Privacy Policy

This Privacy Policy explains how United Exchange Ltd, trading as TwintaPay, collects, uses, stores, protects and shares personal information when you visit our website, contact us, create an account, use our online money transfer services, or otherwise interact with us.

TwintaPay is a trading style of United Exchange Ltd. United Exchange Ltd is registered in England and Wales under Company Number 07860668. Our trading address is 149 Cheetham Hill Road, Manchester, M8 8LY. FCA FRN: 584295. HMRC MLR Registration: XBML00000198839.

1. Who we are

For the purposes of UK data protection law, United Exchange Ltd is the data controller for the personal information we collect and use in connection with TwintaPay services.

If you have any questions about this Privacy Policy or how your personal information is handled, you can contact us using the details below:

• Company: United Exchange Ltd T/A TwintaPay
• Address: 149 Cheetham Hill Road, Manchester, M8 8LY
• Email: info@unitedexchangeltd.co.uk
• Telephone: +44 161 566 7083

2. Personal information we collect

We may collect and use the following types of personal information:

• Identity information: full name, date of birth, nationality, identity document details, photographs, and verification results.
• Contact information: address, email address, telephone number and communication preferences.
• Transaction information: transfer amount, currency, exchange rate, fees, beneficiary details, destination country, payment method, transfer purpose and relationship to the beneficiary.
• Financial and source of funds information: occupation, income source, bank account details, payment references, and supporting documents where required.
• Beneficiary information: recipient name, contact details, bank or wallet details, country, and relationship to the sender.
• Compliance information: customer risk assessment, sanctions screening, politically exposed person checks, adverse media results, fraud prevention checks, and transaction monitoring information.
• Technical information: IP address, device information, browser type, website usage, login data, cookies and similar technology data.
• Communication records: emails, call notes, support requests, complaints and correspondence with us.

3. How we collect your information

We collect personal information in different ways, including:

• when you visit our website or use our online services;
• when you create an account or start a transfer;
• when you provide identity, address, source of funds or transaction information;
• when you contact us by phone, email, website form or support channel;
• from identity verification, fraud prevention, sanctions screening and compliance service providers;
• from payment, banking, open banking, payout and settlement partners;
• from public sources, regulatory sources, official lists and fraud prevention databases where required.

4. Why we use your personal information

We use personal information for the following purposes:

• to provide online money transfer services;
• to create, manage and verify customer accounts;
• to process transfers to beneficiaries in supported countries;
• to calculate and show rates, fees and expected receive amounts;
• to carry out identity verification, customer due diligence and enhanced due diligence where required;
• to comply with anti-money laundering, counter-terrorist financing, sanctions, fraud prevention and payment services obligations;
• to monitor transactions and detect unusual or suspicious activity;
• to prevent fraud, misuse of our services and financial crime;
• to respond to customer enquiries, complaints and support requests;
• to maintain business, accounting, audit and regulatory records;
• to improve our website, systems, security and customer experience;
• to send service messages, important updates and, where permitted, marketing communications.

5. Lawful basis for using your information

We only use personal information where we have a lawful basis to do so. Depending on the circumstances, we may rely on:

• Contract: where processing is necessary to provide the service you request.
• Legal obligation: where we must process information to comply with laws and regulatory requirements, including AML, sanctions, payment services, tax and record-keeping obligations.
• Legitimate interests: where processing is necessary for our business operations, fraud prevention, service improvement, risk management, security and customer support, provided your rights are not overridden.
• Consent: where required, such as for certain marketing communications or non-essential cookies. You can withdraw consent at any time.

6. AML, sanctions and fraud checks

As a regulated money transfer business, we are required to carry out checks before and during the use of our services. This may include identity verification, sanctions screening, PEP screening, adverse media checks, fraud checks, transaction monitoring and source of funds reviews.

If we are unable to complete required checks, we may be unable to open an account, process a transfer, release funds, continue providing services, or respond fully to certain requests. In some circumstances, we may also be legally restricted from explaining specific compliance actions.

7. Who we share information with

We may share personal information with trusted third parties where necessary for service delivery, compliance, security and business operations. These may include:

• identity verification and KYC providers;
• AML, sanctions, PEP and fraud screening providers;
• banks, payment processors, open banking providers and settlement partners;
• payout partners, correspondent partners and wallet or bank payout providers;
• IT, hosting, cloud, cybersecurity and system support providers;
• customer support, communications and email service providers;
• professional advisers, auditors, accountants and legal advisers;
• regulators and authorities, including the FCA, HMRC, NCA, OFSI, ICO, law enforcement agencies, courts and other competent authorities where required;
• complaints bodies or dispute resolution bodies, where applicable.

We only share information where it is necessary, lawful and proportionate.

8. International transfers

Because TwintaPay provides cross-border money transfer services, personal information may need to be shared with payout partners, banks, wallet providers or service providers outside the United Kingdom, including in the destination country of the transfer.

Where we transfer personal information internationally, we take steps designed to protect that information in accordance with applicable data protection law. This may include contractual safeguards, due diligence on service providers, access controls and limiting the information shared to what is necessary for the transfer, compliance or service purpose.

9. How long we keep your information

We keep personal information only for as long as necessary for the purposes described in this Privacy Policy, including legal, regulatory, accounting, reporting and compliance obligations.

For AML and regulatory record-keeping purposes, we may need to keep customer due diligence and transaction records for at least five years after the end of the customer relationship or the completion of a transaction, unless a longer period is required by law, regulation, dispute, investigation or legitimate business need.

10. How we protect your information

We use appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure. These measures may include secure systems, access controls, encryption, staff training, audit trails, transaction monitoring and restricted access to customer information.

No online system can be guaranteed to be completely secure. Customers should keep login details private, use secure devices, and contact us immediately if they believe their account or information has been compromised.

11. Your data protection rights

Subject to legal limitations, you may have the following rights:

• the right to access your personal information;
• the right to correct inaccurate or incomplete information;
• the right to request deletion of your information;
• the right to restrict how your information is used;
• the right to object to certain processing;
• the right to data portability, where applicable;
• the right to withdraw consent where processing is based on consent;
• the right to complain to the Information Commissioner’s Office.

Some rights may be limited where we must keep or use information to comply with AML, sanctions, fraud prevention, payment services, tax, legal or regulatory obligations.

12. Marketing communications

We may send you service messages about your account, transfers, security, compliance, complaints or important operational updates. These messages are necessary and are not marketing.

We will only send marketing communications where permitted by law. You can opt out of marketing communications at any time by using the unsubscribe option or by contacting us.

13. Cookies and website tracking

Our website may use cookies and similar technologies to operate the website, improve functionality, understand website usage and support security. Some cookies are necessary for the website to work. Non-essential cookies will be used only where permitted by law.

For more information, please see our Cookie Policy.

14. Children

Our services are not intended for individuals under the age of 18. We do not knowingly provide money transfer services to children.

15. Complaints and contact

If you have concerns about how we handle your personal information, please contact us first so we can review and respond to your concern.

• Email: info@unitedexchangeltd.co.uk
• Telephone: +44 161 566 7083
• Address: United Exchange Ltd T/A TwintaPay, 149 Cheetham Hill Road, Manchester, M8 8LY

You also have the right to complain to the Information Commissioner’s Office if you are unhappy with how your personal information has been handled.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, systems, legal obligations or regulatory requirements. The latest version will be published on our website.