Privacy
Covercy Group and GDPR
The EU General Data Protection Regulation came into force on 25th May 2018. Covercy Europe Limited and Covercy Technological Trading Ltd (together “Covercy”) have been considering its impact on our business and our relationship with users of our service. The intention is to post a detailed and fully compliant revised privacy policy in this location very shortly. For the time being, Covercy wishes to reassure users of the services we offer that:
• Full compliance with GDPR assumes great importance for us.
• We will strictly police the basis upon which personal data received from our clients is used in our business and passed on to others. Personal data includes names, addresses, telephone numbers and email contact information.
• It is highly exceptional that we pass on personal details to any third party other than where this is essential to conclude a trade instructed through us.
• Exceptions would include compliance with our duties to disclose information to the FCA, our regulator.
• If you require fuller information on our approach to GDPR, please contact us at support@covercy.com
• If you think it is likely or possible we hold personal data for you that you wish us to delete, please follow this link to a page where you will be able to request that we disclose the information we hold and request we delete it.
IMPORTANT: if you ask us to delete your personal information, Covercy will not be able to provide our services to you.
1. Privacy
1.1. We respect your privacy and are committed to protecting your personally identifiable information delivered to us during your use of our website (“Personal Information ”), as contemplated in this privacy policy (“Privacy Policy”). The Privacy Policy explains our policy regarding the type of information (the “Information” – which includes, but is not limited to, Personal Information) we collect from you when you use our website (the “Website”) and the services offered within it (the “Services”), why we collect it and how we use it.
1.2. This Privacy Policy is part of and should be read in conjunction with our Terms and Conditions. When you access or use our Website and/or our Services, you express your approval of any use made of the Information collected from or about you, as contemplated in this Privacy Policy.
1.3. We are authorized to make changes to this Privacy Policy from time to time. In the event where changes are made to this Privacy Policy, we will notify you of these changes by posting the revised privacy policy on the Website. Therefore, we recommend that you revisit this Privacy Policy regularly.
2. Who are we?
Covercy provides money transfer services and related products through the Website.
2.1. If you are a user located or registered with us in the United Kingdom or anywhere else in the world excluding Israel, then except where otherwise stated, references in this Privacy Policy to “Covercy”, “we”, “us” and “our” are references to Covercy Europe Limited, a private limited company registered in England and Wales under company number 09447723 whose registered office is located at 5 Elstree Gate, Elstree Way, Borehamwood, Hertfordshire, WD6 1JD. (“Covercy Europe”). For the purposes of the UK’s Data Protection Act 1998, Covercy Europe is the data controller in relation to the processing of Personal Information provided by users located or registered with us in the United Kingdom or anywhere else in the world excluding Israel.
2.2. If you are a user located or registered with us in Israel, then except where otherwise stated, references in this Privacy Policy to “Covercy”, “we”, “us” and “our” are references to Covercy Technological Trading Ltd., a company registered in Israel under company number 515200657 (“Covercy Israel”).
3. Collection of Information
3.1. When you create an account with the Website and/or use the Services, we may collect certain Personal Information about you.
You are not legally obligated to provide us with any Personal Information about you, but rather any such provision of Personal Information is dependent upon your will and consent. However, certain Services may not be rendered if certain Personal Information is not provided.
The Information that we may collect from you includes, but is not limited to, the following:
Registration Information: in order to be able to use the Services offered on the Website you need to complete a registration process and provide Covercy with Information, including Personal Information. Such information includes your name, email address, contact details, complete a registration process.
Transactions information: in order for us to be able to provide you with the Services, you will be required to provide us with certain details about the Services that you will seek to obtain. Some of this information is required by us in order to implement anti-money laundering and terror financing measures as required by anti-money laundering laws applicable to us.
Usage information: when you use the Website and/or Services, we automatically collect certain information about your use of the Website and the Services. Such information includes, but is not limited to, system preferences, language selection, IP addresses or other unique identifiers of the devices through which you use the Website and/or the Services, browser and operating systems used by you, dates and times of using the Services and reports of technical malfunctions.
Communications between us and you: we may record any communication (including, but not limited, email correspondence, chat and telephone conversations) between us and you. We may do so in order to resolve queries in the future, to monitor the quality of our Services and to ensure compliance with certain legal duties applicable to us, particularly anti-money laundering and terror financing legislation.
