Privacy Policy

Introduction

Our privacy policy will help you understand what information we collect through our network of stores, and, online, at https://cashandchequedirect.co.uk and https://cashandchequedirect.com and how the N&Z Associates Ltd (NZA) uses it, and what choices you have.

When we talk about “NZA”, “we”, “our” or “us” in this policy, we are referring to N&Z Associates Ltd, a business registered in England and Wales (No. 07222914). Its registered office is located at 13 Northgate, Halifax HX1 1UR. N&Z Associates Ltd is an HMRC-registered Money Services Business (No. XRML00000124127), the company which provides the Services. When we talk about the “Services” in this policy, we are referring to the retail foreign exchange service that we provide, both through our network of stores, and our online services, Click & Collect and Home Delivery, offered via https://cashandchequedirect.co.uk and  https://cashandchequedirect.com (the ‘websites’). Our Services are currently available for use via a web browser or applications specific to your desktop or mobile device. “Affiliates” in this context means any entity that directly or indirectly controls, is controlled by, or is under common control with us, and “Control” means direct or indirect ownership or control of more than 50% of the voting interests of the subject entity.

This Privacy Policy sets out the basis on which any Personal Data which we collect from you, or that you provide to us, will be processed by us. In this Privacy Policy, the term “Personal Data” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, our possession, and includes personal data as described in Data Protection Legislation (as defined below).

If you do not agree to these terms you must leave our website immediately. If you choose to accept this Privacy Policy, we will keep a record of your acceptance in this regard.

We will handle your Personal Data in accordance with Data Protection Legislation. “Data Protection Legislation” means the Data Protection Act 1998 and Directive 95/46/EC, any other applicable law or regulation relating to the processing of personal data and to privacy (including the Privacy and Electronic Communications (“EC Directive”) Regulations 2003 and the Privacy and Electronic Communications (EC Directive) Amendment Regulations 2011 (“E-Privacy Regulations”), as such legislation shall be amended, revised or replaced from time to time, including by operation of the General Data Protection Regulation (EU) 2016/679 (“GDPR”) (and laws implementing or supplementing the GDPR, and laws amending or supplementing the E-Privacy Regulations).

Information we collect and receive

We fully respect your right to privacy in relation to your interactions with the Services and endeavour to be transparent in our dealings with you as to what information we will collect and how we will use your information. Also, we only collect and use individual’s information where we are legally entitled to do so. Information in relation to Personal Data collected by UK entities is available on https://ico.org.uk/, the website of the Information Commissioner’s Office (“ICO”)

Customer Data

Personal Data submitted by users to the Services (the “Customers”) is referred to in this Privacy Policy as “Customer Data.” Where NZA collects or processes Customer Data, it does so on behalf of the Customer. Depending on the service being offered, NZA collects first names, second names, customer residential addresses, email addresses, and phone numbers.

We endeavour to keep Customer Data accurate and up-to-date. As such, you must tell us about any changes to such information that you are aware of as soon as possible.

Other information

NZA may also collect and receive the following information:

• Billing and other information. For Customers that purchase Services, our corporate Affiliates and our third party payment processors may collect and store billing address and credit card information on our behalf.
• Services usage information. This is information about how you are accessing and using the Services, which may include administrative and support communications with us and information about the Services, features, content, and links you interact with.
• Log data. When you use the Services our servers automatically record information, including information that your browser sends whenever you visit a website or your mobile app sends when you are using it. This log data may include your Internet Protocol address, the address of the web page you visited before using the Services, your browser type and settings, the date and time of your use of the Services, information about your browser configuration and plug-ins, language preferences, and cookie data.
• Device information. We may collect information about the device you are using the Services on, including what type of device it is, what operating system you are using, device settings, application IDs, unique device identifiers, and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings.
• CCTV: For security reasons, for the safety of our staff, and to help prevent crime and fraud, we may collect information about you in our NZA stores via CCTV.
• Services integrations. If, when using the Services, you integrate with a third party service, we will connect that service to ours. The third party provider of the integration may share certain information about your account with NZA subject to appropriate contracts being in place with such third parties to safeguard your Customer Data. However, we do not receive or store your passwords for any of these third party services.
• Third party data. NZA may also receive information from Affiliates, our partners, or others that we use to make our own information better or more useful. This might be aggregate level information, such as which IP addresses go with which postal codes, or it might be more specific information, such as about how well an online marketing or email campaign performed.

Cookies

A cookie is a small text file that is placed on your device by a web server which enables a website and/or mobile app to recognise repeat users, facilitate the user’s ongoing access to and use of a website and/or mobile app and allows the website and/or mobile app to track usage behaviour and compile aggregate data that will allow content improvements and targeted advertising. We collate information only in relation to the Services which is represented in aggregate format through cookies. They help us to improve our Services and to deliver many of the functions that make your browser experience more user friendly.

By using the Services and accepting the terms of this Privacy Policy you are consenting to the use of cookies as described in this Privacy Policy and our Cookies Policy (i.e. you are agreeing to the placement of cookies on your device unless you specifically choose not to receive cookies).

The ‘Help Menu’ on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also disable or delete similar data used by browser add-ons, such as flash cookies, by changing the add-on’s settings or visiting the website of its manufacturer.

For more information about cookies and managing them including how to turn them off, please visit www.cookiecentral.com. However, because cookies allow you to take advantage of some of the Services essential features, we recommend you leave them turned on as otherwise you may not be able to fully experience the interactive features of the Services or other related websites which you visit.

For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy on http://cashandchequedirect.co.uk and https://cashandchequedirect.com

Aggregated Data

This Privacy Policy is not intended to place any limits on what we do with data that is aggregated and/or de-identified so that it is no longer associated with an identifiable user or Customer of the Services. We may disclose or use aggregate or de-identified information for any purpose. For example, we may share aggregated or de-identified information with our partners or others for business or research purposes.

