Privacy Policy
Last updated 20 May 2024
This privacy notice applies to Transfer World UK and its brand, transferworld, which may also operate under various trading names, including transferworld (collectively referred to as “transferworld,” “we,” or “our”).
This notice demonstrates our commitment to safeguarding your privacy rights and outlines the grounds on which any personal information we collect from you, or that you provide to us, will be processed. It applies to:
The features and services available to you when you visit our websites, portals, or payment panels used by our clients on their websites.
Your use of software, including terminals, mobile, and desktop applications provided by transferworld; as well as email, SMS, phone calls, web chat, websites/portals, and any other forms of communication between you and transferworld.
Please take a moment to carefully read the following to understand our approach to your personal data and how we will manage it.
Transferworld adopts a “layered approach” to explain its privacy practices, as recommended by regulators. This means we first provide you with key privacy information through this “short form” privacy notice. For a full overview, please refer to our Comprehensive Privacy Policy. Contact details for feedback or privacy-related inquiries can be found at the end of this notice.
Information that we may gather from you
You may provide us with information when you inquire about or apply for Transferworld Services, register for or use any of our services, complete forms on our websites, participate in our events, or communicate with us via phone, email, web chat, or other methods. We may also collect certain information automatically, such as through cookies when you visit our websites. For more details, please refer to our Cookie Statement. Additionally, we may receive data about you from third parties, including credit reference and fraud prevention agencies.
Tracking options for users with iOS 14.5, iPadOS 14.5, tvOS 14.5, and subsequent versions
We use the AppTrackingTransparency framework for users with iOS 14.5, iPadOS 14.5, and later versions to request your permission to track your activity. This allows us to enhance the system’s performance and offer a more personalized ad experience in the future. If you consent, the data collected will be used solely to improve the system and help us display the most relevant ads within the app when such functionality is included.
The AppTrackingTransparency framework will prompt the user with an authorization request for app tracking, outlining the purpose of tracking their activity as mentioned above.
How the information is used
We use the information we collect about you to deliver the products we offer, inform you of any changes to these products, and enhance our offerings. Additionally, we may use this data to share information about other products we or trusted third parties offer, which may be similar to those you have used or inquired about, or that we believe could interest you. If you use one of our financial products, we will also use your information to assess your financial situation and detect and prevent potential fraud.
By creating an account on this platform or subscribing to our newsletter, you consent to receive direct marketing emails from the platform operator, as well as its affiliates, partners, or subsidiaries. These communications may include promotional offers, product updates, newsletters, and other information related to the platform and its services. You understand that receiving these marketing emails is a condition of your registration and continued use of the platform. If you prefer not to receive marketing emails, you may opt out at any time by unsubscribing via email, updating your email preferences, or contacting our support team. However, please note that essential service-related communications may still be sent to you, as necessary for the proper operation of your account and the platform.
Revelation of the information
We will not share your personal data with anyone except as outlined in this notice. We may disclose your personal information to third parties, such as service providers, credit reference agencies, and financial institutions, in order to deliver the products we offer. Additionally, we may share your personal data with third parties to prevent crime and mitigate risk, if required by law, when deemed necessary, in response to legal proceedings, or to protect the rights or property of transferworld, our customers, or others.
Location of your personal data storage and data security
The information collected by transferworld may be transferred to, stored, and processed by recipients located outside the European Economic Area (“EEA”). These countries may have data protection standards that differ from, and in some cases, may be less stringent than those in your country of residence. We will take all necessary measures to ensure that your information is handled and protected securely by the recipients, in accordance with the same standards we uphold.
If we have provided you with, or if you have selected, a password, access code, or any other secure method for accessing certain areas of our site, you are responsible for keeping this information confidential and following our instructions. You must not share your password or login credentials with anyone. By using the credentials, you authorize transferworld to act on any instructions and information provided by anyone who enters your credentials.
The transmission of information over the internet is not fully secure. While we strive to protect your personal data, we cannot guarantee the security of any information transmitted to our site, unless you are using a secure communication channel provided by us. Once we receive your information, we will implement strict procedures and security measures to prevent unauthorized access.
