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Privacy policy

PRIVACY POLICY

Last Updated: 11 Mar 2025

 

This Privacy Policy explains how your personal data is used and shared when you browse the Website, create an Account, contact us, or otherwise provide your personal data through the Website or the System.  It also contains important information about your privacy rights. Please read it carefully. If you provide personal data on behalf of someone else, you are required to inform them about the processing of their data and to refer them to this Privacy Policy.  

 

Our Website is: https://www.sterliqpay.co.uk/ 

 

The Data Controller of the Website is: STERLIQPAY LTD, company number: 16286931, address: Northway House 257-258 Upper St, Highbury & Islington, London, United Kingdom, N1 1RU.

 

Our contact e-mail address is: support@sterliqpay.co.uk 

 

The terms mentioned herein, if not explicitly stated otherwise, have the same meaning as defined in the Terms and Conditions.

  1. INFORMATION WE COLLECT AND HOW WE USE IT

    1. Account opening for individuals. The Service Provider requests that you, the Customer, provide certain personally identifiable information when using our Services. This information may include your full name, email address, phone number, address, postal code, date of birth, place of birth, citizenship, ID/passport number, personal code, financial account details, and your (or your relatives’) status as a politically exposed person (PEP). This data is used to contact or identify you. Additionally, the Service Provider may collect information about you and your business from third parties for identification and verification purposes, as required by law. Providing personal data is mandatory for account opening. Without this information, we cannot provide our services to you.  

    2. Account opening for legal entities. To open a company account, we require the contact person's full name, position, phone number, and email address. Additionally, we must collect the following personal data for the company's beneficial owner (UBO): full name, date and place of birth, ID number and country of issue, citizenship, PEP status (of the UBO or their relatives), source of income, residential and postal addresses, email address, and phone number..

    3. Third party data. In order to verify Customers’ identity and to perform other obligatory “know your customer” (KYC) procedures such as checking customers’ PEP status, we rely on third party service providers. Customer data, including facial photographs, ID document photographs, identity check status, involvement in court proceedings or relevant criminal records, applicable sanctions, and PEP status, may be received from third-party service providers.

    4. Transaction information. In terms of usage of the Services the Service Provider saves your information such as transaction type, transaction amount, payer’s details (such as card, name, email), address transaction comes from/sent to for the purpose of implementing the Services.

    5. Usage data. The Service Provider may also collect information about how the Service is accessed and used (hereinafter Usage Data). This Usage Data may include information such as Your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of the Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. This information is used by the Service Provider for the operation to increase the quality of the service, and to provide general statistics and analysis regarding use of the Website as well as for checking unauthorized access.

    6. Additional Information. If the Service Provider encounters any issues verifying the information you have provided, they may request additional documentation about you and your business. These documents may include a Resolution of Directors, Disclosure of Shareholders, proof of business existence (issued within the last 6 months), a utility bill (issued within the last 3 months), or a bank statement. The Service Provider may ask that you send these documents by email or post.

    7. Cookies. A cookie is a small data file that the Website writes to your device when you browse it. A cookie enables the Website to remember your actions and preferences over a period, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another. Cookies may be stored in the following cases:

      1. If you leave a comment on our Website you may opt-in to saving your name, email address and Website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

      2. If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.  

      3. When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year.

      4. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.  If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

    8. Pixel Tags. We also use similar technologies such as ‘pixel tags’ and ‘JavaScript’ to undertake these tasks. Pixel tags and JavaScript are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our Website or opened an e-mail that we have sent them.  JavaScript and some of the similar technologies we use can also be disabled on your device settings or browser, but this may significantly impact the ability for our websites, mobile sites, or mobile apps to work on your devices.

    9. Flash Cookies. Our Website may also use so-called "Flash Cookies" to, among other things, collect and store information about your use of our services, fraud prevention and detection and for other site operations, such as adverts and video. Flash Cookies are also known as Local Shared Objects or "LSOs", and are used on sites using Flash Player to store user data.  If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash Player to block Flash Cookies storage using the tools contained in the Website Storage Settings Panel. You can also control Flash Cookies by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash Cookies, how to prevent Flash LSOs from being placed on your computer without your being asked, and how to block Flash Cookies that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash Cookies may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our services or online content.

    10. Change of purpose. We will generally only use your personal data for the purposes for which we collected it. 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. 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.

  2. WHO WE SHARE YOUR DATA WITH

    1. Trusted service providers. We may share your personal data with our trusted services providers when they provide services to us, to you on behalf of us and under our instructions. We will control and shall remain responsible for the use of your personal data at all times. These are the categories of entities that may have access to your personal data: 

      1. Providers of information technology services such as hosting services; 

      2. Providers of KYC and fraud prevention services; 

      3. Other professional service providers such as accountants, legal consultants, audit firms etc. 

    2. Independent data controllers. In some cases, where you provide your personal data to third parties, those third parties may process your personal data as independent data controllers. In such cases, we are not responsible for processing of your personal data performed by third parties. To protect your privacy, we urge you to carefully read privacy notices of any such third parties.

    3. International transfers. We may share personal data internally within Data Controller’s subsidiary, affiliated and partner companies or with third parties for purposes described in this Privacy Policy. Personal data collected within the European Economic Area (“EEA”) may, for example, be transferred to countries outside of the EEA for the purposes as described in this Privacy Policy. We utilize standard contractual clauses approved by the European Commission, adopt other means under European Union law (such as, where applicable, corporate binding rules), and obtain your consent to legitimize data transfers from the EEA to the United States and other countries.

