1. Introduction

1.1 This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (Act) and applies to PayexFlo and all its trading subsidiaries.

1.2 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as servitude, forced and compulsory labour, slavery, and human trafficking. All of these have in common the deprivation by one person of another person’s liberty in order to exploit them for personal or commercial gain.

1.3 This statement sets out PayexFlo’s approach to dealing with the potential risk of slavery and human trafficking (as defined in the Act) occurring within PayexFlo’s supply chain or any part of its business.

2. PayexFlo’s Business

2.1 PayexFlo is a website that aggregates a Network of Regulated Market Participants that are licensed entities, Regulated Market Participants may be Licensed Banks, Electronic Money Institutions, Authorized Payments Institutions, Investment Institutions and Authorized Payment Service Providers that are supervised and regulated locally by the relevant financial regulator, those institutions may be authorized to undergo into Foreign Exchange Delivery Operations and intermediation that is specific to their applicable regulatory framework in their jurisdiction.

3. Policy statement

3.1 PayexFlo maintains a zero-tolerance approach to modern slavery and human trafficking. As a business, we are committed to acting ethically and with integrity in all our business dealings and relationships. We will not knowingly support or do business with any organization that is involved in either.

3.2 Consequently, we are intent on implementing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. We expect the same high standards from all of our contractors, suppliers and other business partners and by corollary we expect our suppliers to hold their own suppliers to the same high standards.

3.3 As part of our contracting processes, we are working towards including specific contractual prohibitions against the use of forced, compulsory or trafficked labour.

4. Supply Chain

4.1 Based on the nature of our business, PayexFlo believes it has a relatively straightforward supply chain. The vast majority of our supply chain involves only server leasing, the Regulated Market Participants which work with us are highly regulated and supervised entities. As such, we believe that the risk of slavery and human trafficking issues in our supply chain is low. Accordingly, we have adopted a risk based approach to the assessment of and the due diligence we carry out but recognize the importance of reviewing this approach on a regular basis to ensure compliance with international legal standards.

4.2 Due to the nature of our small operation we don’t believe there are areas of our supply chain that may have a higher risk in relation to modern slavery and human trafficking:

4.3 PayexFlo is implementing a due diligence process when approving new suppliers which takes into consideration the geographical location, industry sector and nature of the commercial transaction, and assesses the risk from a slavery and human trafficking perspective.

4.4 We seek to build relationships with reputable suppliers. All suppliers and Regulated Market Participants entering into new or extended contracts with PayexFlo are required to self-certify in compliance with international legal standards.

5. Employment

5.1 While PayexFlo does not have, or consider that it needs a formal human rights policy, our policies are consistent with general human rights principles and applicable human rights legislation. This approach applies to all persons working for, with or on our behalf of PayexFlo in whatever capacity, including employees, directors, officers, agency workers, interns, contractors, external consultants, third-party representatives and business partners.

5.2 In addition to covering such issues as health & safety, training and remuneration, PayexFlo’s employment and external third party agent standards encompass the following:

• Freedom of association is respected
• Equality is promoted;
• We do not tolerate Bullying, harsh or inhumane treatment.
• The right to collective bargaining is respected;
• Working conditions in our premises (if any) are safe and hygienic;
• Employment shall never be coerced and shall always be freely chosen;
• Child labour is prohibited;
• No employee is paid less than the minimum wage in their country of operation;
• Working hours are not excessive;
• No discrimination is practiced

6. Responsibility for the policy

6.1 Our directive staff has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

6.2 The HHRR directive staff has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

7. Compliance with the policy

7.1 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working or cooperating with PayexFlo. Employees and external agents are required to avoid any activity that might lead to or suggest a breach of this policy.

8. Approval

8.1 This statement was approved by the owner of PayexFlo on March 4^th 2020 and is being reviewed annually. It is available on our website at www.payexflo.com 

If you have any questions on regards to this or other policies please email legal@payexflo.com and we will be happy to assist you.

Privacy Policy

Privacy policy

1. Introduction

This Privacy Policy applies to personal data (“information”) held by PayexFlo (“we” or “us”) as data controllers. It explains in detail the types of information we collect about you and how we use this information. Please read it carefully.

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes.

Please read the following carefully to understand how we handle your information.

2. The information we may collect 

2.1.  Information you provide us

• Personal details, e.g. your name, date of birth;
• Contact details, e.g. your address, email, phone number, mobile number
• Information about your identity, e.g. your nationality, passport information; and
• Your prospective operational & amount details (volume, transactions, origin, destination etc).
• Transactional information, e.g. details about your accounts

2.2.  Information we collect about you

• Communication records, e.g. details recorded during our written and verbal communications with you;
• Information gathered when you visit our websites. This might include; the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browsing plug-in types and versions, operating system and platform, Uniform Resource Locators (URL), and how you navigate our websites. We use this information for technical monitoring and optimizing our websites. For more information, visit our Cookie Policy

Where we collect your personal information we will also reference this Privacy Policy to ensure you are informed of our processing activities and your rights under relevant data protection legislation.

