Privacy Policy

Important notice about how we handle your personal information.

This Privacy Policy describes how FD121 Limited (FD121, we, us or our) collects, uses, stores, shares, processes, discloses, and protects your information when you use our Services (as defined below).

The Services shall mean all services provided by FD121 Limited pursuant to the FD121 Account User Agreement and FDD Terms, and all other communications or other engagement between you and FD121, which may be subject to change from time to time.

References to you or your include the representatives or delegates who act on behalf of Users of FD121 Accounts.

This Privacy Policy provides a general overview of our privacy practices regarding your information. It is important that you read this Privacy Policy.

  1. The Data We Collect About You

    Personal data means any information (a) relating directly or indirectly to a living individual; (b) from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and (c) in a form in which access to or processing of the data is practicable. It does not include data where the identity of the individual has been removed such that they cannot be identified (anonymous data).

    We may collect, use, store, process, and transfer different kinds of your personal data:

    1. Identity Data includes first name, middle name, maiden name, last name, title, tax ID, marital status, date of birth, gender, identity document number, nationality and any other information contained in any identification documents you provide to us.
    2. Contact Data includes billing address, residential address, email address and telephone numbers.
    3. Financial Data includes bank account details.
    4. Transaction Data includes details of Services activity such as the amount, date, time, recipient for each transaction.
    5. Technical Data includes your internet protocol (IP) address, 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 the Services.
    6. Profile Data includes your username or similar identifier, password, your preferences, feedback and any survey responses.
    7. Usage Data includes information about how you use the Services.
    8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
    9. Survey and Customer Feedback Data includes information you provide in any survey or feedback forms on Services.
    10. Location Data includes information about your device location.

    We also collect, use and share for any purpose aggregated data such as statistical or demographic data.

    1. Verification and Compliance Checks

      During registration for a FD121 Account or otherwise during the course of your use of the Services, we may perform certain verification or compliance checks. We carry out these checks in order to detect or prevent any unlawful or fraudulent acts and to comply with our legal obligations.

    2. If You Fail to Provide Personal Data

      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 (i.e. to provide the Services to you). In this case, we may have to close the FD121 Account or limit or restrict your access to other Services, in accordance with the terms of the FD121 Account User Agreement, but we will notify you if this is the case at the time.

  2. How We Collect Your Personal Data

    We use different methods to collect data from and about you including through:

    1. Direct interactions. You may give us your Identity, Contact, Financial, Transaction, Profile, Usage, Marketing and Communications, and Location Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when:
      1. you create or use the FD121 Account;
      2. you send a wire transfer to FD121;
      3. we need to request more information to verify your identity or to meet our legal obligations;
      4. you request marketing to be sent to you;
      5. you participate in a survey; or
      6. you give us some feedback.
    2. Automated technologies or interactions. When you interact with our Services, we may automatically collect Usage and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
    3. Third parties or publicly available sources. We may receive personal data about you from various third parties including:
      1. Technical Data from analytics providers;
      2. Contact, Financial and Transaction Data from providers of technical or payment services;
      3. Identity and Contact Data from verification or compliance services providers; and
      4. In providing personal data of any individual (other than yourself) to us, you agree that you have obtained consent from such individuals to disclose their personal data to us for processing.

  3. How We Use Your Personal Data

    We collect all of the information in Section 1 (The Data we Collect About You) so that we can provide you with the Services. The information we collect allows us to:

    1. Deliver the full functionality of the Services;
    2. Keep in touch with you - whether it be for providing customer service, notifying you of new features or updates to the Services, or providing security notices or information;
    3. Verify your identity so that we can prevent fraud or unauthorized activity, and to comply with applicable laws; and
    4. Fulfill any other purpose for which the information was collected.

    We will never share, sell or rent your personal data to third parties. We may combine your information with information we collect from other companies and use it to improve and personalize the Services, as well as our content and advertising.

  4. Purposes for Which We Will Use Your Personal Data

    We have set out below a description of the ways we plan to use your personal data:

    1. To create and register the FD121 Account.
    2. To deliver the full functionality of the Services.
    3. To manage our relationship with you which will include notifying you about changes to our terms or Privacy Policy; and asking you to take part in surveys.
    4. To verify your identity and detect and prevent fraudulent or other unauthorized activities.
    5. To administer and protect the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
    6. To deliver relevant website and platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
    7. To use data analytics to improve our website, platform, services, marketing, customer relationships and experiences.
    8. To improve our product or services and develop new products or services.
    9. To make suggestions and recommendations to you about products or services that may be of interest to you through marketing communications.
    10. To comply with laws, rules or regulations that are applicable to us.
    11. To meet disclosure requirements or respond to requests from our regulators or other government authorities in compliance with applicable laws and regulations.
    12. To commence, defend or otherwise participate in any legal or administrative proceedings or inquiry before any court or competent authority.

  5. Change of Purpose

    We will only use your personal data in accordance with the purposes described in this Privacy Policy and as provided for under applicable law for the purposes for which we collected it. If we need to use your personal data for a new purpose or a purpose unrelated to the original purpose, we will seek your express consent.

  6. Third-party Links

    The Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We are not responsible for the data collection and processing practices of the third party and use of any third party websites is subject to their privacy policies. When you leave our website or platform, we encourage you to read the privacy notice of every website you visit.

  7. Marketing

    1. Marketing Communications from Us

      We may use your Identity, Contact, Technical, Profile and Usage 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).

      You will only receive marketing communications from us if you have requested such information from us or provided us with your details when you registered for a promotion and you have opted in to receiving that marketing.

    2. Opting Out

      You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

  8. Cookies

    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website and platform may become inaccessible or not function properly.

  9. How We Share Your Personal Data

    1. Sharing with Third Parties

      We may have to share your personal data with the parties set out below for the purposes set out in Section 4 above:

      1. Banking partners.
      2. Verification service providers and credit bureaus.
      3. Our agents, contractors, and service providers, including service providers for depositary or custodial services, data storage, onboarding, customer service platforms, accounting and invoicing, IT, communication channels, security, fraud detection, and other third parties to whom we outsource our functions.
      4. Law enforcement agencies, governmental bodies, authorities and regulators.
      5. Our group companies.
      6. Our business partners.
      7. Professional advisers who provide consultancy, banking, legal, compliance, insurance or accounting services to us
      8. Actual or proposed assignee or participant or sub-participant or transferee of, or any person taking or wishing to take over, all or any part of our assets or business.
      9. Other third parties whom you specifically authorize us to do so.
      10. Any other persons under a duty of confidentiality to us for any of purposes set out in Section 4.

  10. International Transfers

    We may transfer your personal data to other countries, which may have adopted different data protection standards. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer.

  11. How We Protect Your Personal Data

    We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to data centers and information access authorisation controls.

  12. Data Retention

    We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

  13. Changes to the Privacy Policy and Your Duty to Inform Us of Changes

    We may change this Privacy Policy from time to time. When we do make updates, we will let you know by changing the date at the top of this Privacy Policy. If it is a more extensive or significant update, we will send you a notification or post a notice on our website and platform. If you ever have any questions about changes made to the Privacy Policy, just reach out to us.

  14. Your Right to Request Access and Correction to Your Personal Data

    You have the right to check whether we hold your personal data and access such data; and to require us to correct any personal data relating to you that is inaccurate.

    If you wish to exercise any of the rights set out above, please contact our data protection officer at [email protected].

    You may charge a reasonable fee for your access and correction of your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive, we may refuse to comply with your request in these circumstances.