1. Introduction This Privacy Policy applies to personal data (“information”) held by Monfor (“we” or “us”) as data controllers. It explains in detail the types of information we collect about you and how we use this information. Please read it carefully. Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes. Please read the following carefully to understand how we handle your information. 

2. The information we may collect 2.1. Information you provide us · Personal details, e.g. your name, date of birth, gender; · Contact details, e.g. your address, email, phone number, mobile number · Information about your identity, e.g. your nationality, passport information, photo ID, National Insurance number; and · Your bank details (account name, number, and sort code). 2.2. Information we collect about you · Transactional information, e.g. details about your accounts, including payments made to and from these accounts; · Communication records, e.g. details recorded during our written and verbal communications with you; · Your preferences, such as consents for marketing and other communications; · Publicly available information, e.g. information made available by you on websites such as LinkedIn; · Usage data, including information about how you use our products and services; · Investigations data. This may include; anti-money laundering checks, credit checks, external intelligence reports, and other due diligence checks; · Information required to satisfy our regulatory obligations, e.g. information about transactions, detection of any suspicious and unusual activity, and information about parties connected to you or these activities; · Risk rating information, e.g. credit risk rating and transactional behaviour; and · Information gathered when you visit our websites. This might include; the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browsing plug-in types and versions, operating system and platform, Uniform Resource Locators (URL), and how you navigate our websites, e.g. products you viewed, issues you have encountered and page interaction information. We use this information for technical monitoring and optimising our websites. For more information, visit our Cookie Policy. Where we collect your personal information we will also reference this Privacy Policy to ensure you are informed of our processing activities and your rights under relevant data protection legislation. 

3. How we collect your information We collect your personal information, either directly or through a third party software, when you subscribe to our services, for example by filling in forms on our websites, by corresponding with us by telephone or email, or when you provide us copies of the documents required for us to confirm your identity. We may also collect your information when you interact with our websites. 3.1. Information from other sources We may receive your information from other Monfor if you use, enquire about, or demonstrate an interest in other services we offer. We will only do this when we have obtained your consent, have a legitimate interest, or have a legal obligation to do so. We may also receive your information from other third parties, such as: · Our partners (companies that introduce you to us); · Our clients (when they wish to make a payment to you); · Credit reference agencies; · Fraud prevention agencies; · Identity verification agencies; · Sub-contractors and advisers; · Agents and suppliers; · Government and law enforcement agencies (such as Companies House and HMRC); · Publicly available online sources, such as company websites, social networks and company registries. 3.2. Information you provide about other people If you provide us with personal information about another person, we ask that you inform them of our identity and the purposes for which their information will be processed. If you ask us to make a payment to another individual, you will need to provide us with their bank account and contact details. We use their contact information to notify the individual that they will be receiving a payment from us, on your behalf. We will never use the information you provide about another individual for marketing purposes. 3.3. Cookies Our websites use cookies to distinguish you from other users of our websites. This provides you with a better browsing experience, and also allows us to improve our websites. 3.4. Information collected by our partners and third party services • Google Analytics: Google Analytics is a web analytics service provided by Google, Inc (“Google”). Google uses cookies to help us analyze how users use our website. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. Google will truncate/anonymize the last octet of the IP address for Member States of the European Union as well as for other parties to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. On behalf of our website, Google will use this information for the purpose of evaluating your use of our website and compiling reports. Google will not associate your IP address with any other data held by Google. You may refuse the use of these cookies by selecting the appropriate settings on your browser as discussed in this policy under section 4. However, please note that if you do this, you may not be able to use the full functionality of the website. Furthermore you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB. Further information concerning the terms and conditions of use and data privacy can be found at http://www.google.com/analytics/terms/gb.html or at https://policies.google.com/?hl=en&gl=uk. • Google reCAPTCHA We use "Google reCAPTCHA" (hereinafter "reCAPTCHA") on our website. This service is provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA ("Google"). reCAPTCHA is used to check whether the data submitted through our website forms has been entered by a human or by an automated program / bot. To do this, reCAPTCHA analyzes the behaviour of the website visitor based on various characteristics. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, how long the visitor has been on the website, or mouse movements made by the user). The data collected during the analysis will be forwarded to Google. The reCAPTCHA analyses take place completely in the background. Website visitors are not advised that such an analysis is taking place. Data processing is based on Art. 6 (1) (f) of the GDPR. We, as website operator, have a legitimate interest in protecting our site from fraud. For more information about Google reCAPTCHA and Google's privacy policy, please visit the following links: https://www.google.com/intl/de/policies/privacy/ and https://www.google.com/recaptcha/intro/android.html. For detailed information on the cookies those services use and the purposes for which they are used, please see our Cookie Policy. 

