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Privacy policy

LINHILL DESIGNATED ACTIVITY COMPANY (“LINHILL”, “we”, “us” or “our”) is committed to protecting and respecting your privacy.

This document refers to LINHILL DESIGNATED ACTIVITY COMPANY.

Last reviewed on 24 March 2024

1. Introduction

This Privacy Policy explains how we collect, use, store, disclose and protect your personal information when you use our website, communicate with us, register for our services or enter into transactions with us.

For the purposes of applicable data protection legislation, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Irish Data Protection Act 2018, LINHILL DESIGNATED ACTIVITY COMPANY acts as the data controller in respect of personal data collected through this website and in connection with our services.

LINHILL DESIGNATED ACTIVITY COMPANY is registered in Ireland under company number 277740.

Registered Office: Drumlogan Lodge, Ravensdale, Dundalk, Co. Louth, Ireland.

This Privacy Policy applies only to LINHILL and our services. It does not apply to third-party websites, applications or services that may be linked from our website. We are not responsible for the privacy practices, security or content of third-party websites.

2. Personal Information We Collect

When you register as a client, request information, communicate with us or use our services, we may collect personal information relating to you. This may include:

  • Full name;
  • Residential or business address;
  • Date of birth;
  • Email address;
  • Identification documents;
  • Proof of address;
  • Nationality;
  • Transaction information;
  • Payment and banking information;
  • Information regarding the source and purpose of funds;
  • Information required for identity verification and compliance purposes;
  • Communications between you and LINHILL;
  • Information regarding your use of our website;
  • Technical information including IP address, device information and browser information.

For corporate clients, we may also collect information relating to directors, shareholders, beneficial owners, authorised representatives and other persons associated with the business.

“Personal Data” or “Personal Information” means any information relating to an identified or identifiable individual.

You are responsible for ensuring that information provided to us is complete, accurate and up to date. You should notify us where any relevant information changes.

3. How We Use Your Personal Information

We may collect and process your personal information for the purposes of:

  • Providing foreign exchange and related services;
  • Opening, maintaining and administering your account;
  • Processing and recording transactions;
  • Confirming and carrying out your instructions;
  • Communicating with you regarding your account or transactions;
  • Verifying your identity;
  • Preventing fraud and financial crime;
  • Performing anti-money laundering and sanctions screening;
  • Assessing transaction and compliance risks;
  • Maintaining internal records;
  • Providing customer support;
  • Improving our website and services;
  • Meeting accounting, taxation, audit and regulatory requirements;
  • Establishing, exercising or defending legal claims;
  • Complying with applicable laws and lawful requests from competent authorities.

4. Lawful Bases for Processing

We will only process your personal information where we have an appropriate lawful basis to do so. Depending on the circumstances, this may include processing which is necessary:

  • For the performance of a contract with you;
  • To take steps at your request before entering into a contract;
  • To comply with a legal obligation;
  • For our legitimate business interests;
  • With your consent where consent is required.

5. Identity Verification and Regulatory Compliance

We may use your personal information to verify your identity and to comply with applicable legal and regulatory obligations, including anti-money laundering, counter-terrorist financing, sanctions and fraud prevention requirements.

As part of these procedures, we may request identification documents, proof of address, information regarding your occupation or business activities, source of funds, source of wealth or the purpose of particular transactions.

Where permitted or required by law, we may also perform checks using public records, electronic identity verification services, sanctions databases, fraud prevention databases or other third-party verification providers.

Failure to provide information required for compliance purposes may result in us being unable to establish or continue a business relationship or process a transaction.

6. Transaction Information

Once you become a client, we may retain information relating to transactions you enter into with us. This may include:

  • Transaction amounts;
  • Currency pairs;
  • Exchange rates;
  • Payment instructions;
  • Beneficiary information;
  • Transaction dates;
  • Transaction references;
  • Supporting documents;
  • Communications and instructions relating to a transaction.

