# Goldfortx Privacy Notice

Last updated on 21/02/2023

Goldfortx is a UK-based fintech start-up, a digital payments platform for international trade merchants.
We provide SMEs participating in trade worldwide with online banking solutions built for their needs: support for large international transfers, better FX rates, global business accounts, and local EU/UK bank details.
Our AI-powered KYC technology allows us to quickly and safely onboard SMEs and make them bankable in Europe and beyond.
We work with banks, regulators, payment networks, and trade finance companies so businesses who bank with Goldfortx don’t have to. Our aim is to eliminate the hurdles in international payments and unlock the true growth potential of global trade.

## ❓What is this notice all about?

We want to be completely transparent about how we collect and use your personal data and this privacy notice exists to tell you exactly how we do this.
This notice applies wherever we decide why and how we process personal data (and therefore act as a Data Controller under data protection law). It covers the personal data we process when you use our services.
Our privacy notice tells you the journey of your personal data from the moment it enters our systems up until you decide to leave us, as well as the various stops it makes along the way.

## 👇 The different ways we process personal data

When you join Goldfortx as a customer

##### 🗂️ What personal data do we collect, why do we collect it, and what legal basis do we rely on?

Personal data is anything that can identify an individual, either on its own or through combining it with other factors that could eventually identify an individual.

When you apply to join Goldfortx, we'll need some information about you, such as your name, email address, phone number, company name, country, payment data, universally unique identifier (UUID), ZIP/Postal code, device information, username/user ID and we rely on Article 6(1)(b) of the GDPR - Contractual Obligation for this processing.
We will also collect a dynamic selfie as well as information gathered during our KYC and AML checks and we rely on Article 6(1)(c) of the GDPR - Legal Obligation for this processing.
If you are a shareholder or a director, we will need additional information from you, such as your name, date of birth, company ownership percentage, home address, ID documents (passport details, ID card, residential permit, drivers licence), proof of this information and copies. We will rely on Article 6(1)(b) of the GDPR - Contractual Obligation and Article 6(1)(c) of the GDPR - Legal Obligation for this processing.
If you first contact us via our our website forms, we will collect your name, email, personal number, country of residence, country of registration.
We record all our sales and customer calls in order to comply with our contractual obligation with Currency Cloud, our banking partner and EMI licence provider. We will rely on Article 6(1)(f) of the GDPR - Legitimate Interest for this processing.

##### 🗺️ Where do we store it?

During the sales process we will store your personal and contact details on our sales management system.
We will need to conduct Know-Your-Customer (KYC) and Anti-Money Laundering (AML) checks before we onboard you as a customer and these will be conducted by various systems in use by Goldfortx. The results of these checks will be hosted on Theropod Admin Panel, our proprietary software.
We will also need to conduct money-laundering due diligence searches databases of Companies House info. The results of this data will be then migrated to Theropod Admin Pannel. We will also conduct Google searches about your company, including social media profiles, for due diligence purposes. We also have an alternative service, Openbankaccount.org, which we may refer you to in case there are additional due diligence checks required.
Once we have onboarded you as a customer, all personal data on our platform will be stored on Theropod Admin Panel. We are conducting a process internally to migrate all our data on our in-house servers and we will update this privacy notice once this has been completed. There are also, other systems and tools that we use to provide our service to you.
Once onboarded, we will need to share transaction data with banking interfaces, in order to manage your transactions.
We use banking partners, which provide our EMI licence. These will have access to your names and bank account details.
The forms on our website that you can use to contact us are created via an online form building software. The information collected is then migrated into our built-in CRM.
We also have data warehouses, primarily for document storage, which can access personal details, contact details and financial data.
We use knowledge-bases and task trackers to manage our services. We don’t aim to store personal data on these systems, but occasionally we may have a user ID or other identifier in one of our tasks documented in there.
We use different data processors and suppliers to manage our services. If you are currently a user of Goldfortx and would like a complete list of where your data resides, please get in touch using the contact details below.
International Transfers
We aim to keep all personal data in the UK or EU, but some of our suppliers may have data centres outside of the EU, including the US. We will only transfer data outside of the UK/EEA pursuant to a specific legal basis and with additional safeguards required by data protection regulations. The additional safeguards we will use will be EU-adopted Standard Contractual Clauses (SCCs), complemented by the UK Addendum to the SCCs if the data is being sent from our UK entity.
Otherwise, we will only transfer personal data from the EU to third countries only if at least one of the following conditions is met:
‍
• the transfer is necessary for the performance of a contract between Goldfortx and yourself or to comply with pre-contractual measures taken at your request;
• the transfer is necessary for important reasons of public interest;
• the transfer is necessary for establishment, exercise or defence of legal claims;

