Who We Are
MIR Limited UK Ltd (“MIR”, “MuchBetter Business”, “we”, “our”, “us”) is a group company of RTEKK Holdings Limited, registered with the United Kingdom Information Commissioner. We are a payment services provider and electronic money issuer authorised and regulated by the Financial Conduct Authority in the United Kingdom, under FCA Reference Number (FRN) 900704 with its registered office at Signature By Regus, Berkeley Square House, 2nd Floor, London, England, W1J 6BD, United Kingdom.
This privacy notice (“notice”) explains the types of personal data we collect and how we use and share it. It also tells you about your rights and the choices you can make about how we process your personal data.
For the purpose of this Privacy Policy, “you” or “your” or “Authorised User(s)” refers to the individual(s) who set up, manage, access and operate the MuchBetter Business Account (“Account”) for the organisation in whose name the Account is held. Data protection laws apply primarily to individuals rather than to legal entities, but we will process personal data about you during your interaction with us in which case both we and the Account holder may be Controllers of your personal data.
Introduction
This Privacy Policy describes the types of Personal Information we collect, the purposes for which we collect that Personal Information, the other parties with whom we may share it, the measures we take to protect the security of the Personal Information and how long we retain it. It also tells you about your rights and choices with respect to your Personal Information, and how you can contact us about our privacy practices.
User Terms
We recognise that a core to Data Privacy is your right to be informed about how we collect and use your Personal Information; therefore, we encourage you to read this Privacy Policy carefully.
The Privacy Policy is a part of our MuchBetter Business Account Services Agreement and is incorporated therein by reference.
By using our Services, you agree to the terms of this Privacy Policy as may be amended by us from time to time.
- Personal Information We Process
Information you give us:
We receive and process any personal information for individuals associated with entities holding Accounts with us, including that which you provide for managing and operating the Account.
Personal information includes your name, address, date of birth and contact details, IP data and anything that can be linked to or identify you directly or when linked with other data. We may also process as a result of your interaction with us
- Passport details or other identity documents such as driving licence or national identity number
- Dependent upon your role in the organisation which hold the Account with us, we may also process additional personal information relating to directors, shareholders and beneficial owners such as financial details and history
- Source of funds or source of wealth, which may include bank statements and credit agreements,
- Images to evidence identity (including biometrics) (see Facial Images – Biometric Data section below)
- Communications we have with you
- Any other relevant information relating you and personal to you which will enable us to provide our services
Any Personal Information provided to us must be by or with the authority of the person to whom it relates, and this Privacy Policy must be read understood and accepted.
Information we collect
From your use of the Services:
- Transaction data
- Information about your devices
- Information about your use of the website and App
Information from Third Parties
We may require information from other sources such as:
- Financial institutions connecting to your Account
- Information from authorities, registries or fraud detection services
- Publicly available sources and/or social networks
- Legal bases for processing Personal Information
We process Personal Information in accordance with the law and for the following purposes:
- Contract necessity:where processing personal data is necessary to carry out or enter into our agreement with you (for example, if the processing is needed to make and receive payments);
- Legal obligation:where we have a legal obligation to process your personal data to comply with laws and regulations (such as collecting identification documents to comply with anti-money laundering legislation);
- Legitimate interests:where we have a legitimate reason to process your personal data that is reasonable when balanced against your rights and interests (for example, to understand how our services are used and how we can make improvements);
- Consent:where you have given us your consent to process your data;
- Substantial public interest:where we process sensitive or special category data (revealing or relating to someone’s health, ethnicity, political views, religious beliefs, sexual orientation, or other protected characteristics) and that processing is in the substantial public interest (for example, to support vulnerable customers).
- What we use personal Information for
Purpose | Legal basis |
· Eligibility checks to comply with Know Your Business “KYB” obligations under anti-money laundering laws including biometric data · As part of our KYB checks we may extract facial scan data (known as “biometric data”) from video or images to compare with images of you on you ID documents | Legal obligations Consent (for biometric data collection) |
· To provide our products and services, including support services, to you | Contract necessity Legal obligation |
- Provide you with customer support services, and to monitor or record any communications between you and us, including phone calls, for training and quality purposes;
| Legitimate interests. It is in our legitimate interests to monitor service quality |
- To prevent, detect, or protect against actual or suspected fraud, unauthorised transactions, claims, liability, and financial or other crimes. To keep our anti-fraud measures effective, we can’t always share all the details about how we prevent fraud;
- To keep our services safe and secure.
