At Navro, we strive to only collect the data that we need in order to provide you the services you use. On this basis we have different privacy policies, depending on what you are doing with us.
At Navro, we strive to only collect the data that we need in order to provide you the services you use. On this basis we have different privacy policies, depending on what you are doing with us.
1.2 Navro is made up of different legal entities, details of which can be found below:
Name of controller: Naro Payments Limited
Address of controller: 3rd Floor 86-90 Paul Street, London, United Kingdom, EC2A 4NE
Country of incorporation: England
Regulated status: Authorised Electronic Money Institution
Name of controller: Navro Payments Europe Limited
Address of controller: Block A, George’s Quay Plaza, George’s Quay, Dublin 2, Dublin, Ireland
Country of incorporation: Ireland
Regulated status: Authorised Electronic Money Institution
Navro Group Limited is responsible for this website.
Purpose of this privacy
1.4 This website is not intended for children, and we do not knowingly collect data relating to children.
Full name of legal entity: Navro UK Limited
Email address: Compliance@Navro.com
Postal address: 3rd Floor 86-90 Paul Street, London, United Kingdom, EC2A 4NE
Full name of legal entity: Navro Ireland Limited
Email address: Compliance@Navro.com
Postal address: Block A, George’s Quay Plaza, George’s Quay, Dublin 2, Dublin, Ireland
If your Controller is Navro UK Limited, you have the right to make a complaint at any time to the Information Commissioner’s Office (the “ICO”), the UK regulator for data protection issues (www.ico.org.uk).
If your Controller is Navro Ireland Limited, you have the right to complaint to the Data Protection Commission (the “DPC”), the Irish regulator for data protection issues (www.dataprotection.ie).
We would, however, appreciate the chance to deal with your concerns before you approach the ICO or the DPC so please contact us in the first instance.
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.
This website may include links to various third-party websites, plug-ins and applications.
Our website currently contains a link to our LinkedIn page and Workable, or from time to time other external sites such as news articles. Visiting a page with social media plugins may result in your data being collected by the social media or website company (depending on your browser’s configuration). This includes data such as an IP address and a record of pages you visit at the relevant time. Social media features may also set third-party cookies (or similar technologies eg tracking pixels). Social media providers linked to by the site may be considered joint controllers for the processing of this Personal Data.
The data we collect about you
2.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
2.2 We may collect, use, store and transfer different kinds of Personal Data about you, which we have grouped together as follows:
a) Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, place of birth and gender.
b) Contact Data includes billing address, delivery address, email address and telephone numbers.
c) Financial Data includes bank account and payment card details including International Bank Account Number (IBAN); credit or debit card details; credit data from credit registers; credit reference agency performance data; authorised signatory details
d) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
e) Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
f) Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
g) Usage Data includes information about how you use our website, products and services].
h) Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
Special Category Personal Data
2.4 Special Category Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.
We may collect the following Special Category Personal Data if you choose to become a client of Navro :
- Biometric Data: to uniquely identity you when you open up an account with us (for example, facial recognition by way of selfie);
- Criminal Convictions Data: we may Process this information about you in accordance with our anti-money laundering and regulatory obligations and to prevent fraud
2.5 We will only Process this information about you when it is required for the products or services we are providing to you, for reasons of substantial public interest; where you have consented or where we have a legal obligation to do so.
2.6 Apart from these two categories of Special Category Personal data above, as a general rule, Navro will not otherwise Process Special Category Personal Data and will:
a) not create any field or location in its CRM tool in which it is required that we obtain or store Special Category Personal Data ;
b) not create any field or location in which it is expected, or that an expectation is made, that we would hold Special Category Personal Data, even when such a field is voluntary;
c) not request from a controller, any Special Category Personal Data as part of our application forms or similar;
d) specifically seek to exclude Special Category Personal Data from its contracts with controllers;
e) review all agreements and processes provided by data Controllers to ensure that the data we hold is not Special Category Personal Data.
If you fail to provide Personal Data
2.7 Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Data Is collected in most cases by you providing it to us at our request. In some cases we may obtain data about you from third party firms such as marketing agencies or from public sources such as the companies registry of your country, or from Social media.
3.1 We use different methods to collect data from and about you including through:
3.1.1 Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
a) apply for our products or services;
b) create an account on our website;
c) subscribe to our service or publications;
d) request marketing to be sent to you;
e) enter a competition, promotion or survey; or
f) give us feedback or contact us.