Your rights and choices
Where applicable, you may have specific rights under data protection laws, including the right to access, correct, update, or delete your personal information; object to or limit its processing; request the transfer of certain personal information to another service provider (known as data portability); or withdraw any consent you have previously provided.
Please note, however, that certain exceptions may apply to these rights. For a complete explanation of the rights available to you, please refer to our Comprehensive Privacy Policy.
Automated decision-making processes
Automated decisions refer to decisions made about you automatically based on computer algorithms (using software), without any human involvement or review.
For instance, we use automated decisions to conduct a credit assessment when you apply for financial services with transferworld or to perform anti-fraud checks on your transactions. However, if you are in the European Union, you have the right to object to an automated decision and request a manual review, taking into account any additional information you provide. To exercise this right, you can contact us using the details provided below.
Legal grounds for processing
Transferworld will process your personal information only when we have one of the following legal grounds:
Based on your consent, such as when sending you marketing messages;
When necessary to enter into a contract with you and fulfill our obligations under that contract;
When we have a legitimate interest, provided that such processing does not override your rights and freedoms;
When we are legally obligated to collect your personal information, or when it is necessary to protect your vital interests or those of another person;
In exceptional cases, when required for the public interest, such as when law enforcement agencies request information to investigate a crime.
Updates to our privacy notice
Any future changes to our privacy notice will be posted on this page, and where applicable, you will be notified via email. Please visit this page regularly to stay informed about any updates or changes.
Contact us
At transferworld, we welcome any comments, questions, or requests regarding our use of your information.
Our Data Protection Officer (DPO) is responsible for ensuring that our company complies with this privacy notice. The DPO is also the primary contact for our Data Protection Supervisory Authority. If you wish to exercise any of your rights or obtain further information about transferworld (to which this notice applies), please contact our DPO at [email protected] or at the address provided below:
Studio Gg, Witan Studios, 305 Upper Fourth Street, Milton Keynes MK9 1EH, United Kingdom
Comprehensive Privacy Notice
This privacy notice applies to Transfer World UK and its brand, transferworld, which may also operate under various trading names, including transferworld (collectively referred to as “transferworld,” “we,” or “our”).
This notice demonstrates our commitment to safeguarding your privacy rights and outlines how we process any personal information we collect from you or that you provide to us. It applies to:
The features and services available to you when you visit our websites, portals, or payment panels used by our clients on their websites.
Your use of software, including terminals, mobile, and desktop applications provided by transferworld; as well as email, SMS, phone calls, web chat, websites/portals, and any other forms of communication between you and transferworld.
The transferworld website is not intended for individuals under the age of 18. If you are under 18, you are not permitted to use the transferworld website.
We encourage you to read this policy carefully, as it provides important information about what to expect when we collect your personal information and how we will use your personal data.
I. Overview
The purpose of this policy is to outline the ways in which we may collect and use personal information obtained about you. By registering as a user of any services provided through the transferworld website and/or by using the website, you consent to our use of your personal data as described in this policy. While you may choose not to provide any information, please note that transferworld may be unable to offer certain services without it.
Your use of the transferworld website is also subject to our online Terms and Conditions. We encourage you to read both the Terms and Conditions and this Privacy Policy. Please note that transferworld may update this Privacy Policy periodically, so we recommend reviewing it regularly.
The controller of your personal data is transferworld, as outlined in the Terms & Conditions. We have appointed a Data Protection Officer (DPO), and you can contact our DPO via email at [email protected].
We adhere to applicable data protection laws, including the Transferworld Data Protection Act (SDPA) and the EU General Data Protection Regulation (GDPR), where applicable. For individuals residing in the European Economic Area (EEA), including the United Kingdom (collectively “EEA Residents”), and in accordance with Article 6 of the EU General Data Protection Regulation (GDPR) or any equivalent legislation (collectively “EEA Data Protection Law”), we process personal information based on our Terms of Use (Agreement) with you, to fulfill our legal obligations, pursue our legitimate interests as described above, and with your consent.
Security is a top priority for us. We implement all reasonable measures to protect personal data from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction, including industry-standard security protocols and encryption methods.
