Privacy Policy UK and ROW

Effective Date: July 2023

Who We Are
MIR Limited UK Ltd (“MIR”, “MuchBetter”, “we”, “our”, “us”) is an app based payment wallet (“the App”) allowing customers and merchants to process and manage e-payments in a secure, fair and economical way (the “MuchBetter Service”).

MIR Limited UK Ltd is a company of the RTEKK Holding Limited and the ‘Controller’ of personal information collected in provision of the MuchBetter Service. We are registered with the United Kingdom Information Commissioner and fully commit to the requirements of the European Union General Data Protection Regulation (GDPR).

MIR LIMITED UK Ltd is also an authorised 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.

Definitions

EEA – means the European Union Member States and Iceland, Liechtenstein and Norway.

GDPR – means The European Data Protection Regulation which is applicable as of May 25th, 2018 in all Member States of the European Union in order to harmonize Data Privacy laws across the European Union.

Introduction

This Privacy Notice 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 data and how long we retain that data. 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.

Our Privacy Practices may vary among the countries in which we operate to reflect local practices and legal requirements. Specific privacy notices may apply to some of our products and services. Please visit the webpage of the specific product or service to learn more about our privacy and information practices in relation to that product or service.

User Terms

We recognise that a core to Data Privacy is your right to be informed about how we collect and use your data; therefore, we encourage you to read this Privacy Policy carefully.

The Privacy Policy is a part of our User Terms and is incorporated therein by references.

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 May Collect

Information you give us:

we receive and store any personal information (including financial information) you provide to us including when you (or your business) enquire for or make an application for the Services; register to use and/or use any Services; upload and/or store information with us using the Services; and when you communicate with us through email, SMS, a website or portal, or the telephone or other electronic means, e.g. in the context of contacting us about your account or transactions. Such information may reference or relate to you or your customers and includes:

name including first name and family name
date of birth & age
email address, billing address, home address
username
password and/or photograph
occupation
nationality and country of residence
a copy of your identification, such as your driver’s license or passport or other government identification or registration data.
Card number, card expiry date, CVC/CVV details (card security code), account numbers, account balances and the length of time you have maintained those accounts, bank and/or issuer details.
Information about your use of our Services, such as information about how frequently you transact with us, your transactions and average transaction volume, account balances, the people, and merchants to whom you send money and from whom you receive money;
Biometric data – one of our third-party providers uses facial recognition software– we use this data to verify your identity; and
any other information that you provide in the context of using the Services.

2. How We May Use Your Personal Information

We may use and share the personal information we collect for the following purposes:

To provide our Services to you, including fulfilling our obligations to you in connection with the Services we provide to you. In this context we record and track details of transactions you carry out in relation to the Services; notify you about important changes or developments to our website or our goods and services.
To improve and develop our business, including without limitation to optimise our websites/portals, products, and services.
To manage and enforce our rights, terms of use or any other contracts with you, including to manage any circumstances where transactions are disputed; manage, investigate, and resolve complaints.
To prevent and/or detect fraud, financial crime, manage risk and to better protect ourselves, our customers, and the integrity of the financial system. This may include software and services we use to verify your identity/age by determining whether a selfie you take matches the photo in your ID.
To prevent, detect and prosecute fraud and other crimes and abuses of the financial system, or to assist others in doing so, including non-compliance with any terms of business and which may involve the sharing of any relevant or necessary information we have collected or inferred with third parties for such purposes.
To contact you about your account, to alert you to potential problems, and to respond to your questions to us.
To send marketing messages, to provide you with the information on products and services you have requested, or we think may be of interest to you; to obtain your views on our goods, services and our website/s; in respect of marketing, market research and similar activities, we may use your personal information for such purposes whether or not you are accepted as a customer or continue to receive Services. If you no longer wish to receive marketing or promotional information, you can always stop it.

You can find more information in the section “Your Data Protection Rights”.

To comply with all local laws and regulations.
To comply with requests from law enforcement and regulatory authorities, to establish, exercise or defend legal claims, or to protect your vital interests or those of other persons; for example, to help those authorities or other organisations in the fight against crime and terrorism; and
To comply with our terms of business.

3. Legal Basis for Processing

We will only process your personal information in compliance with the law. Such laws vary across different territories and further specific information is available on request. In general, we will either process:

Based on your consent, for example to send you marketing messages about products and services in accordance with your interests and preferences, where such consent is required by law.
Where necessary for the performance of, or entry into, any contract we have with you, for example, if we are required to verify your identity and you do not supply us with the relevant information, we may be unable to open an account for you.
Where we have a legitimate interest to process data, subject to such processing not overriding your own rights and freedoms in objecting to such processing. For example, to keep you informed about your use of the Services, improve, and develop the Services, conduct online advertising or other marketing activities, as well as manage and enforce any claim.
Where we have a legal obligation to collect, use and/or disclose your personal information or otherwise needs your personal information to protect your vital interests or those of another person. For example, when necessary to comply with the rules imposed by our or other applicable regulators; or
Exceptionally, we may share your information with a third party, when necessary, in the public interest, for example, when law enforcement agencies or other third parties with whom you may have had dealings request information to investigate a crime or otherwise a breach of third-party terms of business.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information for any specific processing activity, please contact us via the Contact Us section below.

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 Group to which MIR Limited UK Ltd to help us provide our services and for our own internal customer relationship management, analytical and reporting purposes.
To recipients/senders of a payment in the context of the specific relevant transaction.
Fraud prevention agencies as described above, 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, identity verification, and marketing, market research and survey activities carried out on our behalf. Occasionally, we may utilise the services of third-party providers to assist with the provision of services that might require the use of your personal information. 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.
Some information may be shared with our trusted financial service provider – Paynovate UK and Paynovate SA for the purpose to provide you card services. For information on Paynovate’s collection and use of data in accordance with the GDPR, please follow this link: https://www.paynovate.com/privacy-policy
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
With your permission, your information may also be used for other purposes for which you give your specific permission.

Except as necessary for the performance of our services and as described above/attached, we do not sell, rent, share or otherwise disclose personal information about its customers to third parties for their own third-party marketing use without meeting any necessary legal obligations (e.g., consent, opt-out, or as otherwise permitted by law).

5. 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.

FOR FURTHER INFORMATION ON OUR DATA RETENTION PERIODS PLEASE CONTACT: DPO@rtekk.com

6. 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.

7. 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.

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 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 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 complete our dedicated rights form or contact us via the details provided in the Contact Us section.

Privacy laws continue to develop and if you think or are unsure as to whether such right may apply to you, please also contact us, so we can assess and advise.

9. Children’s Privacy

The Services are not designated to users under the age of 18. If you are under 18, you should not download or use the Services nor provide any Personal Information to us.

We reserve the right to access and verify any Personal Information collected from you.

In the event we become aware that a user under the age of 18 has shared any information, we will discard such information.

If you have any reason to believe that a minor has shared any information with us, please contact us at dpo@muchbetter.com

10. How to Complain

If you have any concerns about our use of your personal information, you can make a complaint to us at complaints@muchbetter.com. 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/)

or in writing to:

-The Data Protection Officer

Rtekk Holdings Limited, Park House,

Isle of Man Business Park, Douglas, IM2 2SA

Or by telephone: +44 1624 698775

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 (as reflected in the “Last Revised” heading). 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.

12. 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 Help

Products

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