| Contract necessity Legal obligation Consent for biometric data Legitimate interests. It is in our legitimate interests to detect, prevent, and investigate fraud, money laundering and other crimes to protect our business and our customers. |
- To comply with legal and/or regulatory requirements, including to respond to requests from regulatory or government authorities (where there is lawful authority to do so);
- To evidence your compliance with regulations and obligations which apply to you;
- To prevent, detect, or protect against actual or suspected fraud, unauthorised transactions, claims, liability, and financial or other crimes, including conducting or co-operating with investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so;
- To take steps to recover amounts owed to us, and to allow us to recover or limit damages that we may sustain;
- To allow a third party or a financial institution that incorrectly sent money to recover money received by you in error or due to fraud;
- To verify information you provide to us, and to enforce our Account Services Agreement with you;
- To investigate, manage, and resolve complaints.
| Legal obligations Legitimate Interests (it is in our legitimate interests to protect our business, customers and employees from harm) |
- To measure or understand the effectiveness of our advertising and to deliver relevant advertising;
- To personalise marketing messages you receive about products and services we offer so they are more relevant and interesting;
- To provide you with information about other similar products and services we offer which we feel may interest you.
| Legitimate interests. It is in our legitimate interests to let our customers know about our products and services which may interest them, to personalise marketing communications and to understand the effectiveness of our advertising. Consent where we are required to collect your consent by law and where such consent has not been revoked. |
- To administer our services and for internal operational, planning, audit, troubleshooting, data analysis, testing, research, statistical, and survey purposes;
- To undertake system or product development, including helping third party suppliers improve the services they provide to us;
- To improve our services and to ensure that they are presented in the most effective manner;
- We may use Artificial Intelligence (“AI”) to improve the efficiency and effectiveness of our services and our financial crime and fraud prevention processes. We will always let our customers know if they are interacting with an AI system.
| Legitimate interests. It is in our legitimate interests to maintain, develop and improve our services. |
Understanding if you need extra support We process your personal data to help you if your personal circumstances indicate that you may need extra assistance; | Substantial public interest (if we process your sensitive personal data to adhere to legal requirements that apply to us). Consent where we are required to collect your consent by law. |
- How We Share Your Information
We do not disclose information which could identify you personally, to anyone except as described in this notice, as permitted, or required by law, and/or for the purposes described in this notice, including:
- within the Rtekk Group to help us provide our services and for our own internal customer relationship management, analytical and reporting purposes.
- Other Authorised Users of the Account holder may access Personal Information as may be stored on the Account
- To recipients/senders of a payment in the context of the specific relevant transaction.
- Fraud prevention agencies, including Action Fraud, Financial Fraud Action and the Financial Fraud Bureau and other organisations who assist us in managing fraud and business risk.
- Where we provide services through third parties where we may be required to disclose your information (including any ‘know your customer’ and ‘source of wealth’ information) with such organisations to assist their own regulatory obligations or risk assessments.
- Third Party Service Providers, including suppliers who assist us with the provision of Services, including processing orders, fulfilling orders, processing payments, managing credit, security, sector and fraud risk, cloud hosting and storage providers, identity verification, and marketing, IT and technical support, marketing and market research, third party debt recovery services. When we use these providers, we may process, store, and transfer your personal information in and to a foreign country, with different privacy laws.
- To third parties who do not act under our instructions as a service provider (but will be subject to their own legal obligations to keep data secure), to facilitate provision of the Services. For example, crypto currencies and other financial instruments or transactions.
- To prevent and/or detect fraud, financial crime, manage risk and to better protect ourselves and our customers, it may be necessary to process and disclose sensitive personal information to third parties who help us in managing such risks, including identity verification.
- Where we are required or permitted to do so by law, we may be required to pass information about you to regulatory authorities and law enforcement bodies worldwide, or we may otherwise determine that it is appropriate or necessary to do so, and
- Your information may also be used for other purposes for which you give your specific permission.
- International Data Transfers
Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the UK and European Union. The data protection and other laws of these countries may not be as comprehensive as those in the UK and European Union − in these instances we will take steps, in accordance with our own data protection obligations, to ensure that a similar level of protection is given to your Personal Information.
- How Long We Retain Your Personal Information
We will retain your personal information for as long as needed or permitted dependant on the context and purpose for which it was collected, the type of information and in compliance with applicable local laws or regulations.
This means that when using our Services, we will retain your personal information as necessary for the provision of the services and for any linked legitimate business purpose. This includes the use and retention of your personal information when you commence an application for our services, irrespective of whether you complete such application or are accepted as a customer.
For example, account data is generally retained for at least 5 years after the closure of the account, to align with statute of limitation periods in the event of complaints or legal disputes. We may also be legally required to retain information, for example under anti money laundering or bankruptcy laws or where required by law enforcement or similar government agencies.