Where necessary to carry out a transaction, relevant personal information may be disclosed to banks, payment service providers, counterparties, intermediaries or other organisations involved in processing the transaction.

We will only disclose information that is reasonably necessary for the relevant purpose.

7. Sharing Your Personal Information

We may share personal information with third parties where reasonably necessary for providing our services or complying with our legal obligations. These parties may include:

  • Banks and financial institutions;
  • Payment service providers;
  • Foreign exchange counterparties;
  • Identity verification providers;
  • Anti-money laundering and sanctions screening providers;
  • Technology and hosting providers;
  • Professional advisers;
  • Auditors;
  • Accountants;
  • Legal advisers;
  • Insurance providers;
  • Fraud prevention services;
  • Government agencies;
  • Courts;
  • Regulators;
  • Law enforcement authorities.

Where service providers process personal data on our behalf, we require them to process the information only in accordance with our instructions and applicable data protection requirements.

We do not sell your personal information to third parties.

We do not disclose your personal information to unrelated organisations for their own direct marketing purposes without an appropriate lawful basis.

8. Fraud Prevention and Legal Disclosure

We may disclose personal information where we reasonably believe that disclosure is necessary to:

  • Comply with applicable law;
  • Respond to a lawful request from a court, regulator or government authority;
  • Prevent or investigate fraud;
  • Prevent money laundering or other financial crime;
  • Protect the rights, property or security of LINHILL;
  • Protect our customers or other persons;
  • Enforce our Terms and Conditions;
  • Establish, exercise or defend legal claims.

Where permitted by law, information may also be shared with fraud prevention agencies and financial crime prevention services.

9. Website Usage Information

When you use our website, we may automatically collect certain technical information relating to your visit. This may include:

  • Internet Protocol (IP) address;
  • Browser type and version;
  • Device information;
  • Operating system;
  • Pages visited;
  • Date and time of visits;
  • Referring website;
  • Website interaction data.

We may use this information to:

  • Operate and maintain our website;
  • Monitor performance;
  • Improve website functionality;
  • Understand how visitors use our services;
  • Detect technical or security problems;
  • Prevent fraud or misuse.

Where possible, analytical information may be aggregated or anonymised.

10. Cookies

Our website may use cookies and similar technologies. Cookies are small text files placed on your device when you visit a website. Cookies may be used to:

  • Enable essential website functionality;
  • Remember preferences;
  • Improve website performance;
  • Analyse website traffic;
  • Understand how users interact with our website;
  • Support security and fraud prevention.

Some cookies are necessary for the website to function and may not require consent. Where required by law, non-essential cookies, including certain analytics or advertising cookies, will only be activated after you provide consent through our cookie management system. Disabling certain cookies may affect the functionality of the website.

11. Analytics

We may use analytics services, including services provided by third parties, to understand how visitors interact with our website. Analytics information may include information regarding:

  • Website visits;
  • Pages viewed;
  • Session duration;
  • Approximate geographical region;
  • Device type;
  • Browser type;
  • Referral source.

Where legally required, analytics technologies will only be used with your consent. Analytics data is used to help us understand website performance and improve the services provided to users.

12. Marketing Communications

Where permitted by applicable law, we may contact you regarding LINHILL products, services or information that we believe may be relevant to you.

Where consent is required, we will only send direct electronic marketing communications after obtaining your consent.

You may withdraw your consent or unsubscribe from marketing communications at any time.

Marketing preferences do not affect important administrative, transactional, legal or security communications relating to your account or services.

13. Communications Monitoring

Electronic communications with LINHILL may be monitored or recorded for purposes including:

  • Confirming instructions;
  • Training and quality assurance;
  • Fraud prevention;
  • Compliance monitoring;
  • Resolving disputes;
  • Maintaining evidence of transactions or communications.

Where permitted by law, recordings and transcripts may be retained and used as evidence in connection with an actual or anticipated dispute.

