Privacy Policy
What personal information Zeltz collects, why we hold it, and the rights you have over it.
Draft – pending legal review
This Privacy Policy has not yet been approved and should not be relied on. Highlighted values still need to be confirmed. Questions: [email protected].
1. Who we are
Zeltz is a trading name of [legal entity name], registered in [country] under company number [company number], with its registered office at [registered address]. We are the data controller for the personal information described in this policy.
For any question about this policy, or to exercise the rights set out in section 8, contact [email protected].
2. Information we collect
We collect the following categories of personal information:
- Identity information. Full name, date of birth, nationality, and the identity documents you provide during verification.
- Contact information. Email address, telephone number and residential address.
- Financial information. Bank account or wallet details for you and for the people you send money to, and the funding method used for a transfer.
- Transaction information. Amounts, currencies, corridors, exchange rates applied, timestamps, and the status and reference of each transfer.
- Verification information. The results of identity, sanctions, politically exposed person and adverse media checks, and any supporting evidence you supply about source of funds.
- Technical information. IP address, device and browser characteristics, and log data generated when you use our services.
- Correspondence. Records of your contact with our support team.
We do not collect special category data, and we do not buy personal information from data brokers.
3. Why we use it, and our lawful basis
- To provide the service – opening your account, quoting a rate, executing and tracking a transfer, and providing support. Basis: performance of a contract with you.
- To meet our legal obligations – customer due diligence, sanctions screening, transaction monitoring, record keeping and regulatory reporting. Basis: compliance with a legal obligation.
- To prevent financial crime and fraud – detecting and investigating suspicious activity and protecting our customers and our platform. Basis: legal obligation, and our legitimate interest in preventing fraud.
- To operate and improve our platform – maintaining security, diagnosing faults and improving reliability. Basis: our legitimate interest in running a secure and functional service.
- To communicate with you – service messages about your account and transfers. Basis: performance of a contract. Marketing messages, where sent, rely on your consent and can be withdrawn at any time.
4. Who we share it with
We share personal information only where it is necessary, and only with:
- Payment and payout partners that settle the transfer in the destination country.
- Identity verification and screening providers that carry out the checks described in section 2.
- Banking partners that hold and move funds.
- Regulators, law enforcement and tax authorities, where we are required or permitted by law to disclose. Where a disclosure relates to suspected financial crime we may be prohibited by law from telling you it has been made.
- Professional advisers such as auditors and lawyers, under a duty of confidentiality.
- Technology suppliers that host and support our systems, under written data processing terms.
We do not sell personal information, and we do not share it with advertising networks.
5. Transfers outside your country
Cross-border payments necessarily involve sending information to the destination country. We may also use suppliers located outside [home jurisdiction]. Where information is transferred internationally we rely on [transfer mechanism] and apply appropriate safeguards.
This website loads typefaces from Google Fonts and country flag images from a content delivery network. Your IP address is visible to those providers when the page loads. We do not use them to identify you, and no analytics or advertising service runs on this site.
6. How long we keep it
We keep records of your identity, verification checks and transactions for [retention period] after our relationship ends, because anti-money laundering law requires it. Support correspondence is kept for [retention period]. Technical logs are kept for [retention period]. Where we no longer need information and no legal obligation requires us to keep it, we delete it or irreversibly anonymise it.
7. How we protect it
Information is encrypted in transit and at rest. Access is restricted to staff who need it for their role and is logged. We hold customer funds in segregated accounts, separate from our own operating funds. No system is perfectly secure, but we test and review our controls and will notify you and the relevant regulator of a personal data breach where the law requires it.
8. Your rights
Subject to the conditions and exemptions in applicable law, you have the right to:
- access the personal information we hold about you;
- have inaccurate information corrected;
- have information erased, where we have no continuing legal reason to keep it;
- restrict or object to how we use it;
- receive information you gave us in a portable format;
- withdraw consent, where we relied on consent; and
- complain to a supervisory authority.
Anti-money laundering law limits some of these rights. We generally cannot erase verification or transaction records before the retention period in section 6 has expired.
To make a request, contact [email protected]. We will respond within [response period]. If you are not satisfied with our response you may complain to [supervisory authority and contact details].
9. Cookies
This website uses strictly necessary cookies only. See our Cookie Policy for details.
10. Changes to this policy
We will update this page when our practices change and revise the date shown above. Where a change materially affects your rights we will tell you directly.