At the Sokin Group, we pride ourselves on maintaining the highest levels of security, transparency and integrity in our work, and recognise the importance of protecting and respecting your personal data.
- The information we collect
- How we use that information
- When we share information
- Your rights
- And how to get in contact.
- Lawfulness, fairness and transparency
- Purpose limitation
- Data minimisation
- Storage limitation
- Integrity and conﬁdence
Processing of your personal data
We are registered with the ICO under the Data Protection Register, and our registration number is: ZA546087.
To provide you with our services we need to know things about you. We will only collect information we need to provide you with the services you have requested and will handle your information with the utmost care. Any information we receive about you will be subject to strict controls to minimise the risk of misuse – including unauthorised access to, or disclosure of, your personal data.
Please read this notice carefully, together with our Terms and Conditions and any other documents referred to within. Here we explain the basis on which any information we collect about you, or that you provide to us, will be processed by us and other parties in providing you with the services you use.
What information do we collect? And how do we collect it?
Information you provide to us
To open an account or use The Sokin Group services, you will be asked to provide identifying information about yourself (e.g. name, address, banking details and email address), and documents to verify the information provided.
In order to make transfers/payments, you will be asked to provide the information required to facilitate the payment – e.g. beneﬁciary information, bank account details and source of funds.
Through the course of our business relationship, we may ask for additional evidence in order for us to comply with our legal obligations – e.g. anti-money laundering regulations. These can include but are not limited to, documents required to verify any information provided or evidence of source of funds.
Information we collect when you use our website or app
The Sokin Group user community participants will have their sessions recorded to allow us to capture the feedback to improve our services and help with the development of new products. This will always be based on your consent, which you can withdraw at any time.
For the detection and prevention of fraud and cyber-crime, we will collect information, including session, device and IP address to help ascertain the legitimacy of the account login.
For non-registered users, we may contact you using publicly available information or information from third parties, which you have consented to being shared, to let you know about products that could be relevant for your business.
Once your account is fully set up and you begin to transact with us, we will collect, process and store your Sokin Group ﬁnancial and transactional information. This information includes the amount, currency, type of transaction, source of funds, exchange rate, recipient name and bank details.
Information about you that we receive from third parties
To protect ourselves and our customers against fraud, we verify the information you provide with Anti-Fraud agencies and Electronic Identity Veriﬁcation Services. In the course of veriﬁcation, we receive and process information about you from such services.
Information may be collected from credit reference agencies.
All calls are recorded, and correspondence retained for the purposes of quality control and training, as evidence of transactions and to fulﬁl regulation requirements. Any information you disclose to us will be held on these recordings.
What is the purpose for processing your data?
We will process your personal data:
As necessary to perform our contractual obligations. – To ensure we process payments and fulﬁl our side of the contract, we will process transaction information, veriﬁcation information and phone recordings.
As necessary to comply with our legal obligations. – As a ﬁnancial services company, we must collect and process certain information to comply with applicable laws and regulations.
These include for:
- Completing due diligence to prevent money laundering and ﬁnancial crime
- Financial and tax reporting and bookkeeping
- Establishment and defence of legal rights
- For activities relating to the prevention, detection and investigation of crime
Information on connected parties and beneﬁciaries is used for the purpose it is collected to comply with regulations and to make payments on the Client’s behalf. We will not use this information to market to the non-registered individual unless they have speciﬁcally consented to receive these communications.
As necessary for our own legitimate interests. – The Sokin Group’s aim is to provide an excellent service. There is additional information we may collect that will help us:
- To be able to provide our customers with an excellent service – e.g. contact details, hours of availability and languages
- To notify our customers of market changes, products and The Sokin Groups event information that is relevant to them
- To provide service update notiﬁcations of any changes to our products and service that affect our customers
Based on your consent:
- To provide general product and market insight to make the most of your Sokin Group experience
- To perform market research through surveys to help improve our products
- To build a user community to provide feedback in the development and improvement of The Sokin Groups products
- To provide offers, competitions and incentives
Who do we share your data with? Banking Partners
The Sokin Group uses various banking partners around the world to ensure your payment can get to where it needs to go as quickly as possible. When you transact with The Sokin Group, we may need to share your information with payment providers or banking partners outside of the EEA, such as intermediary or beneﬁciary banks – e.g. if you ask us to make a
USD payment to China – Hong Kong the funds would be cleared through an intermediary bank in the US before reaching China – Hong Kong.
For transparency, veriﬁcation and legal requirements, we are required to include certain information on the payment, which could include:
- Your name
- Your date of birth
- Your address
- Beneﬁciary details
- Your national identity reference (e.g. passport)
If you were introduced to The Sokin Group by one of our trusted partners, we may provide them with your information to fulﬁl our contractual obligations with the partner.
Additionally, we may share your details with a trusted partner for marketing purposes if you have given your consent to do so.
We may share your information with trusted companies providing services to us under conﬁdentiality agreements or to companies that assist us in meeting our obligations to you and our regulators– e.g. the processing of card transactions or the veriﬁcation of documentation. These companies do not have any rights to market other services with you.