If the profile is created by a legal entity, the head or other representative of the client must clearly inform the data subjects (such as beneficial owners, heads, etc.) about the transfer of their data to us and ensure that this Privacy Policy is presented to them.
II. Definitions
“Account” refers to the contractual agreement in which a transferworld member has accepted our Terms of Use and Privacy Policy and has been granted approval to use the transferworld services, including buying and selling Bitcoins and conducting related transactions.
„AML“ shall mean anti-money laundering and counter-terrorism financing regulations.
“DPL” refers to the data protection laws applicable to transferworld, including the Transferworld Data Protection Act (draft of September 2017), its successors or implementing regulations, as well as equivalent legislation governing the processing of Personal Data by transferworld.
“Personal data” refers to any information that can identify an individual, such as name, address, email address, trading information, and banking details. Personal data does not include anonymized and/or aggregated data that cannot be used to identify a specific individual.
“Service(s)” refers to the technological platform, operational rules, and marketplace managed by transferworld, enabling Sellers and Buyers to carry out purchase and sale transactions of Bitcoins and/or other Cryptocurrencies.
“Supervisory institutions” refers to the Organisme de Surveillance pour Intermédiaires Financiers & Trustees (“SOFIT”), the Transferworld Financial Market Supervisory Authority (FINMA), or any other institutions that directly or indirectly oversee our activities.”
transferworld platform” refers to the hardware and software technologies utilized by transferworld to deliver the transferworld Service, as outlined in our Terms of Use.
„Transaction“ shall include the following:
The action taken by the Member to buy and/or sell cryptocurrencies through the Service at the market exchange rate.
The transfer of cryptocurrencies between Members (“Transfer Transaction”).
The exchange of currencies between Members (“Currency Exchange Transaction”); and
transferworld may not currently offer all of these transaction types.
“You, Your, or the Client refers to the natural person who is entering into a contract with us, making payments to our system or representative, or the beneficial owner on whose behalf the personal data is provided.
Other terms used in this Privacy Policy are defined in our online Terms & Conditions.
III. The purpose of processing
1. Collection and Use of Personal Information
We collect and process your data for the following purposes:
Provision of payment services; identity verification; prevention of fraud, money laundering, counter-terrorism financing, and other financial crimes; and fulfillment of other obligations under AML (Anti-Money Laundering) requirements.
- Provision of payment services; identity verification; prevention of fraud, money laundering, counter-terrorism financing, and other financial crimes; and fulfillment of other obligations under AML (Anti-Money Laundering) requirements.
- Notification of changes to our services and prevention of disputes.
- Resolution of disputes.
- Marketing and promotional activities
A. Provision of payment services; identity verification; prevention of fraud, money laundering, counter-terrorist financing, and other financial crimes; and fulfillment of obligations under AML (Anti-Money Laundering) requirements
1. transferworld is legally obligated to verify your identity, monitor client transactions, prevent fraud, money laundering, counter-terrorism financing, and other financial crimes, ensure proper implementation of payment service provider duties, and comply with AML (Anti-Money Laundering) regulations.
2. For this purpose, we may collect the following data about the individual client or representative of the legal entity client:
Data related to your identity: full name, surname, personal identification number or other unique identifier, date of birth, identification document number, copy of identification document, nationality or the country that issued the identification document, country of residence, ID number in the transferworld system, account number in the transferworld system, facial photograph, etc. (“Identity Data”).
Contact information: address, phone number, email address, etc. (“Contact Data”).
KYC (Know Your Customer) data: account numbers with other payment service providers, checks against public and private registries, fraud, money laundering, counter-terrorism financing, and other financial crime prevention agencies, employer details, job position, address, occupation, used services, payment and transaction history, turnover, source of funds, countries from which funds will be received/transferred, information on political exposure, and other data related to monitoring the client’s activity, etc. (“KYC Data”).
Device information: operating system of the device, browser type and version used to access the profile, IP address and location, time zone settings, etc. (“Device Information”).
Financial information: bank account numbers, bank statements, and trading details (“Financial Information”).
