MuchBetter ビジネス
PRIVACY POLICY

Who We Are

MIR Limited UK Ltd（「ミール」、「MuchBetter ビジネス」、「私たち」、「私たちの」、「私たち”) 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.

序章

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.

ユーザー規約

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.

1. 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

2. 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).

3. What we use personal Information for

4. 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.

5. 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. 

6. 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.

7. 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.

8. 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.

8. 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.

9. 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.

10. How to Contact us

本サービスまたは当社がお客様に関して収集する情報とその使用方法に関する一般的な質問がある場合は、次の URL からお問い合わせください。 Support

If you have any concerns about our use of your personal information, please review our 苦情ポリシー また、お客様は、個人情報の処理に関して監督機関に苦情を申し立てる権利、またはデータ保護の権利に関連する要求の処理に対する不満を申し立てる権利を有します。詳細については、情報コミッショナー「ICO」の Web ページを参照してください (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

11. 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.

当社のウェブサイトでのそのような修正の通知に続いて、お客様がサービスを継続して使用することは、プライバシーポリシーのそのような修正を認め、同意し、そのような修正の条件に拘束されることに同意したことを意味します。