Purpose of this privacy policy

This privacy policy aims to give you information on how 3S Money collects and processes your personal data through your use of this website, including any data you may provide through this website when you process payments, take actions relating to your account, communicate with our Client Managers or during the onboarding process.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

3S Money: 3S Money Club Limited, with registered address at 45 Folgate Street, London, England, E1 6GL and with ICO registration number ZA495485 is the controller and is responsible for your personal data (collectively referred to as 3SMC, we, us or our in this privacy policy).

We personally oversee all questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: 3S Money Club Limited

Email address: [email protected]

Postal address: 45 Folgate Street, London, England, E1 6GL

Telephone number: +44 2038079645

 
 
Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 20/07/2021.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

What information do we collect from you?

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth, residential address, citizenship.

Company Data includes business registered name, registration number, registered address, country of incorporation, sector in which the business operates as well as:

• information about products and services the business offers, target customers and remuneration structure of the firm (this may include a funds flow chart);
• background information about when the business was founded and how it has been developed;
• information on the identity and suitability of directors and owners (and UBOs), including proofs of ID and results of PEPS and Sanctions Screening;
• information on whether the business is a part of a Group;
• the shareholding structure of the business;
• management structure of the business;
• product distribution and client acquisition channels used by the business (e.g. web-site);
• standard customer contract used in regular course of business;
• information on business’ involvement in high risk industries (e.g. gambling);
• your position within the business (business which is opening an account with us);
• your or the relevant business’ relationship with relevant introducer.

 
 
Background check data includes information about criminal convictions and offences, KYC background checks on your company, any associated counterparties and any individuals associated with the company.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes purpose of use of the account, inflows and outflows (transaction value, currencies, countries where the counterparties are based), transactional counterparties.

Transaction Data includes details about your incoming and outgoing payments, transactional counterparties, invoicing information pertaining to these transactions and exchange rate information.

Technical Data includes internet protocol (IP) address, address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system.

Profile Data includes your username/e-mail address and password, your mobile phone number to be used with DUO Security app, transactions made or received by you, your preferences, feedback and survey responses.

Usage Data includes the full Uniform Resource Locators (URL) clickstream to, through and from the Website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your communication preferences, communications you send to us (by telephone, email otherwise), for example, to report a problem or to submit queries, concerns or comments regarding the Website, our service, or general comments and information you provide when participating in Website discussion boards or social media functions – this may include personal data depending on the content of the information you provide.

We may receive information about you if you use any of the other websites we operate or the other services we provide.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, 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 a service you have with us but we will notify you if this is the case at the time.

How do we collect your data?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Company, Contact, Financial and Transactional Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our services;
• create an account on our website;
• subscribe to our service or publications;
• use our services;
• request marketing to be sent to you;
• give us feedback or contact us for any reason.

 
 
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

Third parties or publicity available sources. We are also working closely with third parties (including, service providers, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive and exchange information about you with them.

What we do with your data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with our legal and/or regulatory obligations.

View our glossary (below) to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 
 
Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at: 3S Money Club Limited, 45 Folgate Street, London, England, E1 6GL; by telephone on +44 2038079645; or by emailing [email protected]

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see 3S Money Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data
In order to deliver our services, your personal data may also be transferred to the following third parties:

• Internal Third Parties as set out in the Glossary below.
• External Third Parties as set out in the Glossary below. 
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Internal transfers
We take the security of your data very seriously, and all of your personal data will be kept according to strict safeguards and in compliance with the UK-GDPR and EU-GDPR. We share your personal data within the 3S Money Club Limited Group. Your data will be stored on cloud servers within the EEA and we will only store your data outside the EEA in the event that the jurisdiction in question has been assessed as compliant with the GDPR.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will we keep your data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a period of 5 years after you cease being customers for tax and regulatory purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• To be informed.
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data. 
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

 
 
Your legal rights

You have the right to:

Be informed about what personal data we hold and how we are using it. This information is contained within this privacy notice.

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You can do so, by making a ‘subject access request’ to us in writing.

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.

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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.

Object to processing of your personal data 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 may always object to further use of your data for direct marketing purposes by clicking the “unsubscribe” button within marketing emails or by contacting us by writing to us at [email protected] In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

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:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want to erase it.
• 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.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

 
 
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format free of charge and on request. 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.

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. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us 3S Money Club Limited, 45 Folgate Street, London, England, E1 6GL; by telephone on +44 2038079645; or by emailing [email protected].

Should you be dissatisfied with our response or wish to complain to the relevant supervisory authority, you can do so by contacting the Information Commissioner’s Office (ICO). Contact details for the ICO can be found on this webpage.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

Lawful Basis

Under Article 6 of the EU General Data Protection Regulation (GDPR) we are required to tell you about the legal basis under which we collect and process your data.