Online identifiers: geolocation/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses (“Online Identifiers”).
Usage data: survey responses, information provided to our support team, public social media posts, authentication data, security questions, user ID, click-stream data, and other data collected through cookies and similar technologies. Please refer to our Cookie Statement for more details. (“Usage Data”).
“Transferworld payment card details: including the card number, CVC code, PIN, expiration dates, and other relevant information (referred to as ‘Payment Card Information’).”
Any additional information provided by you or your customer.
3. We may also collect and process identity data of the beneficial owners of a legal entity. Additionally, identity data may be collected and processed for the Head of the legal entity if the profile was created by another representative of the client.
4. We may collect data from you and third parties, and search publicly available information about you to verify your identity, process transactions, detect and prevent fraud, and for other similar purposes.
5. We collect the data mentioned above because it is required by law, and we need this information to establish a contractual relationship with the client. If you or a representative of the legal entity do not provide the required data, we may refuse to enter into a contractual relationship and provide services to the client.
6. We may share your data with supervisory authorities, banking and financial service partners, other payment service providers, payment card manufacturing/personalization and delivery companies, entities that provide identification and sanctions/watchlist screening, transaction monitoring services, government bodies, attorneys, bailiffs, pre-trial investigation authorities, courts, auditors, debt recovery agencies, organizations handling joint debtor data files, agencies dedicated to preventing fraud, money laundering, terrorist financing, and other financial crimes, as well as any other parties with a legitimate interest or with your consent.
7. We process personal data for as long as necessary to fulfill the relevant purpose(s) or as required by law (e.g., for tax obligations, anti-money laundering (AML) requirements, and the retention of business records).
“8. We may transfer your data to third countries in order to process your payment transaction to a recipient in a third country or when using services of third-country partners for the transaction. In such cases, we ensure that adequate protection is in place for your personal data, either by transferring it based on an adequacy decision (such as the EU-CH adequacy decision) or by implementing safeguards as outlined in Article 6 of the SDPA and Article 46 of the GDPR. In some instances, we may transfer your data to countries with inadequate data protection, provided that the requirements under applicable data protection laws, such as obtaining your explicit consent, are met.”
B. Notification of Changes to Our Services and Dispute Prevention.
1. By law, we are obligated to notify you about changes to our services and the Terms & Conditions for the provision of services. These notifications are not considered marketing materials and are provided as required by law. Therefore, you do not have the right to object to receiving such notifications. For this purpose, we may process your contact data.
2. We process the aforementioned data because it is required by law and necessary for the performance of the contract with the client.
3. You may also reach out to us for information, to consult about our services, to report unauthorized payments, request the blocking of your payment instrument, or ask for other information. You can contact us by phone or email. When you contact us, we may process your identity data, contact data, device data, as well as record phone conversations and store the content and history of our correspondence.
4. The above-mentioned data is processed for the following purposes:
When you contact us by phone, the data is processed for the legitimate interests we pursue in order to prevent disputes regarding the proper provision or receipt of information.
When you contact us by email or letter, the data is collected to comply with legal requirements and for the legitimate interests we pursue in order to prevent disputes regarding the proper provision or receipt of information.
5. Your data may be shared with supervisory authorities, attorneys, pre-trial investigation agencies, courts, auditors, debt recovery agencies, companies handling joint debtor data files, and other entities with your consent.
D. Marketing
1. We may send you information via email about our current and new services, as well as other products and services we offer that are similar to those you have previously used or expressed interest in. Additionally, we may share this information with selected third parties who may provide you with details about products or services we believe may interest you.
2. Your email will be processed for our direct marketing purposes (e.g., newsletters) only with your explicit consent.
3. You have the right to object to the use of your email for direct marketing purposes at any time.
4. We may share your email address with email marketing service providers to send you newsletters on our behalf.
5. We hereby inform you that we may also use your personal data (such as used services, location, IP, behavior, etc.) to form a view on what We think You may want or need, or what may be of interest to you and show You adverts in our webpage.
6. We may also provide anonymized information to advertisers to promote our products and services. Therefore, such anonymized information would be used to help our advertising partners provide a targeted campaign, relevant for a sub-section of our Clients.