3.1.3 Third parties or publicly available sources. We will receive Personal Data about you from various third parties and public sources as set out below:
- Publicly available sources, such as the company registry in your country
- Creditsafe and other credit referencing agencies
- LinkedIn or other professional social networking sites
- LexisNexis Bridger, which performs Sanctions and negative media searches including some criminal background checks.
3.1.4 Technical Data from the following parties:
(a) analytics providers such as Google based outside of the EU
3.1.5 Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Citi Bank, JP Morgan and Transferwise; credit reference and fraud prevention agencies such as Creditsafe etc.
3.1.6 Identity and Contact Data from data brokers or aggregators such as Creditsafe, Dun and Bradstreet and LinkedIn.
3.1.7 Identity and Contact Data from publicly available sources such as Companies House (UK), Companies Registration Office (Ireland); electoral registers and LexisNexis.
How we use your Personal Data
4.1 We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
a) Where we need to perform the contract we are about to enter into or have entered into with you.
b) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
c) Where we need to comply with a legal obligation.
4.2 Please see the paragraph below (purposes for which we will use your Personal Data) to find out more about the types of lawful basis that we will rely on to process your Personal Data.
4.3 Generally, we do not rely on consent as a legal basis for processing your Personal Data. You have the right to withdraw consent to marketing at any time by contacting us. You have the right to withdraw consent to marketing at any time by contacting us using the details set out in this policy.
Purposes for which we will use your Personal Data
4.4 We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
4.5 Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table linked here.
4.6 We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. All email newsletters or marketing emails have an unsubscribe link and all opt-outs will be actioned and respected. You can ask us to stop sending you marketing messages at any time.
Promotional offers from us
4.7 We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
4.8 You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
4.9 We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.
4.10 You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out or unsubscribe links on any marketing message sent to you OR by contacting us at any time on Compliance@Navro.com
4.11 Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product or service purchase or a product or service experience.
- Account authentication
- Security and fraud prevention
- Preference cookies for the cookie consent tool
- Load balancing
Change of purpose
4.16 We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
4.17 If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
4.18 Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your Personal Data
5.1 We may share your Personal Data with the parties set out below for the purposes set out in the table Purposes for which we will use your Personal Data above.
a) Internal Third Parties, such as companies within the Navro Group.
b) External Third Parties as set out in the Glossary.
c) Specific third parties, who may be inside or outside of the EU
- TruNarrative; For the purpose of performing AML and background checks
- LexisNexis; For the purposes of compliance with Sanctions regimes and for negative media screening
- Dun And Bradstreet; For the purpose of conducting Ultimate Beneficial ownership checks
- Creditsafe; For the purpose of conducting Ultimate Beneficial ownership checks
- Identify Providers and ID verification services; For the purposes of verifying your identity based upon documents you have provided to us, such as passports or driver’s licences.
- AWS/Amazon; For the storage of Navro data and the processing of payments
- Banking Counterparties; For the execution of payments and for the performance of contracts you have with us.
5.2 We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
5.3 We may also disclose your Personal Data for the following additional purposes where permitted or required by applicable law:
b) as part of our regular reporting activities to other members of our group of companies.
c) to comply with legal obligations.
d) if a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is absolutely necessary and we will anonymise data where possible.
5.4 Some of our external Third Parties are based outside the UK or the EU (depending on where you are located) so their processing of your Personal Data will involve a transfer of data outside the UK and/or the EU.
Whenever we transfer your Personal Data out of the UK and/or the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
a) we will transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data;
b) where we use certain service providers, we may use standard contractual clauses approved for use in the UK and/or the EU as appropriate which give Personal Data the same protection it has in the UK and/or the EU.
- Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the UK and/or the EU.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
We use the following security measures on our website:
- Malware scanning and removal
- DDoS protection
- SSL/TLS encryption
- Two-factor authentication
- Daily backups
- Security audits and monitoring
- Automatic updates
- Isolation of accounts
- Secure SFTP/SSH access
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my Personal Data for?
