In this privacy policy, terms such as “Top Connect Limited”, “us” and “we” refer to Top Connect Ltd, Top Connect, a limited liability company registered in England and Wales (registration number 08659511), with its registered office at St. James Tower, 7 Charlotte Street, Manchester, M1 4DZ. Top Connect is registered with UK Information Commissioner’s Office (reference number ZA079914).
Top Connect Ltd is authorised as a Small Payment institution by the Financial Conduct Authority (reference number 610825). Top Connect Limited is strongly committed to protecting your privacy and complying with your choices. Both personal and non-personal information collected is safeguarded according to the highest privacy and data protection standards adopted worldwide. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR and the Data Protection Laws of the United Kingdom.
Definitions and interpretation
Data
Collectively all information that you submit to Top Connect Limited via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws
Cookies
A small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies)
Data Protection Laws
Any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK
GDPR
The General Data Protection Regulation (EU) 2016/679
Top Connect Limited, or us
Top Connect Limited, a company incorporated in England and Wales with registered number 08659511 whose registered office is at St. James Tower, 7 Charlotte Street, Manchester, M1 4DZ
UK and EU Cookie Law
The Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011
Use or you
Any third party that accesses the Website and is not either (i) employed by Top Connect Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Top Connect Limited and accessing the Website in connection with the provision of such services
Website
The website that you are currently using, www.topconnectltd.co.uk, Application and any sub-domains of this site unless expressly excluded by their own terms and conditions.
In this privacy policy, unless the context requires a different interpretation:
a. the singular includes the plural and vice versa;
b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
d. “including” is understood to mean “including without limitation”;
e. reference to any statutory provision includes any modification or amendment of it;
f. the headings and sub-headings do not form part of this privacy policy.
Scope of this privacy policy
This privacy policy applies only to the actions of Top Connect Limited and Users with respect to this Website and Application. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
For purposes of the applicable Data Protection Laws, Top Connect Limited is the “data controller”. This means that Top Connect Limited determines the purposes for which, and the manner in which, your Data is processed.
What data we might collect?
We may collect the following Data, which includes personal Data, from you:
a. name;
b. date of birth;
c. contact Information such as email addresses and telephone numbers;
d. IP address (automatically collected);
e. in each case, in accordance with this privacy policy.
How we collect Data
We collect Data in the following ways:
a. data is given to us by you;
b. data is received from other sources;
c. data is collected automatically.
Data that is given to us by you
Top Connect Limited will collect your Data in a number of ways, for example:
a. when you contact us through the Website, by telephone, post, e-mail or through any other means;
b. when you register with us and set up an account to receive our products/services;
c. when you enter a competition or promotion through a social media channel;
d. when you make payments to us, through this Website or otherwise;
e. when you elect to receive marketing communications from us;
f. when you use our services;
in each case, in accordance with this privacy policy.
Data that is received from third parties
Top Connect Limited will receive Data about you from the following third parties:
a. KYC and ID Verification Service Providers;
Data that is collected automatically
To the extent that you access the Website, we will collect your Data automatically, for example:
a. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
b.we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.
Our use of Data
Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
a. internal record keeping;
b. improvement of our products / services;
c. transmission by email of marketing materials that may be of interest to you;
d. contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;
e. Regulatory;
in each case, in accordance with this privacy policy.
We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below). For the delivery of direct marketing to you via e-mail, we will need your consent, whether via an opt-in or soft-opt-in:
a. soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
b. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that will provide.
c. if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Who we share Data with
We may share your Data with the following groups of people for the following reasons:
a. our employees, agents and/or professional advisors – we partner with other Financial Institutions and Money Service Businesses (MSBs) in different countries to provide you and your receiver with a range of pay-out services from cash pick-ups, mobile money to airtime;
b. third party service providers who provide services to us which require the processing of personal data – to verify your identity, we rely on trusted Know Your Customer (KYC) and ID verification service providers. This may involve verifying your information against credit institutions, PEPs and sanctions lists;
c. third party payment providers who process payments made over the Website – to enable third party payment providers to process user payments and refunds;
d. relevant authorities – we are legally required to keep the data obtained for Know Your Customer (KYC), Customer Due Diligence (CDD) and security purposes (including transaction records and our communications with you) for at least five years after the most recent transaction;
in each case, in accordance with this privacy policy.
Keeping Data secure
Protecting your personal data is very important to us. Top Connect maintains physical, electronic and procedural safeguards that comply with the applicable laws to protect your personal information from unauthorised access:
Using network and application firewalls when you transmit your personal data from your device to our servers, your information is protected by both a “firewall” and industry standard SSL (secure socket layer) encryption.
Secure storage. Once your data reaches our servers, data is securely stored.
Access control. Top Connect maintains a strict policy to control who can have access to your personal data. Any personal data will be accessible by Top Connect employees on a need-to-know basis only. Top Connect regularly trains staff on data protection practices to ensure all employees are aware of the Data Protection Regulations, data protection principles and customers’ rights as data subjects.
Payment Card Industry Data Security Standard (“PCI-DSS”). Any financial information you transmit when you enter your card details is processed in accordance to PCI-DSS standards..
System testing Top Connect regularly tests and reviews its systems and security practices..
Controlled data sharing. Before we decide to share your data with any third party, we make a careful assessment of that third party’s level of data protection. Any agreement to share data is made only with third parties which have an adequate level of data protection which complies with the Data Protection Regulations..
Even though Top Connect will make every effort to protect your data, you accept that we cannot guarantee security when you transmit it over the internet, and any transmission is at your own risk. To minimise your risk, we highly recommend that you do not share your login credentials, passwords, pin numbers or any other Account details with anyone else. We also highly recommend that you use appropriate anti-virus software to protect yourself from your data being compromised..
Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including holding your personal data until we are lawfully required to do so. To comply with relevant KYC, anti-money laundering and counter-terrorism financing regulations, we are obliged to retain your data for at least five years after your last transaction with us in respect of the Remittance Services. We will store your data in respect of the Top Connect Money Transfer Services for one year after you close your account with us. We might retain your data for a longer period if instructed so by the relevant authorities or if required to protect rights of Top Connect.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
What are your rights?
You have the following rights in relation to your Data:
a. Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
b. Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
c. Right to erase – the right to request that we delete or remove your Data from our systems.
d. Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.