This Privacy Policy is designed to ensure that we handle your personal data safely and in accordance with the relevant regulations and laws in the United Kingdom, Singapore, and Canada. These regulations explain what data we may collect from you, the legal basis for doing so, how we will use that data, your rights as a data subject, how you can limit the processing of your information, and how you can decide whether or not to receive direct marketing communications.
This Privacy Policy applies when we act as either a data controller or a data processor for the personal data of our website visitors and service users. This means we can determine the purposes and methods for processing your personal data. By using our website and agreeing to this Policy, you consent to our use of cookies as outlined in the terms of this Policy.
By continuing to interact with us—such as by submitting information or using our services—you confirm that you understand and consent to the collection, use, disclosure, and processing of your personal data (or the personal data of any individual you provide) as described in this Privacy Policy.
This Section outlines:
1.1 We may process data about your use of our website and services (“usage data”). The usage data may include the internet protocol (IP) address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your website or service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is either your specific consent or, where we are not legally required to ask for consent, we may process this data for our legitimate interests, namely monitoring and improving our website and services.
1.2 We may process your account data (“account data”). The account data may include your name, email address, contact phone number and postal address. We may ask for ID verification in order to register for an account with us. These proof of identity and proof of address documents will be used alongside an anti-money laundering (AML) check in order to comply with our legal obligations. Account data may also be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is either your specific consent or, where we are not legally required to ask for consent, we may process this data for our legitimate interests, namely monitoring and improving our website and services.
1.3 We may process personal data provided while using our services (“service data”). The service data may include details of your payment transactions, such as your payments with us, beneficiary details and locations, financial account information, and documents that you’ve provided to support the payment, such as invoices, proof of sale documents and bank statements. The service data may be processed for the purposes of providing our services and ensuring the security of transactions, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is either your specific consent or a necessary prerequisite to providing the services you require or a legal requirement.
1.4 We may process information contained in any enquiry you submit to us regarding our services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is either your specific consent or, where we are not legally required to ask for consent, we may process this data for our legitimate interests, namely monitoring and improving our website and services.
1.5 You agree and consent to the electronic recording of telephone conversations with or without an automatic tone warning device and that we may use such recordings or transcripts from such recordings as evidence in any dispute or anticipated dispute between the parties or relating to dealings between the parties. This is in line with our legal obligations to keep records. We may destroy any such recordings or transcripts made by us in accordance with our normal practices or as otherwise set out in these terms.
1.6 We may process any of your personal data identified in this Policy where necessary for administrative purposes, including in the exercise or defence of legal claims. The legal basis for this processing is our legitimate interests, namely for administrative record keeping, processing transactions and maintaining business records or for the protection and assertion of our legal rights.
1.7 If you supply any other person’s personal data to us, you must do so only if you have the authority of such person to do so, and you must comply with any obligations imposed upon you under the Data Protection Regulations.
2.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our holding company and its subsidiaries) insofar as reasonably necessary for the purposes and on the legal basis set out in this Policy.
2.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary to obtain or maintain insurance coverage, manage risks, obtain professional advice, or exercise or defend legal claims.
2.3 We may pass your personal information to credit reference agencies or other agencies that provide services to verify your identity or for any other checks or searches required by legislation or our regulators relating to money laundering. These agencies may keep a record of any search that they do.
2.4 We may disclose your personal data to business partners, suppliers and sub-contractors for the performance and execution of any contract we enter into with them or you and to help them improve the services they provide to us;
2.5 We may disclose your personal data to advertisers and advertising networks to select and serve relevant adverts to you and others;
2.6 We may disclose your personal data to analytics and search engine providers that assist us in the improvement and optimisation of our site;
2.7 We may outsource or contract the provision of IT services to third parties. If we do, those third parties may hold and process your personal data. In these circumstances, we will require that the IT supplier only processes your personal data for us, as directed by us, and in accordance with the Data Protection Regulations.