3. How we collect your information

We collect your personal information when you use our services, for example by filling in forms on our websites, by corresponding with us by telephone or email. We may also collect your information when you interact with our websites

3.1.  Information from other sources

We may receive your information from other Companies or Agents of our Group if you use, enquire about, or demonstrate an interest in other services we offer. We will only do this when we have obtained your consent, have a legitimate interest, or have a legal obligation to do so.

We may also receive your information from other third parties, such as:

• Our partners (companies that introduce you to us);
• The Regulated Market Participants (when they interact with you);
• Credit reference agencies; 
• Fraud prevention agencies; 
• Identity verification agencies;
• Sub-contractors and advisers;
• Agents and suppliers;
• Government and law enforcement agencies;
• Publicly available online sources, such as company websites, social networks and company registries.

3.2.  Information you provide about other people

If you provide us with personal information about another person, we ask that you inform them of our identity and the purposes for which their information will be processed.

3.3.  Cookies

Our websites use cookies to distinguish you from other users of our websites. This provides you with a better browsing experience, and also allows us to improve our websites. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy linked below.

4. How we use your information

We will only use your information under the following circumstances:

• When it is necessary to fulfil our contract with you or with Regulated Market Participants
  
  Some of the information we process is required by the Regulated Market Participants for them to provide you with their products and services. For example, they will require your transactional details in order to settle payments on orders you place.
• Where we are under a legal obligation
  
  In certain cases, we are required by law to collect and process your information. For example, to fulfil a court order or a regulator requirement, we must store all records of communications you make with us. We are also required to check that you are the person you say you are before we discuss any of our clients’ accounts (which we may do by asking you to confirm your date of birth or other details about yourself) and to retain personal information to facilitate investigations detecting and preventing fraud, money laundering and other financial crimes.
• Where we have obtained your consent
  
  In specific situations, we will collect and process your information with your consent, e.g. when you tick a box to receive marketing material from us, or ask us to contact you about our products and services.

  We will always make it clear to you what you are consenting to and what information is necessary for our services. If you have given consent to the use of your personal information, you are entitled to withdraw this consent at any time. Please be aware, however, that in some circumstances, the withdrawal of your consent may result in us being unable to provide some services to you.

• Where we have a legitimate interest 
  
  Sometimes, we use your personal information to pursue our legitimate business or commercial interests in a way you might reasonably expect. We will not rely on our own legitimate interests without first considering your own rights, freedoms or interests, which we hold in the highest regard.

  Some of our legitimate interests include:

  • Carrying out marketing activities;
  • Communicating with you about our products and services; 
  • Improving our products, services, and relationships with you and our partners; 
  • Create a smoother user experience;
  • Complaints handling;
  • Improve our websites to ensure that content is well presented for you; 

4.2.  Combining information 

We may combine information about you which we receive from other sources with the information you give to us, and the information we collect about you, for the same purposes as those set out above.

5. How we share your information

We only share your personal information under the following circumstances:

• If we are under a duty to disclose or share your personal information in order to comply with a legal obligation;
• In order to conduct necessary background checks on you before passing your information to Regulated Market Participants;
• Where we have been asked for information to facilitate an investigation;
• In order to enforce or apply our terms and conditions and other agreements; 
• To protect the rights, property, or safety of PayexFlo, our users, or others;
• Where we have a legitimate business interest that is not overridden by your own rights and freedoms; 
• Where we have obtained your consent.

Entities that we may share your information with include:

• Regulated Market Participants
• Members of PayexFlo;
• Other Brands, Websites or Entities of the Group.
• Our partners (companies that introduce you to us);
• Credit reference agencies;
• Fraud prevention agencies; 
• Identity verification agencies;
• Agents, suppliers, sub-contractors and advisers;
• Regulatory bodies.

6. International Transfers and Security

We may be required to transfer your information to any country, e.g. if we are obliged to report to foreign authorities, or when your information is processed by Regulated Market Participants or one of our suppliers. In these cases, there will be a contract in place to make sure the recipient protects the information to the same standard we are used to. We also implement strict procedures and security features to ensure that your information is transferred securely in line with the standards set out in the General Data Protection Regulation (“GDPR”). 

7. How long we store your information

Personal information is retained according to our retention schedule. We only retain your information for a period necessary to fulfil the purpose for which it was originally processed, or in order to fulfil a legal obligation. 

8. Your rights

• Access

  You may request access to the information we hold about you by making a Subject Access Request.

• Erasure

  You may request that we destroy, delete or discontinue using your personal information when it is no longer necessary for the purpose we originally collected it.

• Restriction

  You may request that we stop processing your information when you contest its accuracy or the lawfulness of the processing.

• Rectification

  You may ask us to update and correct any out-of-date or incorrect personal information that we hold about you.

• Portability

  Under certain circumstances, you may ask us to provide a copy of your information to another organization in a structured, machine-readable format.

• Withdrawing consent

  Whenever you have given us your consent to use your information, you have the right to at any time withdraw your consent.

• Legitimate interests

  In cases where we are processing your information on the basis of our legitimate interests, you can ask us to stop for reasons connected to your individual situation.

