© 2019 by Totipay.

Suit No A
Radclyffe House
66-68, Hagley Road Edgbaston, Birmingham
B16 8PF
United Kingdom 

 

Email - info@totipay.com

Contact
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Totipay is authorised by the Financial Conduct Authority (FCA) has been granted to carry out payment services activities, under the Payment Services Regulations 2009. 

 

MLR: XXML00000133439
FCA: 759649
Company House: 10338529

Privacy Policy

Welcome to the Totipay Ltd website (hereinafter referred to as "TOTIPAY") www.totipay.com. 
Protecting your privacy is very important to us. Therefore the purpose of this Policy is to inform our customers and other individuals ("you" or "your") how we deal with, collect, use, disclose and protect your personal information. This Policy applies to our collection of, use of and disclosure of, personal information in the United Kingdom. 
This Policy does not apply to information about our employees or to information that is not personal information. You can be assured that TOTIPAYalwaystake steps to comply with the privacy principles and requirements under applicable UK privacy legislation. This policy is applicable to all TOTIPAY consumers and visitors who visit our website. www.totipay.com

Personal Information The personal information that we collect is information about an identifiable individual, as described under applicable privacy legislation. 
TOTIPAY collects personal information about you from a variety of sources in the course of providing you with money transfer service and other related products and services, which include the following: 
We collect personal information when you ask us to send money or to provide other any other Service to you. This personal information may include identities and contact information of senders and recipients of money transfers or payments, credit card, banking or other billing information, birth dates and other personal identifiers such as Passport details, Driving License or other such governmental identification. 
Information is used to verify your identity for security and fraud prevention purposes, identification numbers and amounts paid, transferred, exchanged or otherwise processed. We collect information about your transactions with us, including transaction history, such as frequency of use and amounts paid, transferred, exchanged or otherwise processed and any rewards program account information, if any. 
verification, fraud prevention In
and similar security purposes, we collect and/or confirm certain identity-related information, financial background and similar information through third parties sources such as government agencies and consumer reporting agencies. 
We may collect personal information otherwise with your consent or as permitted or required by law.connectionwith
identify

 

Use of Personal Information
We generally use personal information for the purposes of providing you the Service. 
This may include the following purposes: 

Authorising and processing your transactions, including effecting and administering money transfers, and ensuring proper payment to the designated recipient of funds. Collecting amounts owing to us, and otherwise enforcing and collecting on your accounts or agreements with us. Meeting legal, regulatory, self-regulatory, risk management, fraud prevention and security requirements, which may include (among other measures) verifying the identity of the customer and receiver of funds and checking identities against money laundering, terrorist financing or similar watch lists established by regulatory agencies or similar bodies in the UK or in other countries. For identity verification purposes, customers and receiver of money transfers may be required to produce valid identification or consent to verification by other means. Maintaining business and transaction records for reasonable periods, and generally managing and administering our business. 
Meeting insurance, audit and processing requirements. 
Otherwise, as permitted or required by law. 
There may be circumstances in which TOTIPAY is obliged to collect, use, or disclose certain personal information without your consent. Such circumstances include:

A serious and imminent threat to someone’s life, health or safety.

  1. A serious threat to public health or public safety.

  2. Unlawful activity has been, is being or may be engaged in.

  3. If TOTIPAY reasonably believes that the use or disclosure is necessary for the prevention, detection , investigation, prosecution or punishment of:

    • Criminal offences, breach of law, imposing of penalty or sanction or breach of a prescribed law.

    • the enforcement of laws relating to the confiscation of the proceeds of crime.

    • the protection of the public revenue;

    • the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct; or

    • the preparation for, or conduct of, proceedings before any Court or Tribunal, or implementation of the orders of a Court or Tribunal.

If TOTIPAY is obliged to use or disclose your personal information as herein mentioned, it will create a written report of the use or disclosure. 
We store information that we collect through cookies, log files, and/or third parties to create a profile of our users. Consequently, collected information is used to improve the content of the site for the user. 
If we make changes to any of our Privacy Policies or practices with respect to how we use personally identifiable information, we will post those changes with or without notice to this Privacy Policy as and when they come into effect. 
In some
cases we may be required to disclose certain information to comply with a legal process, such as a court order, subpoena or search warrant.

 

Disclosure of Your Personal Information
We may disclose your personal information to our affiliate partners and to unaffiliated third parties in connection with the purposes described in this Privacy Policy as follows:

  • To Provide Services: In order to process and complete the requested Service, we may disclose personal information to the recipient of a money transfer, to our agents or affiliates, and, if applicable, the recipient and any intermediary banks or other financial institutions or financial services companies involved in the transaction or our Service.