2.8 If we sell all or part of our business, we may pass your personal data to the purchaser. In these circumstances, we will require the purchaser to contact you after the sale is completed to inform you of the purchaser’s identity.
2.9 We share transaction data with our payment service providers as needed to process your payments, issue refunds, and address complaints or queries related to these transactions.
2.10 In addition to the specific disclosures of personal data outlined in this Section, we may also disclose your personal data when necessary to comply with a legal obligation or to protect your legal rights or the legal rights of another individual.
This Section provides information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
3.1 We may need to supply some of your personal data to third parties to whom you wish to receive a currency transfer, such as their bank or an intermediary payment service provider, in order to complete the payment. If their bank is outside the European Economic Area, then this may include transferring personal data to a country outside the European Economic Area.
3.2 You acknowledge that personal data you submit for publication through our website or services may be available worldwide. We cannot prevent the use (or misuse) of such personal data by others.
3.3 For further details on international data transfers or the safeguards we use, please contact us at privacy@clearing.com
This Section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations regarding the retention and deletion of personal data.
4.1 We will retain your personal data only for as long as is necessary to fulfil the purposes for which we collected it. This means that unless we are legally obliged to do so or there is a good reason for us to believe it may be needed for legal proceedings, we won’t keep your personal data for more than 10 years after our business relationship has ended. We will, however, keep your data for a minimum of 5 years in line with our statutory record-keeping obligation.
4.2 While we cannot specify in advance the exact duration for which your personal data will be retained, we will determine the retention period based on your ongoing use of our website or services and our requirements for proper record-keeping, accounting, and legal purposes.
4.3 We will always delete data that is no longer required by the relevant laws or jurisdictions in which we operate.
4.4 We may keep your personal data if it is necessary to comply with a legal obligation or protect your legal rights or those of another person.
We may update this Policy occasionally by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this Policy. We may notify you of changes to this Policy by email or through the private messaging system on our website.
This Section summarises the rights that you have under data protection law. Laws in your jurisdiction may give you specific rights regarding the information we hold about you. If you have questions about our use of your personal information, please contact us at privacy@clearing.com.
6.1 Your principal rights under data protection regulations are:
6.2 You have the right to confirm whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned, and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply you with a copy of your personal data.
6.3 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
6.4 In certain circumstances and countries, you have the right to have your personal data erased without undue delay. These circumstances include the following:
However, there are some exclusions to the right of erasure. Generally, processing is necessary for:
6.5 You have the right to restrict the processing of your personal data under certain circumstances. These circumstances include when:
If processing is restricted in these cases, we may still store your personal data. However, we will only process it further if:
6.6 You have the right to object to our processing of your personal data based on specific circumstances related to your situation. This right applies only if the legal basis for processing is that it is necessary for the performance of a task carried out in the public interest or in the exercise of any official authority vested in us, or for the legitimate interests pursued by us or a third party.
6.7 If you choose to make such an objection, we will stop processing your personal information unless we can demonstrate compelling, legitimate grounds for continuing the processing that overrides your interests, rights, and freedoms. This also applies if the processing is necessary to establish, exercise, or defend legal claims.
6.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
6.9 You have the right to object to our processing of your personal data for scientific, historical, or statistical research purposes based on your specific situation unless the processing is necessary for the performance of a task carried out in the public interest.
6.10 Additionally, if the legal basis for processing your personal data is consent, or if it is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract, you have certain rights.
6.11 If the processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used, and machine-readable format. However, this right does not apply if exercising it would adversely affect the rights and freedoms of others.