We will retain personal information as evidence of our dealings with you regardless of whether there were any financial transactions, for audit and compliance practices, to manage any queries or disputes, including to defend or initiate any legal claims. We can also continue marketing and sending you direct marketing, subject to local laws and where you have not objected to such marketing.
We may also use data minimisation techniques to better protect your information, known as pseudonymisation. Once your information is no longer needed, we may anonymise or aggregate it with other information to make it unidentifiable, as an alternative to deletion.
- Facial Images – Biometric Data
We collect biometric data by extracting information from a facial scan (photo or video), which we compare to your identity document, for identification and fraud prevention purposes.
We carry out this processing with your consent, which we will ask for. If you do not consent we can provide an alternative method of verifying your identity. We may use a third-party service provider to acquire and store your biometric date, which will be processed in accordance with data protection laws.
- Automated Decision Making
In some instances, our use of your personal information may result in automated decisions being taken (including profiling) that may affect you.
Automated decisions mean a decision concerning you is made automatically based on a computer determination (using software algorithms), without human review.
For example, we use automated decisions when you apply for certain Services or to carry out anti-fraud checks, as explained in the section “What We Use Your Personal Information For”. We may also use elements of your Personal Information to customise services and to address your needs. We have implemented measures to safeguard the rights and interests of individuals whose personal information is subject to automated decision-making. In addition, if you are using the Services in the UK or EEA (when we make an automated decision about you), you have the right to contest the decision, to express your point of view, and to require a human review of the decision.
To exercise this right, please contact us via the details provided in the Contact Us section.
- How We Protect Your Personal Information
We have implemented technical, physical, and organisational/administrative measures designed to secure your personal information from accidental loss and from unauthorised access, use, alteration, and disclosure.
The safety and security of your information is also dependent upon you. If we have given you (or if you have chosen) a password or access code for access to certain parts of our website/portal or mobile applications and similar, you are responsible for keeping this password and/or access code confidential. You must not share your password and/or access code with anyone. You must ensure that there is no unauthorised use of your password.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our site, unless you are communicating with us through a secure channel that we have provided. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
- Your Rights and Choices
Depending on your jurisdiction or country of residence, you may have one or more of the following rights:
- Right to be informed: including by being provided with this notice
- Right to access: request a copy of the information we hold about you
- Right to erasure: request deletion of your information
- Right to restriction: request we restrict the processing of your information
- Right to rectification: request we rectify certain information we hold about you
- Right to data portability: request that we provide you or another organisation with an electronic copy of the information you provided to us
- Right to object: request we stop processing your personal information
- Right to opt-out of marketing: remove your information from our marketing database
- Rights related to automated decision-making including profiling: see section “Automated Decision Making” below.
These rights may apply under several different regulations, for example, the GDPR, generally applicable to EEA residents.
Furthermore, such rights may be qualified or restricted. For example, we may not be obligated to grant your request as we may be required by law to continue its processing, or to manage a complaint. Similarly, we are unable to delete your information if you want to continue using our Services, or where such information is necessary to record our contractual dealings; it is required by law (for example, the retention of anti-fraud or “know your customer” identify and verification requirements); or for the purpose of defending or asserting legal rights and legal actions.
When you cease your relationship with us and stop using our services, we are permitted by law to retain your information for a period to evidence our dealings with you, as explained earlier. This will be in accordance with our internal retention policies and procedures. For more information on retention of data, please refer to the relevant section within this Notice.
To the extent that GDPR applies, when you give us consent to use your personal information, you can withdraw it any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. For example, you can stop any marketing communication we send you by clicking on the “unsubscribe” or “opt-out” link in the communications you receive, or according to the instructions that we provide every time, but we will continue to send you operational or service messages in relation to your Services.
- How to Contact us
If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us by visiting Support
If you have any concerns about our use of your personal information, please review our Complaints Policy You also have the right to lodge a complaint with the supervisory authority regarding the processing of personal information or dissatisfaction with our handling of any request in relation to any data protection rights. Please refer to the Information Commissioner “ICO” webpage for more information (https://ico.org.uk/make-a-complaint/)
You may also contact our Data Protection Officer by email
DPO@Rtekk.com
Or in writing:
Data Protection Officer
Rtekk Holdings Limited, Park House,
Isle of Man Business Park, Douglas, IM2 2QZ
- Updates or Amendments to this Policy
We may revise this Privacy Policy from time to time, at our sole discretion, and the most current version will be posted on our website. We encourage you to review this Privacy Policy regularly for any changes. In case of material changes we will notify you through our Services or by email.
Your continued use of the Services, following the notification of such amendments on our website, constitutes your acknowledgement and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.
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