7. You have the right to object to the use of your data for marketing purposes at any time.
8. We may engage certain service providers (data processors) to process your personal data. These may include companies offering data storage, server and communication services, software development and maintenance, marketing services, online activity analysis, website traffic and analytics, statistical services, and other related services. Your personal data will only be shared with these data processors when necessary and to the extent required for the provision of their respective services.
2. Use of Cookies and Similar Technologies
1. transferworld collects and stores certain information automatically whenever you interact with our services. The transferworld website uses cookies, which are small text files placed on your computer by websites you visit, including transferworld. Cookies are commonly used to make websites function or function more efficiently, as well as to provide data to website owners.
“2. Cookies are usually stored on your computer’s hard drive. The information collected from cookies is used by us to assess the performance of our website, analyze trends, and manage the Platform. This data helps us identify the most visited areas of our website and any challenges visitors may face in accessing it. With this insight, we can enhance your experience on the Platform by highlighting popular features and resolving access issues. Additionally, we use cookies and/or a technology called web bugs or clear gifs, which are often embedded in emails, to track your receipt of and response to our communications and to offer you a more personalized experience on our website. The information we gather includes:
Technical information, including the Internet Protocol (IP) address used to connect your computer or device to the internet, your login details, browser type and version, time zone settings, browser plug-in types and versions, and operating system platform;
Information about your visit, including whether you opened an email, the full Uniform Resource Locators (URL) clickstream to, through, and from our site (including date and time), products or services you viewed or searched for, page response times, download errors, duration of visits to specific pages, page interaction details (such as scrolling, clicks, and mouse-overs), methods used to navigate away from pages, and any phone number used to contact our customer service.
3. We use third-party service providers to help us better understand how our website is used. These service providers will place cookies on your computer’s hard drive and collect selected information that helps us learn how visitors navigate our site, what products are browsed, and general transaction details. Our service providers analyze this data and provide us with aggregate reports. The information and insights gathered by our service providers are used to improve our understanding of our visitors’ interests and enhance our ability to serve those interests. The data collected by our service providers may be combined with information we gather about you while using the Platform. Our service providers are contractually obligated to use the information only to assist us.
4. If you prefer not to use cookies, you can disable them in your browser settings. However, disabling cookies may prevent you from using certain features of our website or services, such as logging into your transferworld account or completing transactions. By using our website or services with a browser configured to accept cookies, you consent to the use of both transferworld cookies and third-party cookies.
5. For more information about cookies, the types we use, and how we use them, please refer to our Cookie Statement.
3. Processing of Data
1. Your data will be processed through both automated and manual methods, including automated decision-making and profiling, for various purposes.
2. Automated decision-making and profiling may be used to verify your identity, monitor your profile activities and operations, and predict various aspects of your behavior. These procedures are required to comply with AML regulations and are essential for establishing and maintaining a business relationship between us and the client. transferworld implements appropriate measures to protect your rights, freedoms, and legitimate interests, including the right to request human intervention. You also have the right to express your opinion and challenge any decisions made.
3. The information we process about you is securely stored on our servers. We utilize all necessary technical, organizational, and other measures to ensure the protection of your data.
4. Tracking options for users on iOS 14.5, iPadOS 14.5, tvOS 14.5, and later versions
1. For users on iOS 14.5, iPadOS 14.5, and later, we utilize the AppTrackingTransparency framework to request permission for tracking. This allows us to enhance system functionality and provide a more personalized ad experience. If you grant permission, the collected data will be used solely to improve the system and determine the most relevant ads to display within the application when such functionality is introduced.
2. The AppTrackingTransparency framework will display an app-tracking authorization request to the user, outlining the stated purpose of tracking.
III. Disclosure and Transfer of Personal Data
We may disclose your Personal Data to third parties and legal and regulatory authorities and transfer your Personal Data outside the Switzerland and the EEA, as described below.
1. Disclosures to Third Parties
1. In certain situations, we may share your Personal Data with employees, contractors, and other relevant parties.
We may share your information with other entities within our corporate group to ensure the best possible service. These entities are required to handle your data in compliance with this Privacy Policy.
