Securrency

Privacy Policy

Information posted on this website may be accessible to third-parties, by means of the internet or otherwise. You acknowledge that communications transmitted to or through this website are public and not private communications, and you confirm not to have any expectation of privacy with respect to any such communications.

Personal data

For purposes of this Privacy Notice, “Personal Data” means any information that, by itself or in combination with other information, identifies, relates to, describes, references, is capable of being associated with, or can reasonably be linked, directly or indirectly, to an individual, a device, or a household.  Personal Data does not include information that is anonymized, publicly available information from government records, deidentified or aggregated data subject information, information excluded from relevant data protection law by preemption by sector-specific privacy laws.  The Personal Data Securrency collects may include, but is not limited to: Contact Information, Client Data, Technology Information, Job Applicant / Employment  Information, Compliance Data, and Other Data.

How and Why We Collect Personal Data

 This Privacy Notice tells you how and why Securrency will collect and use Personal Data.

We collect Personal Data from many sources.  It may come directly from individuals (data subjects), indirectly from individuals (i.e. interactions with the website), or from clients, colleagues and publicly available sources.

We regularly receive Personal Data in connection with the provision of our services and as part of our professional activities. The Personal Data we may collect, includes, but may not be limited to:

  1. Personal Data collected as part of our business onboarding procedures;
  2. Personal Data collected when processing job applicant and employment related Personal Data;
  3. Personal Data collected when clients and prospective clients seek our advice;
  4. Personal Data collected when providing services to our clients;
  5. Personal Data collected that is publicly available (e.g. social media);
  6. Personal Data collected that is required for the provision of services from our vendors;
  7. Personal Data collected when individuals browse or interact with our website;
  8. Personal Data collected when carrying out our business, including records of interactions or correspondence with our company;

We collect Personal Data, among other reasons, for:

  1. The provision of services and to respond to requests for services;
  2. The provision of information related to our services either in response to specific requests or generally to develop business;
  3. The processing of job applications;
  4. The managing of our business relationships, including billing, accounting, collection and support services;
  5. The invoicing for our services and receiving payment;
  6. Compliance reasons, to meet legal and regulatory obligations;

How We Use Personal Data

Securrency will use Personal Data only as set out in this Privacy Notice, as well as other purposes for which you give your consent. Securrency will process (collect, store and use) Personal Data in compliance with applicable data protection laws and regulations. Securrency will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

We will endeavor to keep Personal Data provided to us accurate and up to date, and not to keep it for longer than is necessary. We are required to retain certain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of Personal Data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal Data may be held in addition to these periods depending on individual business needs.

Under which circumstances will we contact you

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the Personal Data provided to us will be subject to rigorous measures and procedures to minimize the risk of unauthorized access or disclosure.

What type of Personal Data do we hold

At no time will Securrency conduct any high risk processing activities and no special categories of personal data will be processed. At your request, Securrency can confirm what information we hold about you and how it is processed. If we do hold Personal Data about you, you can request the following information:

  1. Identity and the contact details of the person or organization that has determined how and why to process your data;
  2. Contact details of the data protection officer, where applicable;
  3. The purpose of the processing as well as the legal basis for processing;
  4. If the processing is based on the legitimate interests of Securrency or a third party, information about those interests;
  5. The categories of personal data collected, stored, and processed;
  6. Recipient(s) or categories of recipients that the data is/will be disclosed to;
  7. If we intend to transfer the personal data to another country or international organization, information about how we ensure this is done securely;
  8. How long the data will be stored;
  9. Details of your rights to correct, erase, restrict or object to such processing;
  10. Information about your right to withdraw consent at any time;
  11. How to lodge a complaint with the supervisory authority;
  12. Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the Personal Data and the possible consequences of failing to provide such data;
  13. The source of Personal Data if it wasn’t collected directly from you.
  14. Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will you require to provide to access information about your Personal Data

We accept the following forms of ID when information on your Personal Data is requested:

  1. Passport
  2. Driving License
  3. Birth certificate
  4. Utility Bill (not more than 3 months old)

How can you inquire about, change, update, correct or delete Personal Data

You can change, update, correct, or delete your Personal Data by sending us an email to [email protected]

Internal Personal Data sharing

Securrency is a global firm and a list of our offices, together with relevant contact information, may be found on our website. Irrespective of how we obtain your Personal Data, it may be shared among all the offices within Securrency (jurisdictions include the United States of America, the European Economic Area (“EEA”), and the ADGM) for the purposes outlined above.

Whom We Disclose Personal Data To

We may retain other companies and individuals to perform functions on our behalf. Such third parties may be provided with access to Personal Data to perform the functions for which they have been retained. Our agreements with these third parties will describe the purpose of the processing, will not permit them to use Personal Data for any purposes other than as is required to perform the function for which they have been retained and will commit them to comply with applicable data privacy standards.  We also enter into data processing agreements and standard model clauses with our vendors and clients whenever required and appropriate.

How We Protect Personal Data

Securrency has appropriate physical, technical, and administrative safeguards in place designed to protect your Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction. You should keep in mind, however, that no Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from our website may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

How Long We Retain Personal Data

Personal Data will be retained by Securrency for as long as the information is required to fulfill our legitimate business needs or the purposes for which the information was collected, or for as long as is required by law.

International Data Transfers

Our servers are either located in the United States of America or, if located in other countries, may be accessed from the United States of America. Please note that in countries outside your own country, and in particular outside the EU, the EEA, and the ADGM standards of data protection might apply which are different from those which apply in your own country.

By sharing Personal Data with Securrency, including via our website, you acknowledge and consent that your data may be transferred across international borders.

To govern our transfers of Personal Data from the United States of America, the EU, the EEA, and the ADGM, to recipients outside those jurisdictions, we have entered into the standard data protection clauses adopted by the European Commission, the ADGM, and other applicable jurisdictions (“Data Transfer Agreement”).

Revisions to this Privacy Notice

Securrency reserves the right to change this Privacy Notice at our discretion and at any time. We suggest to check this Privacy Notice regularly. When we make changes to this privacy notice, we will post the updated notice on the Website and update the effective date of the notice. Your continued use of our Website following the posting of changes will be considered as your acceptance of such changes.

Contact

You may contact Securrency if you have any questions or concerns about Securrency’s Personal Data policies and procedures. You can contact us at [email protected]