Vivier (or “we” or “us”) are committed to protecting and respecting your privacy. We review this policy from time to time to ensure it is up to date. The latest version can be found on our Website.
1 SCOPE OF POLICY
1.1 This policy, together with the Standard Terms and Conditions apply to your use of:
1.1.1 any of the services we provide to you (the “Services”); and
1.1.2 our Website.
1.2 This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us.
2 WHAT IS PERSONAL DATA
2.1 Personal data means all data that identifies you or that could be used to identify you, such as your name, contact details and financial information.
2.2 We collect personal information to provide you with our Services. When we require certain personal information from you it is because we are required by law to collect this information or it is relevant for specified purposes.
2.3 For example, we collect personal information which is required under the law to open an account or execute a transaction. We also collect personal information when you use our Services or when you contact us for support. We may use this information in combination with other information we collect about you as set forth in this Policy.
3 THE TYPES OF PERSONAL DATA WE PROCESS
3.1 As a starting point, we endeavour not to collect more information than we need and treat non-essential information you provide to us as voluntary.
3.2 You provide personal data to us by filling in forms, by corresponding with us, when using any of our Services or by entering into any transaction. The information you give us may include:
3.2.1 Personal Identification Information: Full name, date of birth, age, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email.
3.2.2 Formal Identification Information: Tax ID number, passport number, driver’s license details, national identity card details, photograph identification cards, and/or visa information.
3.2.3 Financial Information: Bank account information, transaction history and/or tax identification.
3.2.4 Transaction Information: Information about the transactions made through our Services, such as the name of the recipient, your name and the amount;
3.2.5 Employment Information: Office location, job title, and/or role; and
3.2.6 Any other information you provide us in order to prove your eligibility to use our Services.
3.3 Other information we collect to help us deliver our Services to you may include:
3.3.1 survey responses;
3.3.2 information provided to our support team;
3.3.3 authentication data; and
3.3.4 security questions.
4 USES MADE OF THE INFORMATION
4.1 We will only process your personal data when there is a legal basis to do so. In almost all cases, the legal basis will be the following:
4.1.1 to use your data to process your transactions.
4.1.2 to conduct and improve our business, ie one of Vivier’s legitimate interests as a financial services provider.
4.1.3 to fulfil a legal obligation.
4.1.4 to protect your vital interests and those of other people.
4.1.5 to use your data for a specific purpose.
4.2 If the processing of your data is protected by any other law, the legal basis for this processing could be different to the list above. In those circumstances, the legal basis would normally be your consent.
4.3 Below you will find additional information on each aspect of the legal basis.
4.3.1 To maintain legal and regulatory compliance. Some of our core Services are subject to laws and regulations requiring us to collect and use your personal identification information, financial information, transaction information, and/or employment information in certain ways. For example, to verify your identity to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our Services;
4.3.2 To provide our Services. We process your personal information in order to provide the Services to you. For example, for transfers, ATM withdrawals and deposits we require certain information such as your identification, contact information, and financial information. We cannot provide you with the Services without such information.
4.3.3 To provide Services communications. We send administrative or account-related information to you to keep you updated about our Services or changes to it, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services.
4.3.4 To provide customer service. We process your personal information when you contact us to resolve any questions, disputes or to troubleshoot problems. We may process your information in response to another customer’s request, as relevant. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.
4.3.5 For research and development purposes. We process your personal information to better understand the way you use and interact with our Services. In addition, we use such information to customize and improve our Services and the content and layout of our website, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services. Our basis for such processing is based on legitimate interest.
4.3.6 To engage in marketing activities. Based on your communication preferences, we may send you marketing communications to deliver targeted marketing or to provide you with promotional offers based on your communication preferences. You can opt-out of our marketing communications at any time.
4.4 We will not, without your permission, use your personal information for purposes other than those purposes we have disclosed to you.
4.5 From time to time we may request your permission to allow us to share your personal information with third parties.
5.1 You will receive marketing communications from us if you have signed up to and/or utilize our Services and, in each case, you have opted in to receiving marketing communications.