4. How we use your information We will only use your information under the following circumstances: When it is necessary to fulfil our contract with you Some of the information we process is required for us to provide you with our products and services. For example, we require your banking details in order to settle payments on orders you place. Where we are under a legal obligation In certain cases, we are required by law to collect and process your information. For example, to fulfil our financial reporting obligations, we must store all records of communications you make with us that relate to transactions. That means that your communications (e.g. telephone communications to direct line or mobile numbers, Zoom and other remote communication platform meetings etc.) with us may be recorded. We are also required to check that you are the person you say you are before we discuss any of our clients’ accounts (which we may do by asking you to confirm your date of birth or other details about yourself) and to retain personal information to facilitate investigations detecting and preventing fraud, money laundering, and other financial crimes. Where we have obtained your consent In specific situations, we will collect and process your information with your consent, e.g. when you tick a box to receive marketing material from us, or ask us to contact you about our products and services. We will always make it clear to you what you are consenting to and what information is necessary for our services. If you have given consent to the use of your personal information, you are entitled to withdraw this consent at any time. Please be aware, however, that in some circumstances, the withdrawal of your consent may result in us being unable to provide some services to you. Where we have a legitimate interest Sometimes, we use your personal information to pursue our legitimate business or commercial interests in a way you might reasonably expect. We will not rely on our own legitimate interests without first considering your own rights, freedoms or interests, which we hold in the highest regard. Some of our legitimate interests include: · Carrying out marketing activities; · Communicating with you about our products and services; · Improving our products, services, and relationships with you and our partners; · Create a smoother customer service experience; · Monitor complaints handling; · Improve our websites to ensure that content is well presented for you; 4.2. Combining information We may combine information about you which we receive from other sources with the information you give to us, and the information we collect about you, for the same purposes as those set out above. 

5. How we share your information We only share your personal information under the following circumstances: · If we are under a duty to disclose or share your personal information in order to comply with a legal obligation; · In order to conduct necessary background checks on you before offering our products and services; · Where we have been asked for information to facilitate an investigation; · In order to enforce or apply our terms and conditions and other agreements; · To protect the rights, property, or safety of Monfor, our customers, or others; · Where we have a legitimate business interest that is not overridden by your own rights and freedoms; · Where we have obtained your consent. Entities that we may share your information with include: · Other Monfor Group companies; · Our partners (companies that introduce you to us); · Our clients (when they wish to make a payment to you); · Credit reference agencies; · Fraud prevention agencies; · Identity verification agencies; · Agents, suppliers, sub-contractors and advisers; · Regulatory bodies. 

6. International Transfers and Security We may be required to transfer your information to countries outside the UK and the European Economic Area (“EEA”), e.g. if we are obliged to report to foreign authorities, or when your information is processed by one of our suppliers under our instruction. In these cases, there will be a contract in place to make sure the recipient protects the information to the same standard as the UK and the EEA. We also implement strict procedures and security features to ensure that your information is transferred securely in line with the standards set out in UK and European protection laws. 

7. How long we store your information Personal information is retained according to our retention schedule. We only retain your information for a period necessary to fulfil the purpose for which it was originally processed, or in order to fulfil a legal obligation. 

8. Your rights Access You may request access to the information we hold about you by making a Subject Access Request.  You may request that we destroy, delete or discontinue using your personal information when it is no longer necessary for the purpose we originally collected it. Restriction You may request that we stop processing your information when you contest its accuracy or the lawfulness of the processing. Rectification You may ask us to update and correct any out-of-date or incorrect personal information that we hold about you. Portability Under certain circumstances, you may ask us to provide a copy of your information to another organisation in a structured, machine-readable format. Withdrawing consent Whenever you have given us your consent to use your information, you have the right to change your mind at any time and withdraw your consent. Legitimate interests In cases where we are processing your information on the basis of our legitimate interests, you can ask us to stop for reasons connected to your individual situation. We will do so unless we believe we have a legitimate overriding reason to continue processing your information. Please bear in mind that if you do object, this may affect our ability to provide you with some of our services. Marketing You have the right to stop our use of your information for direct marketing activities through all channels, or selected channels. You always have the opportunity to opt-out, and we will always comply with your request. To do so, click the ‘unsubscribe’ link in any email communication we send to you to notify us that you would like us to stop any further emails. 

9. Submitting a request You can request to exercise these rights at any time by contacting us at [email protected] To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Policy. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act on your behalf. You will not have to pay a fee to access your personal information (or to exercise any other rights). However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. If we do refuse your request, we will explain to you the reasons for our refusal. You also have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, is available at https://ico.org.uk 

10. Further information In the event that you have any questions, comments or concerns regarding this Privacy Policy, please contact our Information Security & Data Protection Officer through the following methods: Email: [email protected] Letter: Attn: Andrew Jolliffe, Monfor Information Security & Data Protection Officer, Monfor, Admin Office, The Old Mill, Kings Mill Lane, South Nutfield, Surrey, UK, RH1 5NB. Our policies are also available in PDF format, please email [email protected] to request the one you’d like. 



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