Confidence and safety are key part of what makes Terry Services the best way to send money world-wide. Your privacy is very important to us; hence we’d like to tell you what we do to keep your data safe and secure. In this policy, we explain how Terry Services collects, manages, uses and protects your data.

INTRODUCTION
Terry Services is a trading name for T&M Logistics Limited with company number 08344193. Registered office is located at 354 Lea Bridge Road, London, E10 7LD, United Kingdom. Terry Services provides money transfer service with the task to make international money transfer easier, quicker and cheaper.

In this Privacy Policy, terms such as “we”, “us” and “Terry Services” refer to T&M Logistics Limited and where applicable to its subsidiaries, branches and/or representative offices. The term “Service” refers to money transfers enabled from our website or mobile app.

In the language of data protection regulation, Terry Services is the “data controller” of your personal data and you, our customer, are the “data subject”. This means that Terry Services determines the purposes and means of processing your personal data, while respecting rights concerning your privacy.

DATA WE COLLECT
We collect Personal Data which you disclose to us via online and offline:
We collect your Personal Data and Personal Data of your beneficiaries when you create a money transfer account with us by completing online forms. Personal Data we collect about you may include: name, surname, home address, email address, date of birth, email address, mobile number, credit and payment history, financial information, such as bank account numbers and credit/debit card numbers, and other Personal Data, including government identification numbers such as a driver’s license, passport number, visa, which may be required to complete the transaction.

As a regulated financial institution, we are bound by the legal requirement to collect, verify and record certain data about you or recipients of your transactions. All types of data we gather may be used to prevent or detect crime. This data is necessary for Terry Services to provide the service to you. We will request this data when you sign up, before the Service is provided.

Data for ‘Know Your Customer’ (KYC) regulations, such as (but not limited to):

 Proof of your identity, like a passport, driving licence, national ID card or residence permit
 Proof of your address, like a utility bill or bank statement
 Additional details on the source of funds being sent, like a payslip, credit card/bank statement, tax rebate receipt or bank loan agreement. This data will sometimes be needed to conduct Know Your Customer (KYC), Customer Due Diligence (CDD) and security checks, as required by the regulatory bodies. This helps us keep your money safe, and we will only request these details when necessary.

Data about your recipient, such as (but not limited to):

 Name
 Date of birth
 Occupation
 Phone number
 Proof of their identity, such as a passport, driving licence, national ID card or residence permit
This data will sometimes be needed to conduct Know Your Customer (KYC), Customer Due Diligence (CDD) and security checks, as required by local and international regulations. This helps us keep your money safe, and we will only request these details when necessary. All data about your recipients will be treated in line with this Privacy Policy.

Data from other third-party sources, such as (but not limited to):

 Facebook, Twitter or Google profile images and names
 Banks and payment service providers used to transfer money to us
 Advertising networks
 Search engines providers
Terry Services collects this data only when you provide the relevant permission to social media sites.

Technical data, such as (but not limited to):

 Page views
 App downloads
 Operating system
 Browser type
This data is used to help us to understand how you use our Service, so that we can improve it.

WHY WE COLLECT YOUR DATA
We collect your data to personalise and improve our service for you. The specific purposes for which we collect your data include:

Transactional purposes
We need to collect data to process your transactions. Without data such as you and your beneficiaries bank account details or full name and address, we would be unable to provide service to you.

Regulatory purposes
As a regulated financial institution, both Terry Services and our partners are required to conduct Know Your Customer (KYC) and Customer Due Diligence (CDD) checks to comply with our legal and regulatory requirements. These include our requirements under Anti Money Laundering (AML) and Counter Terrorist Financing (CTF) legislation. All of this helps us keep our Service safe and secure.

Marketing purposes
We may process your personal data to provide you with certain types of marketing communication that we believe will be relevant and of interest to you. This helps us provide you with a more tailored Service. This kind of activity is permitted by our ‘legitimate interest ‘as contained herein. We will always endeavour to make these communications relevant and will not be intrusive, and you are able to object to marketing communication from us at any time.