5.2 When we collect data directly from you we may ask you whether you wish to receive our marketing communications. These marketing communications will be about our Services that may be of interest to you. We will respect your decision regarding which communications you wish to receive and the way you want to receive them. You can ‘opt-out’ from receiving any marketing communications from us whenever you want.
5.3 Third-Party Marketing. Vivier uses third party marketing. We will obtain your opt-in consent before we share your personal data with any company outside the Vivier group of companies for marketing or promotional purposes.
6 DISCLOSURE OF YOUR INFORMATION
We share your information only where you ask us to, where it is a necessary part of doing business with you and providing you with the services, or where we need to for legal reasons.
6.1 Data Processing Partners
6.1.1 We will disclose the data we collect from you to certain third parties who use personal data in delivering their services to us, they use data securely and confidentially and under strict contractual controls in accordance with data protection laws and enforced by Vivier.
6.1.2 We send personal data to the following sets of data processors in order to perform the Services:
188.8.131.52 Fraud prevention agencies. This is in order to verify your identity, protect against fraud, comply with anti-money laundering laws and to confirm your eligibility to use our products and services;
184.108.40.206 Cloud storage providers. This is in order to safely and securely store your data;
220.127.116.11 Banking and financial services partners. Financial services providers that help us provide the Services including banking partners, banking intermediaries and international payments services providers;
18.104.22.168 Credit reference agencies. For the purpose of assessing your credit score.
22.214.171.124 Companies within the Vivier group. In order to provide a unified service across all of our services, we may disclose your personal information to any member of the group, which means any of our subsidiaries or related entities.
6.2 Third Party Services Providers
6.2.1 We may share your data in order to provide certain services to you. For example, we will share your data with secure marketing platforms to deliver our marketing promotions. Your data will only be sent once you have asked to utilise these services.
6.3 Other circumstances:
6.3.1 If Vivier’s shares or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
6.3.2 If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
6.3.3 To enforce or apply the General Terms of Services or any other agreements between you and us or to investigate potential breaches.
6.3.4 To protect the rights, property or safety of Vivier, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7 DATA AND STORAGE SECURITY
7.1 Keeping your personal data secure represents a high priority for us. We limit access to only those Vivier group employees who have to come into contact with your information to do their jobs and deliver our Services.
7.2 The measures we use to keep your personal data safe and secure include: password and two factor authentication, data encryption, firewalls, intrusion detection systems, 24/7 physical protection of facilities where your data is stored and strong security procedures across all service operations. We encrypt the transmission and storage of your personal data using the highest standards of security technology and procedures.
7.3 All information you provide to us is stored in the cloud or on our secure servers. Any payment transactions carried out by us is done through secure wire transfers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
7.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us or our Site; any transmission is at your own risk. However, as described above, we have created an organisation-wide security programme designed to keep your personal data as safe as possible. It uses a range of technical and administrative security measures and best-practice techniques, depending on the type of data being processed.
8 RETAINING YOUR INFORMATION
8.1 We keep your personal data only for as long as we need to. This depends on why it was collected, or if we have a continuing legal basis to do so, such as to fulfil a contract between us, perform a service you requested or for our legitimate interests. If we no longer have a reason or legal requirement to process your personal data, we will delete it or store it in a way that no longer identifies you.
8.2 No matter how long the retention period, you can ask us to delete your personal data in certain circumstances.
8.3 You may also opt out of allowing us to use or share your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorisation.
8.4 Although the intention is not to prevent the use of our Services, if you choose to withdraw or limit the use of your personal information, certain features of our Services may not be available to you.
9 YOUR LEGAL RIGHTS
You have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
9.1 To request access to your personal. This enables you to receive a copy of the personal data we hold about you. If you require this, then please email us with the request.
9.2 To request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you require this, then please email us with the request.
9.3 To request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
9.4 To object to processing of your personal data. This is in situations where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
9.5 To request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
9.5.1 if you want us to establish the data’s accuracy;
9.5.2 where our use of the data is unlawful but you do not want us to erase it;
9.5.3 where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
9.5.4 you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel your use of the Services, but we will notify you if this is the case at the time.
9.6 To request the transfer of your personal data to you or to a third party. We will provide to you, your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. If you require this, then please email us with the request.
9.7 To withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.