The following is the privacy notice statement (“Privacy Notice”) of NIUM Pte. Ltd. which is the holding company of NIUM and InstaReM subsidiaries globally (formerly known as InstaReM Pte. Limited) (collectively, “NIUM”, “we”, “our”, “us”) and sets forth our policies & practices in connection with personal data that we collect through our website, and any mobile sites, applications, or other mobile interactive features (collectively, the “Platform”).
Our notice is to comply and ensure that our employees comply with the requirements of the Singapore Personal Data Protection Act (2012) (“PDPA”) and any other relevant privacy laws like The General Data Protection Regulation (EU) 2016/679 (GDPR) in the locations in which we operate.
In order to use the services provided on our Platform, you will have to share your personal data with us.
Please use the following link https://www.nium.com/privacy-notice/
Definitions and interpretation
Collectively all information that you submit to Orenda Financial Services Limited via the Website. This definition incorporates, where applicable, the definitions provided in the
Data Protection Laws;
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;
Orenda Financial Services Limited, a company incorporated in the England and wales with registered number 12404984 we or us Orenda Financial Solutions Limited, a company incorporated in England and Wales with registered number 12500737 whose registered office is at 9 Brenton Business Complex, Bury, Bury, BL97BE;
User or you any third party that accesses the Website and is not either (i) employed by Orenda Financial Solutions Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Orenda Financial Solutions Limited and accessing the Website in connection with the provision of such services; and
Website the website that you are currently using, www.orenda.finance, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
the singular includes the plural and vice versa;
a reference to a person includes firms, companies, government entities, trusts and partnerships;
“including” is understood to mean “including without limitation”;
reference to any statutory provision includes any modification or amendment of it;
For purposes of the applicable Data Protection Laws, Orenda Financial Solutions Limited is the “data controller”. This means that Orenda Financial Solutions Limited determines the purposes for which, and the manner in which, your Data is processed.
We may collect the following Data, which includes personal Data, from you:
date of birth;
contact Information such as email addresses and telephone numbers;
financial information such as credit / debit card numbers;
IP address (automatically collected);
operating system (automatically collected);
How we collect Data
Orenda Financial Services Limited will collect your Data in a number of ways, for example:
when you contact us through the Website, by telephone, post, e-mail or through any other means;
when you register with us and set up an account to receive our products/services;
Data that is collected automatically
To the extent that you access the Website, we will collect your Data automatically, for example:
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.
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:
Products and services; in each case,
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).
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:
any of our group companies or affiliates – To credit check before approval;
third party service providers who provide services to us which require the processing of personal data – To ensue that AML requirements are met;
relevant authorities – If the authorities request this information we w ill need to provide this by law;
Keeping Data secure
We will use technical and organisational measures to safeguard your Data, for example:
access to your account is controlled by a password and a user name that is unique to you.
we store your Data on secure servers.
payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology.
Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: email@example.com.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
You have the following rights in relation to your Data:
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.
Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
Right to erase – the right to request that we delete or remove your Data from our systems.
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.
Right to data portability – the right to request that we move, copy or transfer your Data.
Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: info@orenda. finance.
If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Links to other websites
Changes of business ownership and control
We may also disclose Data to a prospective purchaser of our business or any part of it.
In the above instances, we will take steps with the aim of ensuring your privacy is protected.
Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
You may contact Orenda Financial Solutions Limited by email at firstname.lastname@example.org.
Prepaid Financial Services – Privacy and You
Who are we?
Prepaid Financial Services (PFS) is a fast-growing technology company and e-money payments institution with offices in the UK, Malta and Ireland. PFS is authorised and regulated by the Financial Conduct Authority in the UK, as an electronic money institution, under reference number 900036. We provide own label and white label e-money financial solutions, including e-wallets, prepaid cards, and current accounts. PFS provides complete end to end solutions for clients by designing, developing, implementing, and managing these programmes.
It is important that you know exactly what we do with the personal information you and others make available to us, why we collect it and what it means for you. This document outlines the PFS approach to Data Privacy to fulfil our obligations under the EU General Data Protection Regulation (GDPR) 2018 of 25th May 2018. We also welcome it as an opportunity to reassure you of the importance we place on keeping your personal data secure, and of the strict guidelines we apply to its use.
The personal data we would like to collect from you is:
→ First Name and Surname with title → Address
→ Date of birth → Gender
→ Email → Bank Account details
→ Proof of address documents → Telephone number
→ ID Documents → Transactional information
→ Other personal information such as telephone recordings; security questions, user ID
→ CCTV footage where you visit our offices or branches
The personal data we collect will be used for the following purposes:
Providing prepaid card services to you as per our contractual obligations
Providing e-wallet services to you
Providing IBAN Account services to you
Processing your account information
To comply with our legal obligations for the prevention of fraud, money laundering, counter terrorist financing or misuse of services
Verifying your identity
Contacting you regarding our service to you
Where requested by law enforcement for investigation of crime
Our legal basis for processing the personal data:
receipt of your consent
performance of a contract where you are a party;
legal obligations that PFS is required to meet;
Any legitimate interests pursued by us, or third parties we use, are as follows:
the prevention of fraud, money laundering, counter terrorist financing or misuse of services
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified above. Consent is required for PFS to process personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
Consent for Children Under 16
If you are giving consent on behalf of a child under 16 then please be aware that Children need specific protection with regard to their personal data, as they may be less aware of the risks, consequences and safeguards concerned, and also of their rights in relation to the processing of personal data for the purposes of using these services. By consenting to this privacy notice on behalf of a minor you are giving permission for their data to be used for the purposes described above.
Withdrawal of Consent Conditions
You may withdraw consent from direct marketing at any time by contacting our Data Protection Officer. Please note, where you have consented to your data being used for carrying out financial transactions, then the right to withdraw consent does not exist. As a payment service provider, PFS is obliged to retain data concerning financial transactions for 6 years in accordance with national law for the purpose of preventing, detecting and investigating, by the FIU or by other competent authorities, possible money laundering or terrorist financing.
PFS will only pass on your personal data to third parties, including internationally, once we have obtained your consent. Some of our service providers, like payment processors, risk management solutions and suppliers are based outside of the EEA. Where we authorize the processing or transfer of your personal information outside of the EEA, we require your personal information to be protected to data protection standards and we ensure that there are adequate safeguards in place for data protection. The GDPR prohibits transfers of personal data outside the European Economic Area to a third country that does not have adequate data protection. Where transfer occurs outside the EEA the following mechanisms are in place with the third parties:
Data Protection clauses in our contracts and agreements with third-parties
EU-US Privacy Shield
Personal Information Protection and Electronic Documents Act (PIPEDA)
PFS will process personal data for the duration of the contract for services and will store the personal data for 6 years after that date of termination of the contract.
Your rights as a data subject.
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. Your data relating to financial transactions, accounts or cards cannot be deleted due to national law associated with the prevention of fraud, money laundering, counter terrorist financing or misuse of services for crime.
Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to another organisation.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
Right to judicial review, in the event that PFS refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.
All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data. You will find a copy of our Subject Access Request Form on our website.
In the event that you wish to make a complaint about how your personal data is being processed by PFS (or third
parties as above), or how your complaint has been handled, you have the right to lodge a complaint directly
with the supervisory authority and PFS’s Data Protection Officer by email to:
Fifth Floor, Langham House, 12 Little Portland Street, Marylebone, London, W1W 8BJ.
If you are unhappy with our response or if you need any advice you should contact the Information Commissioner’s Office (ICO).
Information Commissioner’s Office
Telephone: 0303 123 1113
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