##### ⏲️ How long do we keep it for?

During the negotiations stages, we will only collect and retain your information for the duration of the process; if you are not onboarded as a customer, we will remove your information within 6 months.
Once you are a customer, we keep your personal information for 6 years after our contractual relationship has ended, in line with statutory retention periods for contractual claims.
We will keep your KYC and AML checks results for at least 5 years from the end of the relationship or last transaction, in line with the required statutory retention periods.

While you are using Goldfortx

##### 🗂️ What personal data do we collect, why do we collect it, and what legal basis do we rely on?

Personal data is anything that can identify an individual, either on its own or through combining it with other factors that could eventually identify an individual.

While you are using the platform, we may collect analytics in order to improve our services; this will not include financial details, but may include an electronic identifiers. We will rely on Article 6(1)(f) of the GDPR - Legitimate Interest for this processing.
We may send you marketing communications in order to make you aware of new products or features available on our platform, to let you know about offers that may be of interest to you or to find out whether Goldfortx may be a good option for your business. For this, we'll need some information about you, such as your name, work phone number, company name, country, work email address. We will rely on Article 6(1)(b) of the GDPR - Legitimate Interest when collecting this data but you will have the option to unsubscribe in our communications.
If you encounter any issues with the platform and need to get in touch for troubleshooting purposes, we will collect your name, email address and user ID to be able to look into the issue and rely on Article 6(1)(b) of the GDPR - Legitimate Interest when doing so.
We will also collect data for user database management. This type of service allows us to track user activities through analytics features and will collect your user ID and activity through the app. We will rely on Article 6(1)(b) of the GDPR - Legitimate Interest for this processing.

##### 🗺️ Where do we store it?

All personal data on our platform will be stored on Theropod Admin Panel, our proprietary software, but there are other systems and tools that we use to provide our service to you.
We use different data processors and suppliers to manage our services, including in order to communicate with you, for customer support and troubleshooting and for user database management. If you are currently a user of Goldfortx and would like a complete list of where your data resides, please get in touch using the contact details below.
International Transfers
We aim to keep all personal data in the UK or EU, but some of our suppliers may have data centres outside of the EU, including the US. We will only transfer data outside of the UK/EEA pursuant to a specific legal basis and with additional safeguards required by data protection regulations. The additional safeguards we will use will be EU-adopted Standard Contractual Clauses (SCCs), complemented by the UK Addendum to the SCCs if the data is being sent from our UK entity.
Otherwise, we will only transfer personal data from the EU to third countries only if at least one of the following conditions is met:
‍
• the transfer is necessary for the performance of a contract between Goldfortx and yourself or to comply with pre-contractual measures taken at your request;
• the transfer is necessary for important reasons of public interest;
• the transfer is necessary for establishment, exercise or defence of legal claims;

##### ⏲️ How long do we keep it for?

We will keep marketing details for the duration of your account with us and only send you marketing materials unless you have unsubscribed. When you unsubscribe, we will need to retain your email address on a no-marketing list, but we will not be using it for any other purposes.
When you send a ticket to our ticketing system, we will retain information about the ticket until the problem is fixed and for 6 months afterwards, in line with our business needs.

When we onboard you as a service provider

##### 🗂️ What personal data do we collect, why do we collect it, and what legal basis do we rely on?

Personal data is anything that can identify an individual, either on its own or through combining it with other factors that could eventually identify an individual.

When we onboard you as a service provider we'll need some information about you, such as a primary contact name, work phone number, company name, country, work email address and amounts needed. We will rely on Article 6(1)(b) of the GDPR - Contractual obligation when collecting this data.