We may also share your information with specific contractors or service providers who process Personal Data on our behalf. For instance, this may include marketing agencies, advertising firms, IT specialists, database providers, backup and disaster recovery experts, email service providers, or outsourced call centers. All suppliers and service providers are required to adhere to our standards for data processing and security. Any information shared with them, including your personal data, will be strictly for the purpose of fulfilling their designated functions.
We may also share your information with certain third parties, either with your consent or when necessary to provide you with products or services. These may include credit reference agencies, anti-fraud databases, screening agencies, and other business partners.
We may share your information to enhance and expand our business, including optimizing our websites, portals, products, and services. This may involve using data you enter into forms but do not submit, for purposes such as website improvement and customer service outreach. Additionally, we may use your personal information to develop and test new products and services.
2. Your Personal Data may be shared with third-party organizations under specific circumstances:
If we are considering selling or transferring part or all of our business, your information may be shared with potential buyers under appropriate confidentiality terms.
If our business undergoes reorganization or is sold, your information may be transferred to the new owner to ensure the continued provision of services to you.
If required by law, regulatory codes, or industry practices we adhere to, or if requested by a public or regulatory authority—such as the police—we may share your information.
If we are involved in a legal claim, your information may be shared as necessary to support our defense.
To ensure compliance with local and national laws.
To send marketing messages, provide information about products and services you have requested or may find interesting, and gather your feedback on our goods, services, and websites. We may use your personal information for marketing, market research, and similar activities, regardless of whether you are accepted for or continue using transferworld services. If you no longer wish to receive marketing or promotional messages from transferworld, you can opt out at any time.
To manage and mitigate credit risks, we may assess your financial position (or that of your business) if you apply for one of our financial products, as outlined in the applicable Terms of Use. This credit check may also extend to linked parties such as directors, shareholders, and principals. We conduct these checks by receiving and sharing information with credit reference agencies and fraud prevention agencies.
Additionally, this assessment may affect anyone with whom you have a joint account or financial association. If a joint application creates a new financial link, it will remain until you submit a “notice of disassociation” to the credit reference agencies. These agencies will record our inquiries, which may be visible to other companies conducting their own credit checks, and a “footprint” may be added to your credit file, regardless of whether your application is accepted.
If you are a director, we will verify that the residential address you provide matches the one held by the relevant companies’ registry (where applicable). Furthermore, if you use our services, we will report your account management details to credit reference agencies.
Failure to repay debts in full and on time will result in credit reference agencies recording the outstanding amount, and this information may be shared with other organizations conducting similar checks. These records remain on file for six years after closure, whether settled or defaulted.
For more information about our use of credit reference agencies, please Contact Us.
To prevent, detect, and prosecute fraud or crime, transferworld may participate in anti-fraud initiatives. This includes assessing you (and/or your customers) and monitoring your transactions and locations to identify patterns that may require investigation or to assess the likelihood of fraudulent activity. We may use third-party products and services to support these efforts.
Additionally, if you provide false or inaccurate information, or if we detect or suspect fraud or criminal activity, we may share your information with fraud prevention and law enforcement agencies. In such cases, we also reserve the right to take legal action against you.
To prevent or reduce information security risks.
To manage and enforce our rights, Terms of Use, or any other agreements with you (and/or your business). This includes handling disputed transactions, rewards, or points; addressing, investigating, and resolving complaints; recovering debts; or managing matters related to insolvency.
3. Your Personal Data may be shared if it has been anonymized and aggregated, as it will no longer be considered Personal Data in such cases.
4. Your information will not be sold, exchanged, or shared with third parties without your consent, except when necessary to provide transferworld services or comply with legal requirements.
5. transferworld’s third-party service providers are contractually obligated to protect your information and use it solely for the purposes for which it was shared, unless otherwise required or permitted by law. We ensure that these third parties adhere to terms that comply with DPL.
6. Specifically, your Personal Data may be shared with the following third-party organizations under certain circumstances:
GlobalPass reviews ID documents and other AML-KYC-related information to help us fulfill our KYC obligations. It processes and stores data in ISO 27001-certified data centers worldwide. Learn more about how GlobalPass handles data.
