Privacy Notice


Welcome to CurrencyLab’s privacy notice. 

CurrencyLab respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website or our app (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how CurrencyLab collects and processes your personal data through your use of our website or our app, including any data you may provide through our website or our app when you use our services.  

Our website and app are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. 


Bureau Buttercrane Ltd trading as CurrencyLab, a company incorporated in Northern Ireland with company number NI603454 whose registered office is at Unit 20 Buttercrane Shopping Centre, Buttercrane Quay, Newry, Down, BT35 8HJ is the controller and responsible for your personal data (collectively referred to as CurrencyLab, we, us or our in this privacy notice). 

CurrencyLab is authorised by the Financial Conduct Authority under the Payment Service Regulations 2017 (Reference number: 747167) for the provision of payment services. We are registered with the Information Commissioner’s Office (ICO), the data protection regulator in the UK, to use personal data. Our ICO registration number is ZA202655. 

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below. 

DPO: Fiona Gildea

Contact Address: Unit 20, Buttercrane Shopping Centre, Newry, Co. Down, BT35 8HJ

Email: [email protected]

2. The data we collect about you

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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes your name, username or similar identifier, date of birth, gender, nationality, date of birth, identification documents (for example, your passport or international identity card), copies of any documents provided for identification purposes to provide you are eligible to use our services (for example bank statements or utility bill), your photo or video (captured during an identity verification session) and photos from your device (if you grant us access).
  • Contact Data includes your address, email address, telephone number. 
  • Financial Data includes bank account details (including the account number, sort code and IBAN) and copies of any source of proof of source of funds (including bank statements or solicitor/accountant letters etc.).
  • Transaction Data includes details about payments to and from you, including the transaction date, time and amount, the currencies and exchange rate used, beneficiary details and the payment method you used.
  • Technical Data includes internet protocol (IP) address, your login data, browser or mobile browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, type of device, unique device identifier (including the IMEI number, the AMC address of the device’s wireless network interface, or the mobile phone number used by the device) mobile network data, mobile operating system and other technology on the devices you use to access our website or use our app. 
  • Profile Data includes your username and password, the services used by you and records of our communication, if you contact us or we contact you. 
  • Usage Data includes information about how you use our website or our app, products and services, including the links you’ve clicked on through and from our website or our app (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction data (such as scrolling and clicks) and methods used to browse away from the webpage or the app. 
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. 

We only collect limited Special Categories of Personal Data about you (which is limited to biometric data and limited information about criminal convictions and offences) where you have chosen to provide that type of personal data to us.

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 (for example, to provide you with 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. 

3. How is your personal data collected?

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

  • Direct interactions. You may give us your Identity Data, Contact Data 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:
  • use our services;
  • create an account on our website or our app;
  • subscribe to our service or publications; 
  • request marketing to be sent to you; or
  • give us feedback or contact us, including our customer helpline and messaging service. We may record calls to our customer helpline, messages and emails but only to train and monitor our staff so that they give you the best support possible.
  • Automated technologies or interactions. As you interact with our website or our app, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie notice [LINK] for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below: 
    • Jumio Corporation and IVXS UK Limited trading as ComplyAdvantage. 

4. How we use your personal data

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:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • 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.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

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.

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 below. 


Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer, check your identity and decide whether or not to approve your application to use CurrencyLab’s services. This is part of our Know Your Customer (KYC) processes and obligations

(a) Identity 

(b) Contact

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation (including our anti-money laundering and KYC obligations)

To process and deliver the services including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity 

(b) Contact 

(c) Financial 

(d) Transaction 

(e) Marketing and Communications

(a) Performance of a contract with you 

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy notice

(b) Asking you to leave a review or take a survey

(c) to provide Customer Support, either by phone or by email. 

(a) Identity 

(b) Contact 

(c) Profile 

(d) Marketing and Communications

(a) Performance of a contract with you 

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity 

(b) Contact 

(c) Profile 

(d) Usage 

(e) Marketing and Communications

(a) Performance of a contract with you 

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business, our website and our app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)  

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website and app content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity 

(b) Contact 

(c) Profile 

(d) Usage 

(e) Marketing and Communications 

(f) Technical 

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website and our app, products/services, marketing, customer relationships and experiences

(a) Technical 

(b) Usage 

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website or our app updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about services that may be of interest to you

(a) Identity 

(b) Contact 

(c) Technical 

(d) Usage 

(e) Profile 

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)


We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

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. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

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

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions. 


Cookies are a small piece of information saved in your browser storage. They are used to improve the customer experience in pages and help third-party services to work properly. We uses cookies extensively in both public pages and the product, as do third-party providers. The data stored in cookies is anonymous, rather than private, and cannot be retained for more than 24 months. 

Change of purpose 

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. 

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.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above including:

  • Third parties who provide a service to us and their sub-processors, including those related to identification and KYC services, customer relation services and I.T. and marketing services. 
  • A public authority in the event that we are required to do so by law.
  • A third party where we are under a legal obligation to transfer it to that third party.
  • A prospective seller or buyer of any of our assets or business.
  • A third party where it is necessary to protect the vital interests of the data subject or another natural person.
  • We may also be required to share your personal data with our regulator the Financial Conduct Authority.
  • Our banking and financial services partners and payment networks to allow us to transfer your money internationally. 
  • Professional advisers, including our lawyers and accountants.  
  • Social media platforms, including Facebook and LinkedIn.

6. International transfers 

As part of our service, we may sometimes need to transfer your data outside the European Economic Area (EEA) and/or the UK (as applicable). Use of our services may require us to send your data alongside any payments you instruct us to make. We do this to adhere to our legal and regulatory requirements. 

Some of our external third party service providers, including the Jumio Corporation and HubSpot Inc., are based outside the EEA and/or the UK so their processing of your personal data will involve a transfer outside the EEA and/or the UK (as applicable).

Whenever we transfer your personal data out of the EEA or the UK (as applicable), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the ICO (as applicable). For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission or the ICO (as applicable) which give personal data the same protection it has in Europe or the UK (as applicable). For further details, see European Commission: Model contracts for the transfer of personal data to third countries.  

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or the UK. 

7. Data security

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 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.

It is still important for you to keep your CurrencyLab account details and password safe. You should not share these with anyone.

8. Data retention

How long will you use my personal data for?

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.

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.

As we are authorised by the Financial Conduct Authority, we must keep certain customer information in order to comply with our regulatory obligations, this includes keeping customer information in respect of our KYC checks for at least five years. This information might include Contact, Identity, Financial and Transaction Data. 

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for five years after they cease being customers for [tax] purposes.]

In some circumstances you can ask us to delete your data: see section ‘Your legal rights’ below for further information.

In some circumstances we will 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. 

9. 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

  • Request access to your personal data;
  • Request correction of the personal data that we hold about you. 
  • Request erasure of your personal data. 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. 
  • Object to processing of your personal data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. 
  • Request the transfer of your personal data to you or to a third party. 
  • 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

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.

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.

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. 

Contact details

If you have any questions about this privacy notice or our privacy practices, please contact us at [email protected] 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review. This version was last updated on 06/04/2021. 

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.

Third-party links

Our website and our app 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 do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or our app, we encourage you to read the privacy notice of every website you visit.