Why We Need Customer Data

NZA needs Customer Data in order to provide the Services you have engaged us to provide. If you do not provide the Customer Data, then we will be unable to provide the Services you have requested. We will not collect any Personal Data from you that we do not need in order to provide and oversee the Services we have agreed to provide you with.

How We Use Your Information

We use your information to provide and improve the Services.

Customer Data

NZA may access and use Customer Data as reasonably necessary to (a) provide, maintain and improve the Services; (b) to prevent or address service, security, technical issues or at a Customer’s request in connection with customer support matters; (c) as required by law and (d) as set forth in our agreement with the Customer or as expressly permitted in writing by the Customer in accordance with Customer’s instructions.

Other information

We use other kinds of information in providing the Services. Specifically:

• To understand and improve our Services. We carry out research and analyse trends to better understand how users are using the Services and improve them.
• To communicate with you by:
  • Responding to your requests. If you contact us with a problem or question, we will use your information to respond.
  • Sending electronic communications. We may send you administrative electronic communications relating to the Services. We may also contact you to inform you about changes in our Services, and important Service related notices, such as security and fraud notices. These electronic communications are considered part of the Services and are made in our legitimate interest in accordance with Data Protection Legislation.

In addition, subject to your explicit consent, we sometimes send electronic communications about new product features or other news about NZA. You can opt out of these electronic communications at any time by contacting us (see ‘How to Contact Us’) below or by clicking the unsubscribe link in the electronic communication. Opting out of direct marketing will not opt you out of essential communications that we need to send to you in respect of the administration of the Services. If you opt out of our electronic communications to you, we may not be able to fully provide the Service to you.

• Protecting Customer Data. We work hard to keep the Services secure and to prevent abuse and fraud, and may contact you in this respect as necessary.

How long we keep customer data for

NZA keeps Customer Data, including any correspondence with you, for five years, as calculated from the date of your last transaction with us, after which time it will be destroyed if it is no longer required for the lawful purpose for which it was obtained. If you consent to marketing, any information we use for this purpose will be kept with us until you notify us that you no longer wish to receive this information. Any CCTV footage that we hold concerning you will not be kept for longer than 90 days.

Your rights

As a data subject, you have the following rights under Data Protection Legislation and we, as data controller in respect of Customer Data, will comply with such rights in respect of Customer Data:

1. the right of access to Personal Data relating to you;
2. the right to correct any mistakes in your Personal Data;
3. the right to ask us to stop contacting you with direct marketing;
4. rights in relation to automated decision taking;
5. the right to restrict or prevent your Personal Data being processed;
6. the right to have your Personal Data ported to another data controller;
7. the right to erasure; and
8. the right to complain to the ICO if you believe we have not handled your Personal Data in accordance with Data Protection Legislation.

These rights are explained in more detail in Schedule A to this policy, but if you have any comments, concerns or complaints about our use of your Personal Data, please contact us (see ‘How to Contact Us’ below). We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex or cumbersome, in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond). Where a response is required from us within a particular time period pursuant to Data Protection Legislation, we will respond within that time period.

Withdrawal of consent

If you no longer consent to our processing of Customer Data (in respect of any matter referred to in this Privacy Policy as requiring your consent), you may request that we cease such processing by contacting us via the ‘How to Contact Us’ facility referred to below. Please note that if you withdraw your consent to such processing, it may not be possible for us to provide all/part of the Service to you.

Sharing and disclosure

There are times when information described in this Privacy Policy may be shared by NZA. This section discusses only how NZA may share such information. We may share with third parties certain pieces of aggregated, non-personal information. Such information does not identify you individually. We restrict access to Customer Data to employees and contractors who need to know that information in order to operate, develop, or improve our Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, civil litigation and/or criminal prosecution, if they fail to meet these obligations.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access the Services, you are responsible for keeping this password confidential. We ask you not to share a password with any person not authorised to use the Service.

In particular:

Customer Data

NZA may share Customer Data in accordance with our agreement with the Customer and the Customer’s instructions, including:

• With third party service providers. We engage third party companies or individuals to process Customer Data as follows:
  • Marketing Automation Services: For marketing purposes, your Customer Data may be stored on a third-party system which provides NZA with email marketing software and marketing automation services.

Other types of disclosure

NZA may share or disclose Customer Data and other information as follows:

• During changes to our business structure. If we engage in a merger, acquisition, bankruptcy, dissolution, re-organisation, sale of some or all of NZA’s assets, financing, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence).
• To comply with laws. To comply with legal or regulatory requirements and to respond to lawful requests, court orders and legal process.
• To enforce our rights, prevent fraud and for safety. To protect and defend the rights, property, or safety of us or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud.

Third-party websites

This Privacy Policy applies to websites and services that are owned and operated by NZA. We do not exercise control over the sites/applications that may be linked from our website. These other sites/applications may place their own cookies or other files on your computer, collect data or solicit personal information from you. You acknowledge that the Services that we provide may enable or assist you to access the website content of, correspond with, and purchase products and services from, third parties via third-party websites and that you do so solely at your own risk. We make no representation or commitment and shall have no liability or obligation whatsoever in relation to the content or use of, or correspondence with, any such third-party website, or any transactions completed, and any contract entered into by you, with any such third party and the use by any such third-party of your Customer Data. We do not endorse or approve any third-party website nor the content of any of the third-party website made available via the Service. We encourage you to carefully familiarize yourself with the terms of use and privacy policies applicable to any websites and/or services operated by third parties. Please be aware that we are not responsible for the privacy practices of any third parties.