Privacy Policy

We understand how important your personal data is and are committed to protecting and respecting your privacy.

www.transferholdingco.com is the main website for the Transfer Holding Co. This Privacy Policy explains how Transfer Holding Co collect, use and protect your personal information across our brands. References to "we", "us" or "our" are to the relevant Data Controller processing your personal information.

By using this site you consent to this Policy, including your consent to our use and disclosure of information about you in the manner as described in this Policy.

How we collect your personal data

We may collect and process the following personal data about you:

Information you provide to us

  • By filling in forms on our website(s) so that we may contact you;
  • By corresponding with us by phone, e-mail, live-chat, social media channels or otherwise;
  • Application/registration forms/identification documentation;
  • Entering competitions, promotions or surveys; and
  • When you report any problem or complaints with our website, products and services.

Information we collect about you

  • Information about when you logged onto our website(s), including your IP address, information about your visit, your browsing history, and how you use our website;
  • Information on what you view, click on and access in and through our marketing emails. This may include the geographic location of the device you have used;
  • If you contact us via social media, we may collect details from your social media account.

Information we receive from third parties

  • As part of our identity and financial crime checking procedures with credit reference agencies, fraud detection agencies and registration or stockbroking industry exchanges;
  • From third parties when you have instructed or agreed for them to pass information to us, such as:
    • From online advertising networks (for example Google) through whom we place advertisements. The information we obtain varies from network to network.  It often summarises the actions of lots of people and so does not enable us to identify you individually.  It relates to what you view, click on, and access through websites in their network, including the subject matter of the website you started at and where you subsequently go.  It might also include their analysis of your behaviour across the wider internet and a profile of you.
    • From social networks (for example Linkedin) where your account privacy settings allow us to validate and complete our records, as well as track information such as displaying and click on advertisements based on previous browsing history on this website.

You can block or delete cookies using settings options in your browser (the software you use to access websites). If you do this some features on this website may not work correctly. This website, like many others, does not respond to Do Not Track ('DNT') requests made through browser settings.

We will only collect and use special category information if the law allows us to do so.

Keeping your personal data up to date

The personal data we hold may include your name, postal address, email address and phone number, date of birth, financial information and employment details to enable us to contact you and respond to your enquiries as well as provide you with information about our products and services.

It is important to us that the personal data we hold about you remains accurate and up to date at all times, but we need your help in doing this.  Please let us know as soon as anything needs updating or correcting.

Other people’s personal data

The information you give us, or that we collect through your use of our services, may contain your or another person’s personal data.  If you provide us with information about another person, you confirm that they have appointed you to act for them, they consent to you providing their personal data to us and any processing of their personal data and that you have informed them of our identity and the purpose for which their personal data will be processed – as set out in this Privacy Notice.

Why we collect your personal data

We demonstrate why and how we use your personal data as well as providing the legal reasons which we rely upon.

  • Provision of services, including the administration and management of customer records;
  • To manage and operate your account with us to facilitate the provision of services, this includes retaining records of your instructions and telephone calls and keeping your account records up to date;
  • To respond to any data rights that you invoke;
  • To complete any transaction that you instruct us to undertake, and any legal obligations we have in relation to the transactions;
  • To keep our websites and portals secure and permit you safe access to our services.

If you choose not to give personal information

We need to collect personal information required by law or under the terms of service you have elected to use.  If you choose not to give us the personal data we need, it can mean that we must cancel or decline a service that you request or have with us.

How long we hold your personal data for

Personal data will not be retained for longer than necessary for us to achieve the purpose for which we obtained your personal data.  We will then either securely delete it or anonymise it so that it cannot be linked back to you. We review our retention periods for personal data on a regular basis.