We will only collect and process your personal data in accordance with one of the below lawful basis:

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Our legitimate interests include:

Improving our service

Providing you with marketing information about our services

Providing you with customer support and administering your account

Providing you with information about related products and services offered by 3SMC

Providing you with information about related products and services offered by our commercial partners

 
Performance of Contract means processing your data where it is necessary for the performance of a contract we have with you or to take steps at your request before entering into a contract, such as providing you with a quote.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to, such as in response to a request by law enforcement or when investigating a civil claim.

Consent means processing your personal data where you have been given the option to explicitly consent to share your data with selected third parties for marketing purposes or to sign up for related products and services, and you have chosen to consent. This will be via a separate notice via 3s.money. We will never assume that we have your consent unless you have explicitly opted in, and you can withdraw your consent at any time by contacting us.

Third Parties

Internal Third Parties

Other companies in the 3S Money Club Group act as joint controllers or processors and are based in Latvia, Netherlands, Luxembourg and the United Arab Emirates and provide communication, compliance, IT and system administration services and undertake analytics and reporting.

External Third Parties

Service providers acting as processors based in the United Kingdom or the European Union provide IT, system administration, identification and two-factor authentication services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom, the European Union and the United Arab Emirates who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom, the European Union and the United Arab Emirates who require reporting of processing activities in certain circumstances.

Third-party credit reference agencies, in circumstances where we may need to assess your creditworthiness.

KYC-AML partners (such as LexisNexis Risk Solutions UK Limited) to facilitate your onboarding as a client.

Our banking partners (such as Raiffeisen International AG) provide you with the necessary services.

Version 0.3.0

1. About Us

1.1. Purpose of this privacy policy

2. What information do we collect from you?

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth, residential address, citizenship.

• Company Data includes business registered name, registration number, registered address, country of incorporation, sector in which the business operates as well as:

  • information about products and services the business offers, target customers and remuneration structure of the firm (this may include a funds flow chart);

  • background information about when the business was founded and how it has been developed;

  • information on the identity and suitability of directors and owners (and UBOs), including proofs of ID and results of PEPS and Sanctions Screening;

  • information on whether the business is a part of a Group;

  • the shareholding structure of the business;

  • management structure of the business

  • product distribution and client acquisition channels used by the business (e.g. web-site);

  • standard customer contract used in regular course of business

  • information on business’ involvement in high risk industries (e.g. gambling)

  • your position within the business (business which is opening an account with us);

  • your or the relevant business’ relationship with relevant introducer.

• Background check data includes information about criminal convictions and offences, KYC background checks on your company, any associated counterparties and any individuals associated with the company.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Financial Data includes purpose of use of the account, inflows and outflows (transaction value, currencies, countries where the counterparties are based), transactional counterparties.

• Transaction Data includes details about your incoming and outgoing payments, transactional counterparties, invoicing information pertaining to these transactions and exchange rate information.

• Technical Data includes internet protocol (IP) address, address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system;

• Profile Data includes your username/e-mail address and password, your mobile phone number to be used with DUO Security app, transactions made or received by you, your preferences, feedback and survey responses. 

• Usage Data includes the full Uniform Resource Locators (URL) clickstream to, through and from the Website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number;

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your communication preferences, communications you send to us (by telephone, email otherwise), for example, to report a problem or to submit queries, concerns or comments regarding the Website, our service, or general comments and information you provide when participating in Website discussion boards or social media functions – this may include personal data depending on the content of the information you provide.

3. How do we collect your data?

• Direct interactions. You may give us your Identity, Company, Contact, Financial and Transactional Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our services;
  • create an account on our website;
  • subscribe to our service or publications;
  • use our services;
  • request marketing to be sent to you;
  • give us feedback or contact us for any reason.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We are also working closely with third parties (including, service providers, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive and exchange information about you with them.

4. What we do with your data?

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with our legal and/or regulatory obligations.

5. Purposes for which we will use your personal data

6. Opting out

7. Cookies

8. Change of purpose

9. Disclosures of your personal data

10. International transfers

11. Data security

12. How long we will keep your data for?

13. Your legal rights

• Be informed about what personal data we hold and how we are using it. This information is contained within this privacy notice.
• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You can do so, by making a ‘subject access request’ to us in writing.
• 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.
• 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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.
• Object to processing of your personal data 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 may always object to further use of your data for direct marketing purposes by clicking the “unsubscribe” button within marketing emails or by contacting us by writing to us at [email protected] In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• 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:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format free of charge and on request. 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.
  • 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. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

14. Glossary

• Service providers acting as processors based in United Kingdom or the European Union who provide IT, system administration, identification and two-factor authentication services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom, the European Union and United Arab Emirates who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom, the European Union and United Arab Emirates who require reporting of processing activities in certain circumstances.
• Third-party credit reference agencies, in circumstances where we may need to assess your creditworthiness.
• KYC-AML partners (such as LexisNexis Risk Solutions UK Limited) to facilitate your onboarding as a client.
• Our banking partners to provide you with necessary services.
• FX brokers (such as Monex Europe Ltd and Monex Europe Markets Limited) to provide you with forex services

Version: 1.0