7.1 We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
7.2 To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
7.3 In the UK for example, by law we have to keep basic information (including Identity Data, Contact Data, Financial Data and Transaction Data) about our clients, their directors, partners and ultimate beneficial owners and beneficiaries for five years after they cease being clients for the purpose of compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
7.4 We are required to retain certain data (relevant for anti-money laundering, regulatory and due diligence purposes):
a) for a minimum of five years from the date at which it ceases to trade with a client.
b) for prospective clients (including those who do not pass the due diligence checks), five years from the date of rejection of their application
7.5 At the end of the five-year period, we must delete any Personal Data contained in our records unless:
a) it is required for any anticipated legal proceedings; or
b) we have the consent of the person to whom the Personal Data relates.
7.6 Where there is no ongoing activity with a client and no balance held, Navro will consider an account to be closed 18 months from the date of its last transactions with a client. Navro will delete data held on accounts five years from the date of its last trade with a client.
7.7 Personal Data in the CDD information and transaction data must be deleted after a maximum of ten years.
7.8 Under section 108I of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 as amended, we are required to retain records for a minimum of six years from the date of the last dealing with the customer or from the date the record is made.
In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
In some circumstances you can ask us to delete your data: see paragraph Your legal rights below for further information.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. Please click on the links below to find out more about these rights:
a) Request access to your Personal Data.
Commonly known as a “Data Subject access request”. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
b) Request correction of your Personal Data.
You have the right to request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
c) Request erasure of your Personal Data.
This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. For example, we are required by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 to keep information on our clients for five years after our business relationship with that client has come to an end.
d) Object to processing of your Personal Data.
You have the right to object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
e) Request restriction of processing your Personal Data.
This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
f) Request transfer of your Personal Data.
You have the right to request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
g) Right to withdraw consent. You have the right to withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent
If you wish to exercise any of the rights set out above, please contact us at 020 4571 4244 or Compliance@Navro.com
No fee usually required
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Glossary (Definitions and Terms)
“CDD” means Client Due Diligence;
“Consent” of the Data Subject means any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data. It is responsible for establishing practices and policies in line with Data Protection Legislation. We are the Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes;
“Criminal Convictions Data” means personal data relating to criminal convictions and offences, including personal data relating to criminal allegations and proceedings
“Data Subject” means the identified or identifiable living individual to whom Personal Data relates;
“EDD” means Enhanced Due Diligence;
“FCA” means the Financial Conduct Authority;
“EU GDPR” means the General Data Protection Regulation ((EU) 2016/679) of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (General Data Protection Regulation) as it has effect in European Union law;
“UK GDPR”: has the meaning given to it in section 3(10) (as supplemented by section 205(4)) of the Data Protection Act 2018;
“KYC” means Know Your Client;
“Legal Basis for Processing” means the lawful bases for processing as set out in Article 6 of the GDPR and UK GDPR. At least one of these must apply whenever Navro process Personal Data. We must also provide this data to the client so that they understand what data we are processing, and why:
a) “Consent” means that the individual has given clear consent for you to process their Personal Data for a specific purpose.
b) “Contract” means that the Processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
c) “Legal obligation” means that the processing is necessary for you to comply with the law (not including contractual obligations).
d) “Vital interests” means the processing is necessary to protect someone’s life.
e) “Public task” means that the Processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
f) “Legitimate interests” means that the Processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s Personal Data which overrides those legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law);
“Personal Data” means “any information that relates to an identified or identifiable natural person” or individual (‘Data Subject’) (Article 4 GDPR); or “any information relating to an identified or identifiable living individual” (Section 3(2) DPA 2018)”.
“Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed;
“Special Categories of Personal Data” includes any data we hold which is Personal data about an individual’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or conditions, sexual life, sexual orientation, biometric or genetic data. Any use of sensitive Personal Data must be strictly controlled in accordance with this policy. Any Criminal Convictions Data which we hold will also be considered to be special category of Personal Data.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties
Other companies in the Navro Group who are based in the UK and Ireland (as applicable) and provide IT and system administration services and undertake leadership reporting.
External Third Parties
a) Service providers based in the EU who provide IT and system administration services;
b) Professional advisers including lawyers, bankers, auditors and insurers based in the UK and Ireland who provide consultancy, banking, legal, insurance and accounting services;
c) Financial institutions, banks, other payment service providers and institutions for the provision of payment services.
d) HM Revenue & Customs (UK), Revenue Commissioners (Ireland), Information Commissioner’s Office (UK), Data Protection Commission (Ireland), Financial Conduct Authority (UK), Central Bank of Ireland, and other regulators and authorities based in the UK and/or the EU.