In any event that you provide us with Information regarding a third party, you confirm to us that you have the right to provide us with such information and that you have referred such third party to this Privacy Policy as its provisions apply to our collection, use and disclosure of such Information as well.
3.2. The Information provided will be used only for Covercy’s purposes, including providing you with the Services and will not be used for any needs other than Covercy’s activity. Except as set forth in this Privacy Policy, we will not disclose the Information to any third parties. Covercy may use the services of data processing and storage of its affiliates and you hereby consent to the sharing of your Information between Covercy and its affiliates.
3.3. In addition to the Information provided by you, Covercy may collect additional personal information from third parties. Covercy will consider such information as Personal Information.
3.4. You are responsible for ensuring the accuracy of your Personal Information and all other Information you submit to us. It is hereby clarified that providing false information constitutes a criminal offence and the perpetrator would be liable for sanctions in accordance with the law.
3.5. Covercy undertakes that the Information shall be kept in a database in accordance with the provisions of the Israeli Privacy Law, 1981 (the “Privacy Law”) in connection with Covercy Israel.
3.6. The aforesaid constitutes a notice under Section 11 of the Privacy Law.
3.7. You have the right to access the Information provided by you to Covercy for the purpose for reviewing its correctness.
3.8. You may review Personal Information independently through your account page if you: (1) want to confirm the accuracy of the Personal Information we have collected about you; and/or (2) would like to update your Personal Information; you may e mail our customer service at support@covercy.com if you wish to (Y) update your Personal Information; and/or (Z) have any complaint regarding our use of your Personal Information. If requested, we will (a) update any Information you have provided to us, provided that you furnish evidence that we may require, or (b) mark any Information so as to prohibit its future use for marketing purposes. For the avoidance of doubt, nothing in this Privacy Policy shall prevent us from retaining your Personal Information (including Personal Information that you asked to update or restrict) where we are required to do so by law. Please note that requesting to delete your Personal Information may lead to termination of your Registered User status.
4. Use of Information
Your Information will be stored in Covercy’s Database (the “Database”).
The Information in the Database will be used for the purposes for which the Database was established, in accordance with the provisions of this Privacy Policy or any law, as well as for the following subsequent purposes:
4.1. offer our Services and to provide customer support;
4.2. implement anti-money laundering and terror financing measures that we are obligated to take pursuant to anti-money laundering laws applicable to us;
4.3. provide you notices with respect to the Services;
4.4. transfer of funds to the Recipient;
4.5. track your use of the Website and for other internal purposes, such as evaluating the Website and improving our Services;
4.6. Gather statistical information regarding the activity on our Website for the purpose of improving the Services offered on our Website;
4.7. Monitoring the use for the prevention of misconduct;
4.8. Storage of the Information in accordance with the Privacy Law;
4.9. Distribution of marketing materials, including through Direct Marketing, general and personalized notices to those users who consented to the receipt of such;
4.10. Sending notices with respect to any breaches of the Terms and Conditions;
4.11. To protect our rights and properties
The Website uses the Lucky Orange analytics system to help improve usability and the customer experience. Lucky Orange may record mouse clicks, mouse movements and scrolling activity. Lucky Orange may record keystroke information that you voluntarily enter on the Website. Lucky Orange does not track this activity on any site that does not use the Lucky Orange system. You can choose to disable the Lucky Orange Service at https://www.luckyorange.com/disable.php. Note, that doing so will disable other features of the Lucky Orange system that the Website employs such as 1-to-1 support chat.
5. Disclosure of Personal Information to Third Parties
5.1. We will not disclose the Information to any third parties unless we are required to do so in order to provide the Services or as required by any law. Accordingly, we may transfer Personal Information to the following third parties and in the following circumstances: (i) entities controlled by, controlling or under common control with, us; (ii) third parties providing services to us or to anyone on our behalf for the purpose of providing the Services and maintaining the Website; (iii) if we believe in good faith that such action is necessary to: (A) comply with any legal process or in circumstances where we are legally obligated; (B) defend any dispute, claim, action, demand, or legal proceedings, if any, between yourself and Covercy and/or others on its behalf; (C) protect and defend our rights and property; (D) protect the personal safety of other users or the public; or (E) required by any of our liquidity providers, brokers, banks, or payment service providers in order to provide the Services or comply with their regulatory requirements.