Analytical purposes
We may collect and analyse data such as website or app visit logs to improve the quality of our Service. You do not have to disclose any of the above data to us. However, if you choose to withhold certain data, we may not be able to provide you with our service.

HOW DO WE PROTECT YOUR INFORMATION SAFE AND SECURE?
We ensure that there are satisfactory safeguards in place to protect your personal details from unauthorised access. When You enter certain information such as a credit card number on our order forms, we encrypt the transmission of that information using reasonable security measures. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. Regrettably, the transmission of information via the internet (including by email) is not completely secure. Although we will do our best to protect Your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent illegal access.

HOW LONG WE KEEP YOUR DATA
We will only keep the information we collect about you for as long as required for the purposes set out above, or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still essential. The period for which we will retain information about you will vary depending on the type of information and the purposes that we use it for. In general, we will keep our records for up to 7 years after you have terminated your relationship with us, to comply with our legal obligations.

Regulatory
We are legally required to keep the data obtained for Know Your Customer (KYC), Customer Due Diligence (CDD) and security purposes (including transaction records and our communications with you) for at least five years after the most recent transaction.

Legitimate Interest
When the five years’ retention period and/or legitimate interest no longer apply, we will remove your data from our system.

Consent
In situations where you give us specific consent to process certain kinds of data, you can withdraw that consent at any time. We will then stop processing your data and, if the five years’ retention period and/or legitimate interest retention period does not apply, we will also erase your data from our system. We may retain any data mentioned above for a longer period, if required to protect the rights, property or safety of Terry Services or of the service provided by us or our partners.

WHO WE SHARE YOU’RE YOUR INFORMATION WITH
We share your personal information with third parties only when it is necessary for the fulfilment of the service or to comply with applicable laws. We will never sell your personal data to other organisations. We work with partners who help us to complete your transactions. If they are based outside the EEA, we will share your personal data with them only when they apply essential safeguards, or if it has been established by EU institutions that the relevant country has an appropriate data protection regime in place, or when we otherwise ensure that the appropriate level of protection is applied for data processing. The following are some purposes for which we may share your data with third parties:

To fulfil the contract between you and Terry Services
We may share your data with third parties, such as our partners and intermediaries, when they are necessary for the fulfilment of the Service.

When required by law
We may share your data when required by law, for example for the purposes of security, taxation and criminal investigations.

For marketing and communication
We may share your data with third parties such as providers of customer service tools, marketing campaign tools, email communication tools, analytics software (for marketing purposes) and data visualisation tools (for analytical purposes). If we sell or buy any business or assets, we may be obliged to share your personal data with the prospective seller or buyer.

YOUR RIGHTS
The law gives you several important rights in relation to your personal data, which are listed below. There are certain exceptions where these rights may be superseded by laws and other requirements applicable to regulated financial institutions like Terry Services. An example of this would be the obligatory retention period mentioned above, which supersedes the right to data erasure. Your rights are:

 The right to be informed: the right to be informed about how we use your personal data
 The right of access and data portability: the right to request access to the data that we have about you, to obtain the data within a month of asking for it, and to use it for your own purposes
 The right to erasure: the right to ask us to remove the data we hold about you from our records
 The right to object: the right to object to data processing, if you believe that our legitimate interest might infringe upon your rights
 The right to be forgotten: the right to request erasure of any links to your personal data, or of any copy or replication of any public personal data
 The right to restrict processing: the right to ask us to stop processing your personal data
 The right to rectification: the right to correct, amend or update your personal data if it is wrong or has changed (this can usually be done using the settings provided on your account)
 Rights related to automated decision-making and profiling: the right not be subject to individual decisions made solely by automated means.
 The right to notification in the event of breach: the right to be immediately informed if we identify a data breach
 The right to raise a complaint: the right to contact our Data Protection Officer if you are not happy with how we have handled your personal data
 The right to lodge a complaint with a supervisory authority: the right to submit a complaint to the Information Commissioner’s Office (ICO) if you are not satisfied with our Data Protection Officer’s response, or if you believe that we are not processing your personal data in a lawful way (For more details please refer to the Commissioner’s Office website
 If you would like to read more about your rights in relation to your personal data, please refer to the Information Commissioner’s Office website.