The conditions under which we may share your personal data with others

The personal data we hold about you is confidential, and we will only share your personal data to enable us to deliver our product(s) or service(s), examples are as follows:

  • At your request, or with your consent;
  • Other companies who help us deliver our products and services,
  • Non-entities, in connection with running accounts and services for you, including:
  • Service suppliers to facilitate website, email, IT and administration services;
  • Our professional advisors, for example, our lawyers and technology consultants, when they need it to provide advice to us;
  • Your employer or agent(s), in accordance with any specific instructions you provide to us;
  • Market Research Agencies to measure or understand the effectiveness of advertising we serve to you and others.  We may do this ourselves or appoint an agency to do this on our behalf.  This will include your use of social media sites.
  • Credit reference agencies and fraud detection agencies as part of our identification procedures.
  • Fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment.
  • Your Official Receiver or appointed insolvency practitioner if we receive notice of your insolvency, bankruptcy or insolvency proceedings/arrangement.

We will only transfer your personal information to trusted third parties who provide sufficient security guarantees and who demonstrate a commitment to compliance with applicable law and this policy.  Where third parties are processing personal information on our behalf, they will be required to agree, by contractual means, to process the personal information in accordance with the applicable law. This contract will stipulate, amongst other things, that the third party and its representatives shall act only on our instructions, or as permitted by law.

We are also required to share your personal data with external third parties as follows (but not limited to):

  • Regulators and supervisory authorities as part of our legal obligations;
  • Where the law requires or permits disclosure, or there is a duty to the public to reveal it;
  • When we need to defend or exercise our legal rights or those of a third party;
  • Debt collecting, debt chasing or another agent for enforcing payment of monies owed to us;
  • Efforts to trace you if we lose contact with you;
  • Police and other law enforcement agencies for the prevention and detection of crime and where a valid permission is applicable;
  • As a result of a court order or other regulatory instruction; and
  • Our insurers and insurance brokers where required for underwriting our risks and as part of ongoing risk assessments.

We may transfer your personal data to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. At all times, we will take steps to ensure your privacy rights continue to be protected as per this Privacy Notice.

Overseas Processing

Data processors who are third parties providing services to us.  We have contracts in place with our data processors which means they cannot do anything with your personal data unless we have instructed them to deliver that service for us, and if applicable, to you.  Some third parties are outside of the UK or EEA which may mean that personal data is transferred or accessed where those third parties (processors) operate.

How we keep your personal data secure

We understand how important your personal data is to you and we take its security very seriously.

We safeguard your personal data across all our computer systems, networks, websites and offices as much as possible through appropriate procedures and technical security measures.

We also use secure ways of communicating with you such as when collecting your personal data or providing your account information:

  • online through the use of security and encryption protocols.
  • before we discuss matters relating to your account(s) by telephone we will always ask you security questions to confirm your identity.

Where we have given you (or where you have chosen) a password or unique identifier (PIN) which enables you to access certain parts of online services, you are responsible for keeping this password/ PIN confidential, along with any username. We will never ask for your full password or PIN, and you must not divulge your full password to us or anyone else.  We recommend that any password or PIN you set is not easy to guess and is changed frequently.

Because we cannot guarantee the confidentiality of personal data sent on the internet you should never send your login details via email nor SMS.

Your personal data rights and how to exercise them

You have rights in respect of the personal data that we hold about you.  They include the right to request a copy of the information that we hold about you, or in certain circumstances your data to be deleted from our systems. If you would like to exercise any of your rights under relevant data protection legislation then please contact our Data Protection Officer using the details provided at the end of this Privacy Notice.

If you wish to raise a complaint on how we have handled your personal data, please contact our Data Protection Office.

If you remain unsatisfied with our response or believe we are not processing your personal data in accordance with the law, you are able to contact the data protection authority in your country.

In the US, it is the Federal Trade Commission (FTC) who regulates Data Controllers compliance with data protection legislation. They can be contacted by post: Federal Trade Commission, 600 Pennsylvania Avenue, NW, Washington, DC 2058 or by calling: 1-877-FTC-HELP (382-4357).