    4. Aggregated data. We may create aggregated data for internal use or for improving Services and creating new features. Aggregated data is anonymous and is not linked to any personal data. Aggregated information helps understand trends and customer needs so that new products and services can be considered and so existing products and services can be tailored to customer desires. We may share such aggregated data with our partners, without restriction, on commercial terms that we can determine in our sole discretion.

    5. Automated decision making (“ADM”). ADM is used when a decision is made solely on automated processing (including profiling) which produces legal effects or significantly affects an individual. We do not use ADM when a decision has a legal or similar significant effect on an individual unless (a) you provide us with your consent, (b) ADM is authorized by law or (c) ADM is necessary for the performance of or entering into a contract you have with us. We use ADM for:

      1. recommending additional Services to you.

      2. blocking or limiting features for the Customers when we detect prohibited behaviour under our Terms and Conditions.

      3. chargeback fraud alert and prevention, based on the information about conflicting location and engagement in fraud.

      4. Some of our support functions, like requests to change your profile information, update your payment method, actualise subscription details, etc., may be processed by our AI-based chatbot. The chatbot will always request for your consent for a particular action, and its activities will be logged in our files.

If you believe that ADM acted inappropriately or want to be serviced by a human, please contact  our support team via the email address indicated above.

  1. AI Functions. Our Service may offer you different AI-based functions, like suggesting possible answers in chat, automatic information verification or translation of live conversations. This list may be enlarged in future. For that purpose we may transfer your respective data to the relevant AI model provided to us by the trusted partner. Your data are safe and will be processed only for the purposes of providing the respective services to you.

  2. Cross-device tracking. If you login to your Account with us using multiple devices (for instance, your phone and laptop), we will link your devices to your Account. This allows us to provide a seamless user experience to you. We also work with third parties to employ technologies, including the application of statistical modeling tools, which attempt to recognize you across multiple devices so that we understand how you use our Services across various devices, to ensure the safety and security of your data and the Services, to show you targeted advertising (with your consent) tailored to your interests and experience, and to measure the performance of advertising campaigns.

  3. Transfer of business. We may transfer or share a copy of your personal data in cases where the Data Controller or one of its properties, affiliates, or subsidiaries is part of a business transition, such as a merger, being acquired by another company, or selling part of its assets, or in the event of bankruptcy, dissolution, divestiture or any related or similar proceedings.

  4. Legal defense. We may share your personal data to, in our discretion, (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce our Terms and Conditions, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, our property or safety, our users or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.

  1. HOW LONG WE RETAIN YOUR DATA

    1. Data collected via the Website analytics will be stored for up to 1 year in an identifiable state.  

    2. Communication data used for the improvement of the quality of our service is stored for up to 1 month.

    3. Other personal data may be stored for as long as the Account is opened and for 10 years thereafter. 

    4. In some cases, personal data may be stored for a longer period if the storage of personal data is required in order to protect our or any third parties’ legitimate interests, e.g. in case of a legal dispute, or if we are obligated to do so by law.  

  2. YOUR RIGHTS

If you are located in the European Union or the United Kingdom, as data subject (a person whose personal information is collected, stored and processed) you have several rights under General Data Protection Regulation (for EU) and Data Privacy Act 2018 (for UK):

 

  1. You have the right to obtain confirmation if your personal information is being processed by us. If that is the case, you can access your personal information and the following information:

    1. the purposes of the processing;

    2. the categories of personal information;

    3. to whom the personal information have been or will be disclosed;

    4. the envisaged period for which the personal information will be stored, or the criteria used to determine that period.

  2. If you would like to have a copy of your personal information from us, we will provide it only in case: (1) you will prove your identity, (2) it will not adversely affect the rights and freedoms of others.

  3. You have the right to demand that we erase your personal information, and we shall erase it without undue delay where one of the following grounds applies:

    1. this personal information is no longer necessary in relation to the purposes for which they were processed;

    2. you withdraw consent if the processing was based on your consent, and where there is no other legal ground for the processing;

    3. you object to the processing and there are no overriding legitimate grounds;

    4. your personal information has been unlawfully processed;

    5. your personal information has to be erased for compliance with a legal obligation.

  4. You have the right to receive your personal information which you provided us with in a structured, commonly used and machine-readable format and have the right to transmit those data to another company, where: (a) the processing is based on your consent or on a contract; and (b) the processing is carried out by automated means.

  5. You have the right to withdraw your consent for processing of your personal information at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

  6. You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal information infringes GDPR. For the UK, please contact the Information Commissioner’s Office.

You can exercise the above rights by contacting our support team via the email address indicated above.

  1. YOUR LIABILITY

    1. You hereby confirm and guarantee that you will never generate any databases, websites, software, legal entities and services that compete with our Services. Such behavior will be fully investigated, and necessary legal action will be carried out, including, without limitation, civil, criminal, and injunctive redress.

    2. Where you do not provide the personal data detailed in this Privacy Policy, you may not be able to use our Services.

  2. CHANGES IN THIS PRIVACY POLICY

    1. We regularly review this Privacy Policy and reserve the right to modify it at any time in accordance with applicable laws and regulations. Any changes and clarifications will take effect immediately upon their publication on our Website. Please review this Privacy Policy from time to time to stay updated on any changes.