LEGITIMATE INTEREST
Legitimate interest is a specific legal justification for the collection and processing of your personal data. It applies when we have reasonable grounds to collect and/or process your personal data to improve our service, if this does not infringe on your rights. Our legitimate interest may justify some examples of automated decision-making. One of those is our estimated transaction timing, which we use to determine the time in which the transfer will reach your beneficiary. We believe that if you are an active customer of Terry Services, it is in your interest to receive occasional information about our Service. We may therefore send you communications about offers or promotions that we believe are relevant for you based on your previous use of the Service. If we notice that you are having problems using our service, we may on our own initiative decide to contact you, in some cases by phone, to offer help. We may also process your data to help develop new product features that we believe will improve the service. We may contact you occasionally to assess your satisfaction with the Service. We may also use your data to determine the effectiveness of marketing or promotional campaigns. We may also contact you with information about any changes in the service, and/ or other important updates. We will only share anonymised or encrypted data with the third parties. We may also provide our partners with anonymous aggregated data about our customers for marketing and analytical purposes, to help optimise our marketing communications. You can object to data processing based on our legitimate interest at any time by contacting us at privacy@terryervices.co.uk or by changing the settings on your Terry Services account.

COOKIES POLICY
A cookie is a small text file that is downloaded onto ‘terminal equipment’ (e.g. a computer or smartphone) when You access Terry Services website. It allows the website to recognise your device and store some information about your preferences or past actions. They allow us to recognise you and store data about your past activity and your preferences so that we can personalise and improve the service for you. Cookies and other similar technologies may collect data such as language preference, country and previously viewed pages. We use the following cookies:

 Necessary cookies: these cookies enable the basic use of our Service e.g. enabling content reserved for registered users
 Personalisation cookies: these cookies allow our Service to be personalised for you e.g. remembering your preferred language or sending country
 Analytical cookies: these cookies allow us to see how people use our Service so that we can understand how to improve it e.g. seeing how many people are logged in at a given time of day By using our service, you agree to place the cookies described above on your device. You have the right to withdraw your consent at any time. If you would like to delete our cookies, you can do so by changing the settings of your browser.
Blocking or deleting cookies may mean that some features of the service may not be available to you.

USING SOCIAL MEDIA TO ACCESS TERRY SERVICES
You can log in to Terry Services using your Facebook or Google profiles. This allows us to authenticate your identity by obtaining access to:
 Your e-mail address associated with your Facebook and Google profile
 Your Facebook public profile
 Your Google basic profile
 Your Google contacts
Any of your personal data that we receive from third parties will be subject to this Privacy Policy and the privacy policies of those third parties.
By using your Facebook or Google login credentials, your personal data may be processed by Facebook or Google marketing tools. An example of this is the Facebook tool called ‘Lookalike Audiences’ or a similar tool used by Google called ‘Customer Match’. These help us to identify people who have similar interests or behaviours to those of our customers. We may use similar tools provided by Facebook or Google in the future.

CHANGES IN OUR PRIVACY POLICY
Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy. The date of the most recent update is displayed at the top of the page.

COMPLAINTS
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to:
Terry Services:
354 Lea Bridge Road,
London, E10 7LD,
United Kingdom.
Email: complaints@terryservcies.co.uk
If you have any concerns about our use of your information, you also have the right to make a complaint to:
• the Information Commissioner's Office, which regulates and supervises the use of personal data in the United Kingdom, via their helpline on 0303 123 1113.