When you top up via the Platform using a wire transfer or credit card, your Personal Data may be shared with Transfer World UK, as a free crypto wallet is automatically created upon registration. Transfer World UK processes and stores data in ISO 27001-certified data centers worldwide. Learn more about how Transfer World UK handles data.
When you hold, buy, sell, or transfer cryptocurrency through the Platform, your Personal Data may be shared with Transfer World UK. It processes and stores data in ISO 27001-certified data centers worldwide. Learn more about how Transfer World UK handles data.
When you open an IBAN account, your Personal Data may be shared with Transferworld, UAB or another provider specified on the Platform. Transferworld, UAB securely processes and stores data in ISO 27001-certified data centers worldwide. Learn more about how Transferworld, UAB manages data.
When you apply for a debit card through the Platform, your Personal Data may be shared with Transferworld, UAB for the approval process. Transferworld, UAB securely processes and stores data in ISO 27001-certified data centers worldwide. Learn more about how Transferworld, UAB handles data.
2. Disclosures to Legal Authorities
1. Transferworld may be legally required to share your information with regulatory authorities and law enforcement agencies worldwide or may determine that doing so is necessary or appropriate. These disclosures may also include requests from governmental or public authorities, as well as commercial organizations you have interacted with that seek to mitigate fraud risks. Additionally, we may share your data for litigation, legal proceedings, national security, or if we deem it in the national or public interest or otherwise lawful to do so.
As a result, we may disclose your Personal Data to law enforcement, data protection authorities, government officials, and other relevant entities when:
a) We are compelled by a court order or other legal procedures.
b) Disclosure is necessary to report suspected illegal activity.
c) Disclosure is necessary to investigate violations of this Privacy Policy or our Terms of Use.
3. International Transfers of Personal Data
We store and process your Personal Data in data centers around the world, wherever Transferworld facilities or service providers are located. As such, we may transfer your Personal Data outside of Switzerland and the European Union. Some of the countries to which your Personal Data may be transferred for these purposes that are located outside Switzerland or the EU do not benefit from an adequacy decision issued by the Transferworld Data Protection and Information Commissioner or by the EU Commission regarding protection afforded to Personal Data in that country. Details of these specific countries can be found here: https://www.edoeb.admin.ch/edoeb/de/home/datenschutz/handel-und-wirtschaft/uebermittlung-ins-ausland.html and https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. Such transfers are undertaken in accordance with our legal and regulatory obligations and appropriate safeguards under DPL will be implemented, such as standard data protection clauses with data recipients or processors approved by competent authorities. A copy may be requested at the address set out in the Contact Us section.
IV. Your rights
1. Please be informed about your rights under Data Protection regulations in relation to Your personal data:
1. You have certain rights under data protection regulations regarding your personal data, including:
a) Right to Information: You have the right to request details about what personal data of yours is being processed and the reasons for such processing.
b) Right of Access: You may request access to your personal data.
c) Right of Rectification: You can request corrections to inaccurate personal data and completion of incomplete data. We may need to verify the accuracy of any new information you provide.
d) Right of Erasure (Right to Be Forgotten): You have the right to request the deletion of your personal data if there is no legitimate reason for us to continue processing it. However, in some cases, we may be legally required to retain certain data, such as for anti-money laundering (AML) regulations, which require records to be kept for a minimum of 10 years. After this period, we will securely delete or anonymize the data.
e) Right to Restriction of Processing (Right to Withdraw Consent): You can request that we restrict the processing of your data under certain circumstances. In such cases, your data will only be processed with your consent, for legal claims, or for significant public interest.
f) Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format and to transmit it to another data controller. This applies only to data you have provided.
g) Right to Object: You can object to the processing of your personal data at any time if it is based on our legitimate interests. If we process data for marketing purposes, you may opt out at any time.
h) Right to Object to Automated Processing: If a decision that affects you is made solely by automated means (such as an automated credit check), you have the right to request a manual review of that decision.
i) Right to Withdraw Consent: If we rely on your consent to process your data, you may withdraw it at any time. This will not affect prior processing, but it may impact our ability to provide certain services.
j) Right to Complain: If you have concerns about our data processing practices, you can file a complaint with the relevant data protection authority in your country. In Switzerland, the Federal Data Protection and Information Commissioner (FDPIC) oversees data protection matters. We encourage you to contact us first so we can address your concerns. You can reach our Data Protection Officer at [email protected].