  We will do so unless we believe we have a legitimate overriding reason to continue processing your information. Please bear in mind that if you do object, this may affect our ability to provide you with some of our services.

• Marketing

  You have the right to stop our use of your information for direct marketing activities through all channels, or selected channels. You always have the opportunity to opt-out, and we will always comply with your request.

  To do so, click the ‘unsubscribe’ link in any email communication we send to you to notify us that you would like us to stop any further emails.

9. Submitting a request

You can request to exercise these rights at any time by contacting us at dataprotection@payexflo.com

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Policy.

If you have authorized a third party to submit a request on your behalf, we will ask them to prove they have your permission to act on your behalf.

You will not have to pay a fee to access your personal information (or to exercise any other rights). However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. If we do refuse your request, we will explain to you the reasons for our refusal.

10. Submitting a request

In the event that you have any questions, comments or concerns regarding this Privacy Policy, please contact our Data Protection Officer through the following methods:

Email: dataprotection@payexflo.com

If you have any questions on regards to this or other policies please email legal@payexflo.com   and we will be happy to assist you.

Cookie Policy

Most websites you visit will use cookies in order to improve your user experience by enabling that website to ‘remember’ you, either for the duration of your visit (using a ‘session cookie’) or for repeat visits (using a ‘persistent cookie’).

Cookies do lots of different jobs, like letting you navigate between pages efficiently, storing your preferences, and generally improving your experience of a website. Cookies make the interaction between you and the website faster and easier. Cookies also allow us to count unique visitors, and see how they use the website, e.g. to help us improve how easily users can find what they are looking for.

If a website doesn’t use cookies, it will think you are a new visitor every time you move to a new page on the site.

Some websites will also use cookies to enable them to target their advertising or marketing messages based for example, on your location and/or browsing habits. Cookies may be set by the website you are visiting (‘first party cookies’) or they may be set by other websites who run content on the page you are viewing (‘third party cookies’). 

What is in a cookie?

A cookie is a simple text file that is stored on your computer or mobile device by a website’s server and only that server will be able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier and the site name and some digits and numbers. It allows a website to remember things like your preferences or what’s in your shopping basket.

Cookies may also store your IP address or other information about your device.

What to do if you don’t want cookies to be set

Some people find the idea of a website storing information on their computer or mobile device a bit intrusive, particularly when this information is stored and used by a third party without them knowing. Although this is generally quite harmless you may not, for example, want to see advertising that has been targeted to your interests. If you prefer, it is possible to block some or all cookies, or even to delete cookies that have already been set; but you need to be aware that you might lose some functions of that website.

How can I control cookies?

If you don’t want to receive cookies, you can modify your browser so that it notifies you when cookies are sent to it or you can refuse cookies altogether. You can also delete cookies that have already been set.

If you wish to restrict or block web browser cookies which are set on your device then you can do this through your browser settings; the Help function within your browser should tell you how. Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of desktop browsers.

Please note that if you disable the use of Cookies on this website some functionality such as navigation may not work as intended.

For information about controlling cookies on the browser of a mobile device please refer to your device manual.

Cookies in emails

We also use cookies and similar technologies in some emails. These tell us whether you open an email and how you interacted with it. If you have enabled images, cookies may be set on your computer or device. Cookies will also be set if you click on any link within the email. The technology types we use are:

• Web beacons: tiny, invisible images placed in emails to tell us whether you open them (and if so how often), how you interact with them (for example the time you spend reading the email), which email software and web browser you used, which device you used and your IP address. We also use web beacons to help us display emails in the best format for your device.
• Link tracking: our emails contain several hyperlinks, each with a unique tag. When you click on a link the mailing company logs the click so that we can understand who has clicked through from an email to our website. We use this information to tailor future messages to you.
• Cookies: our process for delivering emails may cause cookies to be set when you download images or when you click on a link.

How to control email cookies

If you don’t want to accept cookies from our emails, just close the email before clicking on any links or downloading any images. You can also alter your browser settings to restrict or reject cookies. These settings will apply to all cookies on websites and emails.

Depending on your email or browser settings, cookies in an email may be automatically accepted, e.g. if you’ve added an email address to your address book or safe senders list. Check your email browser or device instructions for more information.

Third party cookies

We sometimes embed photos and video content from websites such as flickr and YouTube and pages with this embedded content may present cookies from these websites. Similarly, when you use one of the share buttons on our website, a cookie may be set by the service you have chosen to share content through. We do not control the dissemination of these cookies and your acceptance of our cookie policy includes these 3rd party cookies. You should check the relevant third party website for more information about these. We don’t sell the information collected by cookies, nor do we disclose the information to third parties, except where required by law (for example to government bodies and law enforcement agencies).

You can usually disable third party cookies by going to that third party’s website and opting out. Note that if you opt out of third party advertising cookies, you will still see advertising when using the website, however that advertising will not be tailored to you.

Cookies used by this website

Below is a list of the cookies that this website uses along with an explanation.

If you have any questions on regards to this or other policies please email legal@payexflo.com and we will be happy to assist you.