Xelda is committed to respecting the privacy rights of all visitors to Xelda. This Privacy Policy covers the use of the App and Website and the services provided by Tipsee Limited trading as Xelda (“Xelda”, “we”, “us” or “our”). Xelda is incorporated in Ireland with company registration number 690463 and having its registered address at ℅ Barry Healy & Co…,,, 363, North Circular Road, Phibsborough, Dublin 7. This Privacy Policy provides details of the way in which we process personal data in line with our obligations under the General Data Protection Regulation (No. 2016/679) (“GDPR”), the Data Protection Act 2018 and any other laws which apply to us in relation to the processing of personal data (collectively referred to as “Data Protection Laws”). In this Privacy Policy, “controller”, “personal data” and “process” (and its derivatives) have the meanings given to those terms in Data Protection Laws.

We will collect your personal data when you use: 

our website at http://www.xelda.com; 

the Xelda app; 

or any of the services you can get access to through the Xelda app or website. 

Personal data generally means information that can be used to individually identify a person, and processing generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.

THIS POLICY CONTAINS IMPORTANT INFORMATION 

This policy explains what information we collect, how we use it, and your rights if you want to change how we use your personal data. If you have concerns about how we use your personal data, you can contact [email protected]

WE COLLECT DIFFERENT TYPES OF PERSONAL DATA FROM YOU AND OTHERS 

The table below explains what personal data we collect and use. We collect information you provide when you: fill in any forms; correspond with us; register to use the Xelda app; open an account or use any of our services; speak with a member of our customer support team (either on the phone or through the Revolut app); or contact us for other reasons.

We will collect the following information: Your name, address, and date of birth; Your email address, phone number ; password and other registration information; Identification documents (for example, your passport or driving licence), copies of any documents you have provided for identification purposes and any other information you provide to prove you are eligible to use our services;Records of our discussions, if you contact us or we contact you (including records of phone calls); Your image in photo form (where required as part of our Know-Your-Client (KYC) checks or where you upload a photo to your Xelda account).

Information from your device Whenever you use our website or the Xelda app, we collect the following information: Technical information, including the internet protocol (IP) address used to connect your computer to the internet, your log-in information; Information about your visit, including the links you have clicked on, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling and clicks), and methods used to browse away from the page; Information on transactions (for example, payments into your account), including the date, time, amount, currencies, beneficiary details, IP address of sender and receiver, sender’s and receiver’s name and registration information and the payment method used. 

We must have a legal basis (a valid legal reason) for using your personal data. Our legal basis will be one of the following. Keeping to our contracts and agreements with you: We need certain personal data to provide our services and cannot provide them without this personal data. Legal obligations: In some cases, we have a legal responsibility to collect and store your personal data (for example, under anti-money laundering laws we must hold certain information about our customers). Legitimate interests: We sometimes collect and use your personal data, or share it with other organisations, because we have a legitimate reason to use it and this is reasonable when balanced against your right to privacy.

Consent: Where you’ve agreed to us collecting your personal data.

We use your personal data so we can provide the best service, tell you about products and services you may be interested in, and meet our legal obligations. 

PROVIDING OUR SERVICES

Whenever you apply for a product or service, we will use your personal data to check your identity (as part of our KYC process) and decide whether or not to approve your application. If you are already a Xelda customer, we use your personal data to meet our obligations relating to any transactions you make (payments made to you through Xelda and withdrawals you make to your bank account). We use your personal data to give you details of our products and services and to help us develop new products and services. We use your personal data to contact you by phone and provide you with information about our products or services, as well as customer support services. We may monitor or record any communications between you and us, including phone calls, to maintain appropriate records, check your instructions, analyse, assess and improve our services, and for training and quality control purposes.

PROTECTING AGAINST FRAUD 

We use your personal data to check your identity to protect against fraud, keep to financial crime laws and to confirm that you are eligible to use our services. We also use it to help us manage fraud risks related to your Xelda account.

We use your personal data to manage our website and the Xelda app, (including troubleshooting, data analysis, testing, research, statistical and purposes), and to make sure that content from our website is presented in the most effective way for you and your device. We also use your personal data to tell you about changes to our services, and to help keep our website and the Xelda app safe and secure.

You have the right to be told about how we use your personal data. We provide this privacy policy to explain how we use your personal data. If you ask, we will provide a copy of the personal data we hold about you. We can’t give you any personal data about other people, personal data which is linked to an ongoing criminal or fraud investigation, or personal data which is linked to settlement negotiations with you. We also won’t provide you with any communication we’ve had with our legal advisers. You can ask us to correct your personal data if you think it’s wrong. You can have incomplete or inaccurate personal data corrected. Before we update your file, we may need to check the accuracy of the new personal data you have provided. You can ask us to delete your personal data. You can ask us to delete your personal data if: there’s no good reason for us to continue using it; you gave us consent (permission) to use your personal data and you have now withdrawn that consent; you have objected to us using your personal data; we have used your personal data unlawfully; or the law requires us to delete your personal data. You can object to us processing your personal data for marketing purposes. You can tell us to stop using your personal data for marketing. You can object to us processing other personal data (if we are using it for legitimate interests). If our legal basis for using your personal data is ‘legitimate interests’ and you disagree with us using it, you can object. However, if there is an overriding reason why we need to use your personal data, we will not accept your request. If you object to us using personal data which we need in order to provide our services, we may need to close your account as we won’t be able to provide the services. You can ask us to restrict how we use your personal data. You can ask us to suspend using your personal data if: you want us to investigate whether it is accurate; our use of your personal data is unlawful but you do not want us to delete it; we no longer need your personal data, but you want us to continue holding it for you in connection with a legal claim; or you have objected to us using your personal data (see above), but we need to check whether we have an overriding reason to use it. You can withdraw your permission. If you have given us any consent we need to use your personal data, you can withdraw your consent at any time by sending an email to [email protected] . 

PEOPLE OR COMPANIES THAT TRANSFER MONEY TO YOU: Where a payment is made to your Xelda account, we will provide you with the name of the payer. We will provide your details to the recipient (your full legal name). This is necessary to confirm that the payment has been made to the correct account. 

We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of your Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data covered by this Policy against unauthorized access, destruction, loss, alteration or misuse. Personal Data is only accessed by a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. To help us protect personal data, we encourage you to use a strong password and never share your password with anyone or use the same password with other sites or accounts. If you have reason to believe that your interaction with us is no longer secure (e.g. you feel that the security of your account has been compromised), please contact us immediately.

Data Retention

We will keep personal data only for as long as the retention of such personal data is deemed necessary for the purposes for which that personal data are processed (as described in this Privacy Policy) unless we are required to retain your personal data for a longer period (e.g. in the event of legal proceedings or investigations).

Service-related Announcements and Changes

If we change the way we use your personal data, we will update this policy and, if appropriate, let you know by email, through the Xelda app or through our website.

Contacting Us

For further information about this Privacy Policy or the processing of your personal data by or on our behalf, please contact us on [email protected] . While you may make a complaint in respect of our compliance with Data Protection Laws to the Data Protection Commission, we ask that you contact us in the first instance to give us the opportunity to address your concerns.

This Policy was last updated on 1 March 2023.