5.2. Moreover, in the event that we sell, assign, or transfer some or all of our business or assets to a successor or acquirer, or if we are acquired by or merge with a third party, or if we file for bankruptcy or become insolvent, we may sell, assign, or transfer all of your Personal Information and other information provided by you or about you, regardless of your opt out status, to such successor or acquirer. 5.3. Any information pertaining to minors under 18 years of age will not be used for Direct Marketing.
6. Direct Marketing
6.1. Your Personal Information will also be used to contact you personally, based on your affiliation to a population group, as determined by the characterization of one or more persons whose names are included in the Database (“Direct Marketing”). Such contacts constitute a “direct marketing” under the Privacy Law, and they will be made only if you have given explicit consent. You may opt out and cease to receive direct mailing as stated at any time, by choosing the button “Remove” in the body of the message sent to you or by sending an email to our Customer Service (at support@covercy.com ). By doing so, Covercy will only delete the Information which is required to contact you by Direct Marketing, while the rest of the Information you submitted to Covercy which is necessary in order to provide you with the Services will continue to be stored in the Database, but will be no longer be used for Direct Marketing.
6.2. We do not disclose Personal Information to advertisers. However, we may transfer statistical information regarding the activity of our Website users. Statistical information to be delivered will not identify you personally.
7. Cookies
We use a browser feature known as cookies, which are small text files which are placed on your computer or equipment when you visit certain online pages, to track your activities, record your preferences, and make our Website more responsive to your needs by delivering a better and more personalized experience to you. The cookies are stored on your computer’s hard drive and are used by us to help track your clicks and to pass information as you go through the pages within our Website. Cookies can allow us to associate navigational information from browsing visits with Personal Information you provide at our Website.
8. Security
8.1. The security of your Personal Information is important to us. We understand the importance of information security and the techniques needed to secure information. We have implemented suitable security policies, rules, and technical measures in order to protect and safeguard the Personal Information under our control from unauthorized access, improper use or disclosure, unauthorized modification, unlawful destruction, or accidental loss. All our employees and data processors that have access to, and are associated with the processing of your Personal Information, are obliged to respect the confidentiality of your Personal Information.
8.2. The security of your account depends on you keeping your account password confidential. If you share your account information with a third party, he or she will have access to your account and your Personal Information.
8.3. It is your responsibility to control access to your computer and account, including keeping your password confidential and not sharing it with anyone. It is also your responsibility to alert Covercy if you believe that the security of the Information in your account or our Website has been compromised.
9. Transfers of Information Outside the Jurisdiction of the State of Israel
We may transfer your Information to jurisdictions outside the jurisdiction of the State of Israel and/or outside the European Union.
The data protection and privacy laws of the jurisdictions to which the Information will be transferred may not be as comprehensive as those in the European Union; in which case we will take measures to ensure a similar level of protection is provided to your Personal Information.
10. Links to Other Sites
Our Website may contain links to other sites on the Internet (the “Links”), which are not operated by us (the “Other Sites”) and are governed by different privacy policies.
Although we aim to be linked to reliable and trusted websites only, we are not responsible for the privacy practices or systems and procedures for the security and the protection of information applied on the Other Sites, or of the information collected by the Other Sites and/or third parties who are not governed by this Privacy Policy, and we assume no responsibility or liability whatsoever for the policies (including privacy policies), practices, actions, or omissions of such third parties.
11. Legal Disclaimer
We are not responsible for events beyond our direct control.
We cannot guarantee, nor do we represent, that there will be error-free performance regarding the privacy of your Personal Information, and we will not be liable for any indirect, incidental, consequential, or punitive damages relating to the use or release of Personal Information including, but not limited to, disclosure of Personal Information due to errors in transmission, unauthorized third-party access, or other causes beyond our reasonable control.
12. Contact Us
For any questions regarding the Terms of Use or Services on our Website or this Privacy Policy, please contact us as follows:
Covercy Technological Trading Ltd.
3 Ha-Yetsira St, Ramat Gan 5252141 Israel
Phone: +972-3-720-8883
Email: support@covercy.com
Covercy Europe Limited
5 Elstree Gate, Elstree Way, Borehamwood, Hertfordshire, WD6 1JD England.
Phone: +44-203-8567-888
Email: support@covercy.com