1. We take the protection of your personal data very seriously and strive to implement all necessary organizational and technological security measures.
2. To ensure the confidentiality of your personal data and protect it from loss, theft, unauthorized access, misuse, alteration, or destruction, we employ a range of security measures, including but not limited to:
Password-protected directories and databases.
Secure Sockets Layer (SSL) technology to encrypt and securely transmit your information over the internet.
PCI scanning to proactively safeguard our servers against hackers and vulnerabilities.
3. All financially sensitive and credit-related information is transmitted via SSL technology and encrypted in our database. Access to your personal data is strictly limited to authorized Transferworld personnel, who are required to treat this information as highly confidential. Our security measures are regularly reviewed and updated in line with legal and technological advancements.
4. We will never request financial or payment details—such as credit card numbers, passcodes, account numbers, or PINs—via email, text, or any other communication. Always verify that any website requesting financial or payment information for Transferworld services is officially operated by us. If you receive a suspicious request, do not provide your information and report it immediately by contacting our customer service team as outlined in this Privacy Policy.
5. You are responsible for maintaining the confidentiality and security of your account passcode, membership numbers, and PINs. Do not share this information with anyone. If you suspect unauthorized use or a security breach involving your information, notify us as soon as possible.
6.Please be aware that transmitting information over the internet is not entirely secure. While we take extensive measures to protect your personal data, we cannot guarantee complete security unless you are communicating with us through a secure channel that we have provided. Once we receive your information, we implement strict procedures and security protocols to prevent unauthorized access. By browsing our website and using our services, you acknowledge and accept that providing personal data to us or third parties is done at your own risk.
V. Security of your data
1. We take protecting of your personal data very seriously and strive to apply all necessary organizational and technological security measures.
2. We use a variety of security measures to ensure the confidentiality of your Personal Data, and to protect your Personal Data from loss, theft, unauthorised access, misuse, alteration or destruction. These security measures include, but are not limited to:
Password protected directories and databases;
Secure Sockets Layered (SSL) technology to ensure that your information is fully encrypted and sent across the Internet securely;
PCI Scanning to actively protect our servers from hackers and other vulnerabilities.
3. All financially sensitive and/or credit information is transmitted via SSL technology and encrypted in our database. Only authorised transferworld personnel are permitted access to your Personal Data, and these personnel are required to treat the information as highly confidential. The security measures will be reviewed regularly in light of new and relevant legal and technical developments.
4. We do not ask for financial or payment information, such as your credit card number, passcode, account number or pin number, in an e-mail, text or any other communication that we send to you. Please always check that any website on which you are asked for financial or payment information in relation to our reservations or services is operated by transferworld. If you do receive a suspicious request, do not provide your information and report it by contacting one our member service representatives as set in this Privacy Policy.
5. You are responsible for keeping your account passcode, membership numbers and pin numbers safe and secure. Do not share those with anyone. If there is an unauthorised use or any other breach of security involving your information, you must notify us below as soon as possible.
6. Please note, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our site, unless you are communicating with us through a secure channel that we have provided. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. By browsing the Website and/or using the services of the Company you expressly acknowledge and agree that any personal information or other data provided by you to us or third persons is provided at your own risk.
VI. Final provisions
1. This Privacy Policy is intended to apply globally; however, it does not override any legal rights or restrictions applicable in specific jurisdictions. Where local laws take precedence, the rights and obligations outlined in this policy will be subject to necessary modifications to ensure compliance.
2. We reserve the right to modify the provisions of this Privacy Policy as needed. In the event of any changes, we will notify you in advance and publish the updated version on our website. The latest revision of this Privacy Policy was made on May 20, 2024.