  • Service Providers: We may transfer personal information to outside agents or service providers (including our affiliate partners acting in this capacity) that perform services on our behalf, for example, information technology and/or data hosting or processing services. Some of these service providers or affiliate partners may be located outside the United Kingdom, and your personal information may be collected, used, disclosed, stored and processed in the United Kingdom or elsewhere for the purposes described in this Privacy Policy. 
    We take reasonable measures to ensure that personal information that may be processed by these service providers on our behalf is protected and not used or disclosed for purposes other than as directed by us, subject to legal requirements in the UK and other foreign countries applicable to our affiliates, agents and service providers, for example lawful requirements to disclose personal information to government authorities in those countries.

  • Business Transactions: Your personal information may be used by us and disclosed to parties connected with the contemplated or actual financing, securitisation, insuring, sale, assignment or other disposal of all or part of our business or assets (including, for example, your account with us), for purposes related to the evaluation and performance of these transactions, including:

  • permitting such parties to evaluate and determine whether to proceed or continue with the transaction, and

  • fulfilling reporting, inspection or audit requirements or obligations to such parties. Our successors and assignees and/or its business or assets may use and disclose your personal information for similar purposes as described in this Privacy Policy.

  • Legal, Regulatory, etc: TOTIPAY may disclose your personal information as necessary to meet legal, regulatory, self-regulatory, insurance, audit, and security requirements, and as otherwise with your consent or as permitted or required by law (including as required by applicable UK and foreign laws).

 

UK Financial Conduct Authority (FCA) require all financial institutions including TOTIPAY to verify but not limited to the identity of the customer, purpose of transaction and source of funds. To comply with these regulatory requirements, we will be comparing, which also include sharing the information that you have provided such as but not limited to Name, Address, Driver's license number and any other information contained in your consumer report, with available and reputable ID verification service provider. Such agency will only use the information in your consumer report for the purpose of validating your identity and no other. 


If we are unable to validate your identity through the on-line process, you will be directed to an alternative, off-line process. Additional documentary proof might be required for establishing the source of funds. 
Our services have also been regulated by the HMRC and comply with money laundering regulations.

 

Your Consent
Consent to the collection,
use
and disclosure of personal information may be given in various ways. Consent can be express (for example, orally, electronically or on a form you may sign describing the intended uses and disclosures of personal information) or implied (for example, when you provide information necessary for a service you have requested). 


You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an "opt out" option provided, if any. Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). Generally, by providing us with personal information, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or described in this Privacy Policy, if applicable, or otherwise at the time of collection. 


You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. Note that if you withdraw your consent to uses of your personal information, we may no longer be able to provide certain Services. Note also that where we have provided or are providing services to you, your consent will be valid for so long as necessary to fulfill the purposes described in this Privacy Policy or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, but not limited to, maintaining reasonable business and transaction records and disclosures to UK and foreign government entities as required to comply with laws). 
TOTIPAY collects, uses and discloses your personal information with your consent, except as permitted or required by law. We may be required or permitted under state laws, federal laws, or foreign statute or regulation to collect, use or disclose personal information without your consent, for example to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us. 

Security
TOTIPAY takes all reasonable steps to protect your personal information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our custody or control, which may include safeguards to protect against loss or theft, as well as unauthorised access, disclosure, copying, use or modification. Our authorised employees, agents and subsidiaries who require access to your personal information in order to fulfill their job requirements will have access to your personal information. 


We have in place a range of security safeguards to protect your personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification, regardless of the format in which it is held. 


TOTIPAY work to protect personally identifiable information stored on their site’s server from unauthorised access using commercially available and industrially acceptable standards of computer security products, such as firewalls, as well as carefully developed security procedures and practices. In addition, a username and password are generally required for you to use, view or change application or interview information. We use both internal and external resources to review the adequacy of security measures on a regular basis. 


TOTIPAY ensures that all staff are aware of the importance of maintaining the confidentiality of personal information.

Access, Correction and Contacting Us
TOTIPAY will upon request allow you to access to your personal information. The requested information shall be provided or made available in a form that is generally understandable. In circumstances where you point out to us that any information held by us is inaccurate or incomplete, we will take appropriate action to amend the information as required and, if necessary, notify any third party of the correction.

There may be circumstances which preclude TOTIPAY from providing access to some or all of your personal information. Those circumstances could be:

  • The information may contain references to other individuals;

  • Legal, investigative, security, or commercial proprietary reasons; or

  • The information is subject to solicitor/client or litigation privilege.

 

This Privacy Policy
Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our websites. 
Legal Disclaimer

This Privacy Policy may be revised from time to time. If we intend to use or disclose Personal Information for purposes materially different than those described in this Policy, we will make reasonable efforts to notify affected individuals, if necessary, including by revising this Privacy Policy. If you are concerned about how your personal information is used, you should contact us as described above to obtain a current copy of this Privacy Policy. We urge you to request and review this Privacy Policy frequently to obtain the current version. Your continued provision of personal information or use of our services following any changes to this Privacy Policy constitutes your acceptance of any such changes.
Privacy Policy Changes

or telephone us at +44 - 7508084715. If you wish to make inquiries or complaints or have other concerns about our personal information practices, you may write to us as described above, e-mail us at
lastmodified April 25, 2018.info@totipay.com ;
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