We are European Change Consulting Limited, also trading under the name Cheques and Change. Our head office address is 40a East Street, Bedminster, Bristol, BS3 4HD.
Our registered company number is 2887296 and we are registered with HMRC as a Money Service Business no 12137003. We are authorised and regulated by the Financial Conduct Authority with the firm reference number 664878 for the provision of Pawnbroking loans.
We are registered with the Information Commissioner’s Office as a data controller under the number Z488112X.
This policy explains what happens to any information that you provide to us, or which we collect from you, either through our website or directly from you when you apply for the use of any of our products or services.
This policy is reviewed and updated in line with changes to our practices so please take the time review it regularly.
Information We Collect
We may collect some or all of the following information about you:
- Identity – full name, date and place of birth, nationality
- Contact information – addresses, telephone numbers, email addresses
- Employment – current or previous employers, their location and contact details, nature and length of your employment
- Financial – residential status, evidence of income and source of wealth
- Transactional – details of our products and services that you have used including frequency and volumes
- Security – details of usernames and passwords for electrical buybacks, personally identifiable security questions
- Payment details – merchant copies of PDQ slips
- Third Party – the nature of your relationship with a third party which impacts upon your transaction with us – for example when you are cashing a cheque issued by them.
- Sensitive information – such as mental or physical health issues when provided by you in order to assist us in managing your account appropriately.
- Communication – collected through the website to such as pages viewed and resources accessed. Such information includes traffic data, location data and other communication data.
- Information provided voluntarily by you. For example, when you register for information or make a purchase.
- Information that you provide when you communicate with us by any means.
How we collect your information
We may collect your information:
- when you provide it to us face to face in branch
- over the phone when taking an order, managing your account, or assisting you with an enquiry
- you correspond with us through email or post
- you enter details on our website
- we need to verify your data with a third party such as evidencing identity through a credit reference agency
Why we collect your information
We collect information from you in order to provide you with our products and services. This involves establishing your identity, managing your account and any transaction that you apply for or undertake. We use it to keep your records up to date and contact you as part of fulfilling your transaction or in the event that there was a default on a transaction. We may also use it to monitor and improve our systems, fee levels and the products we provide. We will also use your data for the detection and prevention of money laundering and fraud.
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Who we share your data with
We may share your data with the following third parties:
- law enforcement agencies or regulatory bodies where we are required to do so by law for the prevention and detection of crime
- online credit search agencies used to confirm your identity
- our software and hardware providers for IT errors, maintenance and upgrades
- external auditors (such as those from HMRC, the Financial Conduct Authority or Travelex, our foreign currency wholesaler) and Compliance Consultancy firms for the purpose of testing our compliance with our legal obligations
- third party companies used in the process of providing our services to you: Gemcabin Ltd who process third party cheques on our behalf, Diablo Graphics Ltd who manage the Click and Collect function on our website and/or First Data Merchant Services who process card payments.
Our legal basis for collecting your information
Data Protection laws say that we are allowed to use personal information only if we have a proper reason to do so. Of the legitimate reasons stated in law, three are relevant to our purpose for collecting your data:
- to fulfil a contract we have with you
- when it is our legal duty – in order to detect, investigate, report and prevent financial crime. To assist law enforcement when requested to do so. When complying with laws, regulations and regulatory guidelines.
- when it is in our legitimate interest, - for example to provide our services, to manage accounts and systems, for the training of staff.
Third Party Data
If you provide data about a third party, such as an alternative contact number, you should ensure that you have their consent to do so. In the circumstances you will be confirming with us that consent has been given. When information is provided by you about another, or someone provides information about you this may be added to you records in order to assist in effective running of your account.
How do we store your data
We may store your information electronically on our systems and/or retain paper copies in branch or secure archiving units. We will keep your information as long as you are a customer with us and for six years after your last transaction. We may keep your information for longer than this for legal, regulatory or technical requirements.
We store your information within the European Economic Area (EAA). We do not anticipate transferring your information outside the EAA, however should we need to do so we would first ensure that there was adequate protection in place to maintain the security of your data.
How you can access your information
Under the General Data Protection Regulations you may request details of, or make amendments to, the personal information which we hold about you at any time. Under normal circumstances no fee would apply. If you would like a copy of the information held about you please write to the Data Officer, details below.
If you choose not to give personal information
You may opt out of providing us with your personal information or request that we no longer process your data. However this may restrict the way in which we can transact with you or may prevent us from offering you products or services. Your right to opt out does not supersede our legal obligation to comply with anti-money laundering legislation.
If you have a question or would like to exercise your rights or make a complaint please contact our Data Protection Officer: Naomi Porter, by post at 13 Broadwalk, Knowle, BS4 2RA or by phone 0117 9720900.
You also have the right to complain to the Information Commissioner’s Office at Wycliffe House, Water Lane, Wimslow, Cheshire, SK9 5AF. www.ico.org.uk
or by phone 0303 123 1113.