##### 🗺️ Where do we store it?

Contact detail are hosted in our CRM system. Invoices are sent over email and are also shared with our payment processing provider.
International Transfers
We aim to keep all personal data in the UK or EU, but some of our suppliers may have data centres outside of the EU, including the US. We will only transfer data outside of the UK/EEA pursuant to a specific legal basis and with additional safeguards required by data protection regulations. The additional safeguards we will use will be EU-adopted Standard Contractual Clauses (SCCs), complemented by the UK Addendum to the SCCs if the data is being sent from our UK entity.
Otherwise, we will only transfer personal data from the EU to third countries only if at least one of the following conditions is met:
‍
• the transfer is necessary for the performance of a contract between Goldfortx and yourself or to comply with pre-contractual measures taken at your request;
• the transfer is necessary for important reasons of public interest;
• the transfer is necessary for establishment, exercise or defence of legal claims;

##### ⏲️ How long do we keep it for?

We keep the personal data mentioned for the duration of your account with us and for 6 months after our commercial relationship has ended, in line with statutory retention periods for contractual claims.

When you visit our website

Our website uses cookies and other similar technologies of which you should be aware.

##### 🗂️ What cookies do we collect, why do we collect them, and what legal basis do we rely on?

Cookies are text files placed on your hard drive by a web page server when you visit a website and are saved in your browser's history. They allow the website to recognise your device and store some information about your preferences or past actions. Cookies cannot be used to run programs or deliver viruses to your computer; they are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie.

When you use our website, the cookies can be stored on your device are either first party cookies, which are placed and read by us directly while you are using our website or third party cookies, which are set by other third parties we have partnered with.
Below is a list of the cookies we use and the purposes for which they are used:

Essential cookies – These are essential to the operation of our website and are integral to the functioning of our Website, therefore they cannot be removed.

Non-essential cookies – These cookies are additional to the the performance of our Website and help us improve the service we provide to you.

For information about our use of essential and non-essential cookies, please visit our cookies policy.
You can choose not to store Non-essential cookies on your computer when you visit our website, or you can adjust your browser settings to prevent cookies from being saved on your computer. You can find information about how to manage Cookies in the most commonly used browsers at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari, Microsoft Internet Explorer, Microsoft Edge, Brave, Opera.

## 📜 What are your rights?

Your personal data is yours and you have rights in relation to it granted by the UK GDPR, which include:

📮 The right to be informed

You have the right to be informed about the collection and use of your personal data, the purposes for processing, retention periods for that personal data and who it will be shared with. We have set this information out in this privacy notice.

🗝️ The right of access

You have the right to ask us for copies of the data we hold about you. If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details).

⛔ The right to object

You have the right to ask us to stop processing your personal information in some circumstances, such as when we are relying on our own (or someone else’s) legitimate interests to process your personal information, when we are processing your personal information for direct marketing or when we are processing your personal information for research.

📝 The right to rectification

You have the right to ask us to rectify the personal information you think is inaccurate or to complete information you think is incomplete. When you ask us to rectify your information, if we’ve shared your personal information with others, we’ll let them know about the rectification where possible.

🧽 The right to erasure

You have the right to ask us to erase your personal information, in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable).

🚫 The right to restrict processing

You have the right to ask us to restrict the processing of your personal information for a period of time in some circumstances, such as where you contest the accuracy of that personal information or object to us processing it. This right is separate from the right to object and will only stop us from using your personal information further, not from processing it. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible.

✈️ The right to data portability

You have the right to ask that we transfer the personal information you gave us to another organisation, or to someone else, in some circumstances.

You don't have to pay anything in order to exercise your rights. Please contact us by sending an email to hello@Goldfortx.com if you wish to make a request under your rights; we have a calendar month to get back to you with a response.

## 💔 How you can complain

If you have any concerns about our use of your personal information, please let us know by:

Emailing us at hello@Goldfortx.com, or

Writing to us at Goldfortx Global Limited, 1 Kings Avenue, London, United Kingdom, N21 3NA

If you are not satisfied with our response or you are unhappy with how we have used your data, you can complain to the Information Commissioner's Office (ICO). You can find the ICO contact details below:

ICO Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, Helpline number: 0303 123 1113.

ICO Website: www.ico.org.uk

### Contact details

Email: hello@Goldfortx.com‍

‍‍Address:
‍Goldfortx Global Limited,
1 Kings Avenue,
London,
United Kingdom,
N21 3NA

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