VenturePay ("us", "we", or "our") operates the https://venturepay.co.uk website (hereinafter referred to as the "Service").
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://venturepay.co.uk
We collect several different types of information for various purposes to provide and improve our Service to you.
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
We may use and store information about your location if you give us permission to do so ("Location Data"). We use this data to provide features of our Service, to improve and customise our Service.
You can enable or disable location services when you use our Service at any time by way of your device settings.
We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
VenturePay Limited uses the collected data for various purposes:
If you are from the European Economic Area (EEA), VenturePay Limited legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
VenturePay Limited may process your Personal Data because:
VenturePay Limited will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
VenturePay Limited will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
VenturePay Limited will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
Venturepay Limited (the "Firm") is committed to preventing money laundering and terrorist financing. The Firm has a zero-tolerance policy towards any involvement in money laundering or terrorist financing
The Firm is required to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the "MLRs") and the Proceeds of Crime Act 2002 (the "POCA"). The MLRs require the Firm to take reasonable steps to prevent money laundering and terrorist financing. These steps include:
The main risks facing the firm are
Whilst the likelihood of encountering instances of money laundering other than tax evasion or even terrorist financing may be minimal, principals, staff and sub-contractors must remain alert to such eventuality.
Principals, staff and sub-contractors must also be alert for complex or unusually large transactions and unusual patterns of transactions which have no apparent economic or visible lawful purpose.
Similarly, principals, staff and sub-contractors must identify situations where the client is using products and transactions which might favour anonymity (such as Panamanian companies), recognise the increased risk of money laundering or terrorist financing that these products and transactions produce, and take additional measures, where appropriate.
All know our client forms and customer due diligence forms should record the client’s risk profile.
Risk assessments will be undertaken and documented prior to any new business practices or technology updates being implemented.
Senior management approval should be obtained before establishing or continuing a business relationship with any high-risk clients.
In conjunction with the senior management of the firm the MLRO should prepare and keep up to date a risk assessment for the firm that assesses the risks faced by the firm as identified above relevant to its client base. This assessment should also consider risks identified by the firm’s regulator for AML purposes and the National Risk Assessment.
The standard approach to verifying the identity of individuals will be (in order of preference):
When carrying out enhanced due diligence on individuals, the standard approach should be enhanced with at least one additional piece of evidence of identity.
Before the first regulated activity for the client is undertaken staff should check that:1. A risk assessment taking account of risks identified in the firm’s own risk assessment has been completed and updated where necessary.
2. Existing evidence of identification for the client is up to date. If not, it should be updated.
3. Existing list of principals (directors, partners, trustees, etc.) is up to date. If not, it should be updated.
4. Depending on the risk assessment in ‘1’, the file contains adequate information to satisfy us on the identity of the principals
5. Where the client has beneficial owners, the details of all beneficial owners are fully recorded and up to date.
6. Depending on the risk assessment in ‘1’, the file contains adequate information to satisfy us that we know who any beneficial owners are.
7. Know your client forms exist and are up to date.
8. The client’s risk assessment in ‘1’ remains up to date and appropriate.
As part of the firm’s customer due diligence procedures, consideration must be given to establishing whether the client is a politically exposed person, or a family member or close associate of a politically exposed person or is included on a sanctions list. This is achieved by checking the client on [specify service used such as an electronic check.
Because of the increased risk involved the firm will not seek to rely on customer due diligence evidence obtained by others. Instead, where we are acting for a mutual client who has already provided adequate customer due diligence to a financial or credit institution, firm of accountants or a lawyer, we should seek certified copies of that evidence in an attempt to avoid requiring the client to produce identification evidence again.
Similarly, we will not allow other firms to rely on our customer due diligence Evidence. However, if we are acting for a mutual client, we will normally provide the other firm with certified copies should they ask for them.
We must maintain appropriate ongoing monitoring of all client transactions to prevent activities related to money laundering and terrorist financing. This applies even where the client qualifies for simplified customer due diligence measures.
In future years, steps 1 to 8 in the customer due diligence section should be reviewed to ensure the information held is still appropriate.
All principals and staff must report knowledge or suspicion of money laundering (including bribery and tax evasion), whether it relates to clients or anyone else. Before deciding that a potentially suspect activity is not suspicious, you should consider whether the information you have might provide “reasonable grounds for knowledge or suspicion”.
In the event of a report being made to the MLRO or to NCA, or to any other person authorised to receive disclosures including the police and HM Revenue & Customs, under no circumstances must the client be informed. This means that the client must not be made aware that a report has been made. It also means that the client should not be made aware if an investigation into allegations that a money laundering offence has been committed is being contemplated or carried out.
If it appears to be necessary to disclose the existence of a report or an actual or contemplated investigation to any other person (i.e. not the client) then the MLRO must be consulted before any disclosure is made.
A qualified accountant or tax adviser can try to dissuade a client from committing a criminal offence without fear that the discussion could be treated as tipping off. However, this should not refer to any reports that have been or would be made.
We will keep full records of:
All such records shall be retained for at least six years. The latest records of customer due diligence checks, details of beneficial ownership and know your client forms for clients with whom we had a business relationship will be kept for at least six years from the end of the relationship.
The Firm's ProceduresThe Firm has in place a number of procedures to prevent money laundering and terrorist financing. These procedures include:
A customer due diligence (CDD) policy and procedure;A suspicious activity reporting (SAR) policy and procedure; and A record-keeping policy and procedure.
The Firm's CDD policy and procedure requires the Firm to obtain and verify the identity of its clients before entering into a business relationship with them. The Firm's SAR policy and procedure requires the Firm to report any suspicious activity to the NCA. The Firm's record-keeping policy and procedure requires the Firm to keep records of its AML/CTF procedures and activities for at least six years.
The Firm's staff are required to receive training on the Firm's AML/CTF procedures. The Firm's training program covers the following topics:
- The MLRs;
- The POCA;
- The Firm's AML/CTF procedures; and
- How to identify and report suspicious activity.
- The Firm's Compliance
The Firm is committed to complying with the MLRs and the POCA. The Firm has a number of procedures in place to ensure that it complies with these requirements. These procedures include:
The Firm's compliance officer is responsible for ensuring that the Firm complies with the MLRs and the POCA. The Firm's AML/CTF committee is responsible for developing and reviewing the Firm's AML/CTF procedures. The Firm's AML/CTF training program ensures that the Firm's staff are aware of their AML/CTF obligations.
Venturepay Limitedis committed to preventing money laundering and terrorist financing. The Firm has a zero-tolerance policy towards any involvement in money laundering or terrorist financing. The Firm has in place a number of procedures to prevent money laundering and terrorist financing, and the Firm is committed to complying with the MLRs and the POCA.
If VenturePay Limited is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
Under certain circumstances, VenturePay Limited may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
VenturePay Limited may disclose your Personal Data in the good faith belief that such action is necessary to:
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. VenturePay Limited aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyse the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
VenturePay Limited uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.
Google Ads (AdWords) remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/ , the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
AdRoll remarketing service is provided by Semantic Sugar, Inc.
You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences web page: http://info.evidon.com/pub_info/573?v=1&nt=1&nw=false
For more information on the privacy practices of AdRoll, please visit the AdRoll Privacy Policy web page: http://www.adroll.com/about/privacy
Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If you have any questions about this Privacy Policy, please contact us:
support@venturepay.co.uk
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