and Mastercard
To help us provide our services to you - This includes banking and (if relevant) lending partners, banking intermediaries and international payment
service providers
Identity verification and KYC service providers -To help us verify your identity so we can provide our services to you
Analytics providers and search information providers
To help us improve our website or app, Customer-service providers, survey providers and
developers
To help us provide our services to you
- Communications services providers
- To help us send you emails, push notifications and text messages
Partners who help to provide our services
We may share your personal data with our partners to:
- provide certain services you’ve asked for (for example, membership plans)
Make sure you get any reward we have promised you (for example, if you make a purchase with a partner, we will share limited information about you to make sure you get the right reward) We’ll only share your personal data in this way if you’ve satisfied the qualifying event criteria, asked for the relevant service or if it’s provided as part of our membership plans.
From time to time, we may work with other partners to offer you co-branded services or promotional offers, and we’ll share some of your personal data with those partners. We will always make sure you understand how we and our partners process your personal data for these purposes.
We may share your personal data with other financial institutions, or Green Swan customers if you ask us to. For example, if you have activated ‘Open Banking’ through an account you hold with another financial institution and given them permission, we’ll share data from your Green Swan account (such as your balance, payment transactions, account number, and sort code) with that financial institution.
We may also share your personal data with other financial institutions, or Green Swan customers, where you do not ask us to. For example, if a payment is made to your account by mistake, we can share your information with the financial institution, or Green Swan customer, the payment came from. This will help the payer and the other financial institution to try and get the payment back themselves.
Joint account holders If you have a joint account with us, we will share account and transaction information between joint account holders. For example, your co-account holder will see any transactions you make from your joint account.
Other third parties
We may share your personal data with other third parties where necessary to facilitate you receiving
payments to your Green Swan account.
For legal reasons
We also share your personal data with other financial institutions, financial services companies,
insurance providers, government authorities, law enforcement authorities, tax authorities, companies and
fraud prevention agencies to check your identity, investigate or protect against suspected fraud, keep to
tax laws, anti-money laundering laws, or any other laws and confirm that you’re eligible to use our
products and services.
If fraud is detected, you could be refused certain services by Green Swan or other companies.
We may also need to share your personal data with other third party organisations or authorities:
- if we have to do so under any law or regulation
- if we sell our business or credit portfolio
- in connection with criminal or fraud investigations
- to enforce our rights (and those of customers or others)
- in connection with legal claims
Social media and advertising companies
When we use social media for marketing purposes, your personal data (limited to only your name, email
address and app events) may be shared with the social media platforms so that they can check if you
also hold an account with them. If you do, we may ask the advertising partner or social media provider to:
- use your personal data to send our adverts to you, because we think that you might be interested
in a new Green Swan product or service
- not send you our adverts, because the marketing relates to a service that you already use
- send our adverts to people who have a similar profile to you (for example, if one of our services is
particularly useful to people with similar interests to the ones on your social media profile, we
may ask our advertising partner or social media partner to send our adverts for that service to
those people)
An example of how we may use social media for marketing purposes is through Facebook’s ‘Custom
Audience’ tool. Read more about these terms.
We may share your personal data with our advertising partners in the ways described above, but the
personal data is hashed before we send it, and the advertising partner we share it with is only allowed to
use that hashed personal data in the ways described above.
Our legal basis is:
- legitimate interests (to ensure Green Swan's advertising is as effective as possible)
You can contact us at any time, either through the Green Swan app or by emailing dpo@greenswanfinancial.com, if you
don’t want us to share your personal data for advertising purposes. You can also use the privacy settings
in the Green Swan app to opt out from having your personal data shared in this way.
Remember you can also manage your marketing preferences directly with any social media provider that
you have an account with.
Where you ask us to share your personal data
Where you direct us to share your personal data with a third party, we may do so. For example, you may
authorise third parties to act on your behalf (such as a lawyer, accountant or family member or guardian
under a power of attorney). We may need to ask for proof that a third party has been validly authorised to
act on your behalf.
12.0 Will my personal data go outside the United Kingdom or Europe?
Your data will not ordinarily be transferred outside of the UK. There may be some regulatory and fraud instances, we may need to transfer your personal data outside the United Kingdom or the European Economic Area (EEA) to help us provide our services and/or meet our regulatory requirements.
We may send your personal data outside of the United Kingdom or EEA to:
- keep to global legal and regulatory requirements
- provide ongoing support services
- fraud prevention agencies or law enforcement authorities
- enable us to provide you with products or services you have requested
If we transfer your personal data to another country that doesn’t offer a standard of data protection equivalent to the United Kingdom or EEA, we will make sure that your personal data is sufficiently protected. For example, we’ll make sure that a contract with strict data protection safeguards is in place before we transfer your personal data. In some cases, you may be entitled to ask us for a copy of this
contract. If you would like more information, please contact us by sending an email to dpo@greenswanfinancial.com.
13.0 How do you protect my personal data?
We recognise the importance of protecting and managing your personal data. Any personal data we process will be treated with the utmost care and security. This section sets out some of the security measures we have in place.
We use a variety of organisational and technical measures to:
- maintain the confidentiality, availability and integrity of your personal data
- make sure your personal data is not improperly used or disclosed
We have detailed information security and data protection policies which our employees are required to follow when they handle your personal data. Our employees receive data protection and information security training. Personal data is stored on secure computer systems with access management controls in place to limit physical, system and information access to only authorised employees. Green Swan has strict policies in place that control how we share your personal data with other companies.
Before sharing personal data with any company, we thoroughly:
- vet the company in advance
- assess the security controls the company has in place to protect your personal data
While we take all reasonable steps to ensure that your personal data will be kept secure from unauthorised access, we cannot guarantee it will be secure during transmission by you to our app, our website or other services we may provide. We use HTTPS (HTTP Secure), where the communication protocol is encrypted through Transport Layer Security for secure communication over networks, for all our app, web and payment-processing services. If you use a password, PIN or generated authorisation code or prompt to use the Green Swan app, our website
or other services, you will need to keep it confidential. Please do not share it with anyone. Green Swan will never ask you for this credential.
When you use our public services, which may include our social network accounts and the Green Swan Community forum, do not share any personal data that you don't want to be seen, collected or used by other customers, as this personal data will become publicly available.
14.0 How long will you keep my personal data for?
We will keep your personal data:
- for as long as necessary to achieve the original purpose we collected it for
- in line with relevant laws
We are required to keep certain personal data for specified time periods by KYC, anti-money laundering,e-money laws. These time periods vary from country to country - in the UK this is typically for 7 years after the end of our relationship with you or as advised by the the FCA. Green Swan has detailed policies and procedures in place to ensure we comply with these requirements.
We may keep your personal data for a longer time period because of a potential or ongoing court claim, or for another legal reason.
15.0 How will you keep me updated about how you use my personal data?
If we change the way we use your personal data, we’ll update this notice and, if appropriate, let you know by email, through the Green Swan app or through our website.
16. Do you use cookies?
We use cookies to analyse how you use our website. Please read our Cookies Policy for more information
about cookies.
We may also use pixels or web beacons in the direct marketing emails that we send to you. These pixels track
whether our email was delivered and opened, and whether links within the email were clicked. They also
allow us to collect information such as your IP address, browser, email client type, and other similar
details. We use this information to measure the performance of our email campaigns and for analytics.
You can control whether you receive direct marketing emails through the privacy settings in the Green Swan
app.
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