Electronic communications and network activity may also be monitored where reasonably necessary for security and regulatory purposes.

14. Information Security

We take reasonable technical and organisational measures to protect personal information against:

  • Unauthorised access;
  • Accidental loss;
  • Destruction;
  • Alteration;
  • Unauthorised disclosure;
  • Misuse.

Security measures may include encryption, access controls, authentication systems, network security and internal information security procedures.

However, no internet transmission or electronic storage system can be guaranteed to be completely secure.

You are responsible for maintaining the confidentiality of passwords and other authentication credentials associated with your account.

LINHILL will not normally request that you disclose your complete password by email.

Where necessary for security or identity verification purposes, we may ask you to answer verification questions or provide supporting information.

15. Retention of Personal Information

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected and to comply with legal, regulatory, accounting and reporting obligations. Retention periods may vary depending on:

  • The nature of the information;
  • The services provided;
  • Applicable anti-money laundering requirements;
  • Tax and accounting requirements;
  • Regulatory requirements;
  • Limitation periods for legal claims;
  • Whether disputes or investigations are ongoing.

Where information is no longer required, it will be securely deleted, anonymised or otherwise disposed of in accordance with our data retention procedures.

16. International Transfers

Due to the international nature of financial services and internet infrastructure, your personal information may in certain circumstances be transferred to, stored in or processed in countries outside the European Economic Area (“EEA”).

Where personal information is transferred outside the EEA, we will take appropriate measures required under applicable data protection law. These measures may include:

  • Transfers to countries recognised as providing an adequate level of protection;
  • European Commission Standard Contractual Clauses;
  • Other legally recognised transfer safeguards.

Where required, additional security measures may also be implemented.

17. Your Data Protection Rights

Subject to applicable law, you may have the right to:

  • Request access to your personal information;
  • Request correction of inaccurate or incomplete information;
  • Request deletion of your personal information;
  • Request restriction of processing;
  • Object to certain processing;
  • Request portability of certain personal information;
  • Withdraw consent where processing is based on consent;
  • Lodge a complaint with a supervisory authority.

These rights are not absolute and may be subject to legal or regulatory restrictions. For example, we may be required to retain certain personal information despite a deletion request where that information must be retained for anti-money laundering, tax, regulatory or legal purposes.

We may request proof of identity before responding to a data protection request.

18. Complaints

If you have concerns regarding the way your personal information is handled, you may contact LINHILL by email at [email protected] or in writing to our registered office.

You also have the right to lodge a complaint with the Irish Data Protection Commission.

  • Data Protection Commission, Ireland — website: www.dataprotection.ie

19. Corporate Transactions

If LINHILL, its business or substantially all of its assets are sold, transferred, reorganised, merged or integrated with another organisation, personal information may be disclosed to professional advisers, potential purchasers, investors or other parties involved in the transaction.

Where a transaction is completed, relevant personal information may be transferred to the new owner or successor organisation, subject to applicable data protection law.

20. Changes to This Privacy Policy

We may amend this Privacy Policy from time to time to reflect:

  • Changes to our services;
  • Changes in law or regulation;
  • Changes to our data processing practices;
  • Changes to technology;
  • Changes to our business operations.

Any updated version will be published on this website. Where changes are material, we may provide additional notice where appropriate.

Continued use of our services following publication of an updated Privacy Policy will be subject to the updated policy, subject to any consent requirements imposed by applicable law.

21. Data Controller

The data controller responsible for personal information processed under this Privacy Policy is:

LINHILL DESIGNATED ACTIVITY COMPANY

Irish Companies Registration Office Number: 277740

Registered Office: Drumlogan Lodge, Ravensdale, Dundalk, Co. Louth, Ireland.

22. Contact

If you have any questions regarding this Privacy Policy, the personal information we hold about you, or wish to exercise your data protection rights, please contact us.

Registered Office: Drumlogan Lodge, Ravensdale, Dundalk, Co. Louth, Ireland.

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