6.12 If you believe that our handling of your personal information violates data protection laws, you have the legal right to file a complaint with the supervisory authority responsible for data protection outlined below:
| Country or Region | Entity | Registered Office and Details | Data Protection Authority |
|---|---|---|---|
| Canada | Everpay Canada Inc | Everpay Canada Inc Registered in Alberta 795219153 | Registered Office Suite 3810, Bankers Hall West, 888 3rd Street SW, Calgary AB T2P 5C | Registered with FINTRAC M23890418 | Office of the Privacy Commission of Canada (OPC) (www.priv.gc.ca/en/) |
| Singapore | WTSG Pte Ltd | WTSG PTE. LTD., #12-01 Hub Synergy Point, 70 Anson Road, Singapore, 079905 Registered in Singapore No. 201429584Z | Licensed by the Monetary Authority of Singapore under the Money-changing and Remittance Businesses Act. | Personal Data Protection Commission (PDPC) (www.pdpc.gov.sg/) |
| UK | WTUK Limited | WTUK Limited is registered in England and Wales under registration number 08261731, and our registered office is at The Landmark, Tudor Square, West Bridgford, Nottingham, England, NG2 6BT |WTUK Limited is authorised by the Financial Conduct Authority under the Electronic Money Regulations 2011, Reference number 900536, for the issuing of electronic money | Information Commissioner’s Office (ICO) (www.ico.org.uk) |
6.13 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.14 You can request access to any personal information we hold about you. Please note that obtaining this information will require proof of your identity. We typically accept a certified photocopy of your passport, certified by a solicitor or bank, along with an original utility bill that shows your current address.
6.15 We will impose a reasonable fee when permitted by local laws or if your request is clearly unreasonable, repetitive, or excessive. In these situations, we may also refuse to fulfil your request.
A cookie is a small file containing an identifier, a string of letters and numbers. This file is sent by a web server to a web browser, asking for permission to be placed on your computer’s hard drive. Once added, the cookie helps analyse web traffic and notifies you when you visit a specific site. Cookies enable web applications to respond to you as an individual, allowing them to tailor their operations based on your needs, preferences, and dislikes by gathering and remembering information about you.
There are two types of cookies: “persistent” cookies and “session” cookies. A persistent cookie is stored by the web browser and remains valid until its set expiration date unless the user deletes it before that time. In contrast, a session cookie expires at the end of the user session, which typically occurs when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
7.1 Cookies that we use
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our services in order to tailor them to customer needs. We only use this information for statistical analysis purposes, and then the data is removed from the system.
Overall, cookies help us provide a better experience by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. This may prevent you from taking full advantage of our services.
We may use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use through cookies. The information gathered relates to our website and is used to create reports about its use. Google’s privacy policy can be found at the following web address: https://www.google.com/policies/privacy/.
We may provide links to the websites of our partner networks, advertisers, and affiliates. Please be aware that these websites have their privacy policies, and we cannot take responsibility for them. Therefore, if you follow a link, we encourage you to review these policies before submitting any personal information to those websites.
If you have any questions, comments or requests about this Policy, don’t hesitate to contact our privacy team at privacy@clearing.com, where you can also contact our Data Protection Officer. You can also write to us or our Data Protection Officer at our registered office that applies to you, as listed below:
WTUK Limited Trading as Clearing
Registered Office: The Landmark, Tudor Square, West Bridgford, Nottingham, England, NG2 6BT.
Registered in England No. 08261731.
WTUK Limited is authorised by the Financial Conduct Authority under the Electronic Money Regulations 2011 (Reference number 900536) for the issuing of electronic money.
WTSG PTE. LTD. trading as Clearing
Licensed by the Monetary Authority of Singapore (MAS) as a Major Payments Institution under the Payment Services Act 2019 and the Payment Services Regulations 2019 (License No. PS20200445).
Elevate North America Inc
Registered Number 4959243.
Registered Office: 228 E 45TH ST, STE 9E, New York, NY 10017.
Everpay Canada Inc. Trading as Clearing
Registered Office: Suite 3810, Bankers Hall West, 888 3rd Street SW, Calgary AB T2P 5C.
Everpay Canada Inc. is a money services business registered with FINTRAC in Canada (Registration number M23890418).