These trusted companies may be outside of the EEA. The Sokin Group will ensure that the company is based in a country with adequate data protection under their law, or that we impose contractual obligations or require them to be certiﬁed with a framework of protection deemed suitable by The Sokin Group. The Sokin Group performs due diligence to ensure third parties are compliant with applicable legal and contractual requirements.
Also, we may share your information with any person acting on your behalf provided that you have given us the permission to do so.
Regulators and Law enforcement
We may need to pass necessary information on to Governmental departments, regulatory bodies, the police/law enforcement agencies or other third parties where we are legally compelled to do so – e.g. if we have reason to believe an individual is acting fraudulently and using our services for an illegal purpose.
We will never sell any personal data that we hold about you.
How long do we keep your personal information for?
The Sokin Group will only retain your information for as long as is necessary for providing our service to you and will not hold or process your information for any longer than we are legally required to. The criteria used to determine the appropriate retention includes:
- Regulatory requirements The Sokin Group is subject to
- Whether a legal claim could be brought against The Sokin Group
- Necessity of information to provide our service to our customers
- The legal basis for processing – e.g. consent
Information about connected parties and beneﬁciaries, which may not belong to a Sokin Group client, are stored for a period to comply with applicable legal requirements.
We may communicate with you on a regular basis via email and phone to provide excellent customer service and fulﬁl requests.
Additionally, we use your email address, phone number and postal address to:
- Provide notiﬁcation as part of the on-boarding and trading life-cycle
- Send you important changes to our products and services
- Send notices and disclosures required by law
Due to the service-orientated nature of these communications, you cannot opt-out to receiving these.
The Sokin Group would like to keep you up to date concerning our products and services. Once you are a client of The Sokin Group, we may use your information to provide product information, and rate and market updates that are relevant to you and/or your company.
We may also use your information (whether you are a registered Sokin Group user or a visitor to our website) to keep you up to date on general products, market updates or rate movements provided you have given your consent to do so.
If you change your mind on which communications you would like to receive or how you would like to receive them, or you decide that you do not wish to receive these types of communications, you can remove your consent at any time by:
– emailing email@example.com
You will not miss out on any service we provide by not choosing to receive marketing from us, and you can change your mind whenever you like as often as you like.
What are your rights?
We recognise and support the rights outlined below that you have in relation to your personal information under Data Protection Laws. If you would like to exercise any of the below rights, then please contact firstname.lastname@example.org, and we will respond to your query within 1 month.
We will require you to provide proof of your identity and to provide suﬃcient information to allow us to locate your information.
Non-registered users (e.g. website users, connected parties and beneﬁciaries of payments) have the same rights as any registered user and can contact The Sokin Group to request these.
For more information about your rights, please visit the ICO website.
To ask for information that The Sokin Group holds about you to be corrected.
If you notice any of the information on your account is incorrect, you can contact us, and we will make any necessary changes, subject to veriﬁcation of the information.
To ask us to erase your information if we no longer have a reason to hold it
The Sokin Group will retain your information only for as long as necessary based on our obligations and business needs. This will be in line with our data retention policy. Additionally, you can request for your data to be deleted, subject to our legal and contractual obligations.
We will retain a record of your erasure request, but we will not use this information for any other purpose.
To ask for a copy of the information, The Sokin Group holds about you
You have the right to request details of the information we hold about you, a description of that data, the purposes for which it is being used and any parties with which we share your information. Where we are legally permitted to, we may decline your request or part of your request, but we will provide an explanation with the response.
To ask The Sokin Group not to further process your information.
If you make a request for us to stop processing information, we will investigate to see if there is a compelling reason for processing to continue and will discuss the conclusion of the investigation with you.
You can not object to the processing, which is a legal obligation or where we must process your information to satisfy a contract to which you are a party.
Also, you can object to marketing communications at any time.
To ask not to be subject to automated decision making and proﬁling
The Sokin Group puts people ﬁrst. There will not be any scenarios in which proﬁling or automated decision making will have a legal impact on you without a person reviewing or making a decision on the result. If you feel you may have been unfairly impacted, please contact us to discuss this further.
We store all data electronically in a secure manner to protect its conﬁdentiality, integrity and availability. Data is stored on servers which are protected by actively maintained ﬁrewalls.
We make use of up-to-date anti-virus software and our servers have restricted access.
If you provide paper-based documentation for the purpose of identity veriﬁcation, these will be stored electronically, and the original will be destroyed securely or returned to you.
Transmission of data on the internet can never be completely secure. We do not and cannot guarantee the security of information collected or transmitted electronically however, we take reasonable care to safeguard your personal information.
What if I am unhappy?
If at any time you are not happy with how we handle your information, you can make a complaint to us.
We would really like the opportunity to set things right with you, but you also have the right to raise any data protection concerns with the Information Commissioners Oﬃce directly if you are unhappy with the way we are handling your information.
If you would like to get in contact with us, please send us an e-mail to email@example.com or call us on 020 8050 3219
We may amend this policy from time to time. If we make any changes that will aﬀect you, we will be sure to let you know. This will always be published publicly on our website here.