Privacy Policy
INTRODUCTION
We at Vitesse care about your privacy.
We build our relationships with clients, service users and employees based on transparency and trust.
This privacy notice was created to explain what personal information we collect, why we need to collect your personal information, when we will collect your personal information, who we will share your personal information with, how long we will keep your personal information for, what are your subject rights and how we keep your personal information safe.
Vitesse is headquartered in London, England and has offices in London and Rotterdam in the Netherlands, and New York, and provides treasury management and payment services to corporate customers.
Whenever Vitesse processes your personal data, we are processing it in line with our regulatory obligations, including the UK and EU General Data Protection Regulations as well as applicable US Regulations such as, but not limited to, the California Privacy Rights Act (CPRA) and Vermont Data Privacy Act (VDPA).
This Privacy notice relates to our use of any personal information we collect from you as follows:
- When you visit our website;
- When you fill in an application form or any other form of contact;
- When we communicate by email or text message;
- When we communicate by telephone;
- When you use our platform; or
- We process a payment in which you are the payer or payee.
INFORMATION WE WILL COLLECT ABOUT YOU
Corporate client
When a corporate client applies to use our services we will collect details in respect of key individuals within that business, including names, email addresses, postal and/or residential addresses, telephone or mobile numbers, gender, dates of birth and other relevant business financial information. Those details will be processed on the lawful basis of fulfilling a contract. We will act as data controller for those details.
We also may gather personal information from third parties relevant to financial crime such as fraud prevention and anti-money laundering. This includes US financial crime compliance regulations, including the ‘travel rule’, where applicable.
Payment originators and beneficiaries
When a corporate client instructs us to make a payment to or on behalf of an entity or individual, we will collect, where relevant, names, email address, postal address, telephone or mobile number, gender, date of birth and bank account information. These details will be passed to us by our client, or directly by you where we have been instructed to collect this information directly by our client, and will be processed on the lawful basis of fulfilling a contract and in order to comply with our legal obligations. We and our client, with whom you have a direct relationship, will be both data controllers in our own right.
Please note that sometimes we may require you to provide additional personal information, depending on the country destination where payments are being made from or to. When we do this, we will provide further information, to our client, about why we are collecting this information and how we will use it.
Telephone Call Recordings
If you telephone us, we may record the calls in order to confirm any instructions given to us, for training purposes, for crime prevention, to improve the quality of our customer service and to comply with our legal or regulatory obligations.
HOW WE WILL USE THE INFORMATION WE COLLECT ABOUT YOU
We will use this personal information for a number of purposes including the following:
- To make a payment to you, or on your behalf where applicable;
- To contact our clients about a service request you have made.
Sharing of your information with others
Your personal data may be shared beyond Vitesse for the following reasons:
- For the performance of any contract we enter into with our clients or you, we may be required to share data with select third-parties, including:
- business partners;
- suppliers;
- sub-contractors. - If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or
- To protect the rights, property, or safety of Vitesse, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and the prevention and detection of crime.
How long we will retain your information
We will keep your information only as long as necessary. The time will depend on the type of relationship you have with Vitesse. All data required to execute a payment will be kept for 7 years as we are required by law to keep this information.
When our relationship with our client ends, we will keep relevant information for 7 years after the contract end date. If the application to become a Vitesse client is rejected, we will keep any relevant details for a maximum of 12 months.
Where we store your information
The personal data provided is stored in our main processing centres in the UK, EU and US. Your data will be stored in one of these secure hosting environments appropriate to your location.
The transaction data that we collect may be transferred to other global locations. We ensure that appropriate safeguards, including Standard Contractual Clauses and/or International Data Transfer Agreements are in place. By submitting your personal data, you agree to this transfer, storing or processing.
The transmission of information via the internet is not completely secure. Vitesse has accredited information security practises in place but we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
We employ a range of technology and procedures to ensure that this data is secure, including encryption, anti-virus and anti-malware software, intrusion detection, company-wide data usage policies, and mandatory security and privacy staff training.
OUR OBLIGATIONS TO YOU
Depending on the jurisdictions where you are resident, you may have specific legal rights in relation to your data. Vitesse looks to uphold the following rights even where it is not required to do so but law, so long as it does not conflict any other legal obligations we have.
The right to be informed
You have the right to be informed why and how we collect your personal data, how we will use this information, who we share it with, what are the security measures we take to protect this information and what are you are your individual rights. We publish this information in this Privacy Notice.
The right of access
You have the right to access the information we hold for you by making a Subject Access Request, by emailing privacy@vitessepsp.com.
The right to rectification
You have the right for inaccurate or incomplete data we hold to be updated. You can make a request to have your data updated by emailing privacy@vitessepsp.com.
The right to erasure
You may have the right to be forgotten in the circumstances where we are not obliged by law to keep your information. If you wish to exercise this right please contact us by emailing privacy@vitessepsp.com.
The right to restrict processing
You have the right to restrict processing when you have exercised one of the above right and it may take some time to process that request. For example: when you contact us to update your details you have the right to request restriction until your details have been updated
The right to withdraw consent
For the processing activities where we have asked you for consent, you have the right to withdraw this consent at any point by emailing privacy@vitessepsp.com.
The right to object
You can object to the processing of your personal data at any point by emailing privacy@vitessepsp.com. There may be instances where we may not be able to fulfil those requests, but we will provide you with an explanation when replying back to you.
The right not to be subject to automated decisions and profiling
Vitesse does not undertake any automated processing or profiling. If this changes, this Privacy Notice will be updated and you will be informed accordingly.
The right to data portability
If you have provided us with your personal data with consent or under any other relevant lawful basis, you have the right to request the data that you have provided to us in a machine-readable format should you decide to move to another data controller.
The right to complain
If you feel we have been intrusive to your privacy or misused your data you may have the right to complain to a local authority, including the Information Commissioner’s Office or the FTC if you are based in the US.
Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.
Changes To Our Privacy Notice
This notice was last updated on 30th November 2023. 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.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites
ADDITIONAL CONSIDERATIONS FOR US RESIDENTS
The personal data provided by you is stored in a secure hosting environment based in the US.
The transaction data that we collect may be transferred to, and also stored at, a destination outside the US. It may also be processed by staff operating outside the US who work for Vitesse or for one of our suppliers. This includes staff engaged in the processing of your payment details and the provision of support services. By submitting personal data, you agree to this transfer, storing or processing. To ensure your data is secure and we comply with our privacy obligation, we have data processing agreements and security operational and technical measures in place as per this Policy.
For California residents:
We will not share information we collect about you with non-affiliated third parties, except as permitted by law, including, for example, with your consent or to service your account. We will limit sharing with our affiliates to the extent required by California law.
You may have certain rights under the California Consumer Privacy Act (“CCPA”) regarding your personal data, including:
- The right to be informed of the personal data we collect, use, and process for purposes listed in section 4.
- Further detail on:
- the categories of personal data collected,
- the sources from which we collect it,
- the business or commercial purposes of collection,
- as well as the categories of third parties to whom we disclose personal data, are described within this Privacy Policy,
- The right to request the specific pieces of personal data that we have collected about you in the twelve (12)months preceding your request;
- The right to request deletion of your personal data that we collected;
- The right to correct any inaccurate information that we hold about you;
- The right to limit the use of your sensitive personal information to only that which is necessary for providing products or services;
- The right to opt-out of the sale or sharing of personal information,
- The right not to be discriminated against for exercising any of these rights. - You should be aware that this section does not apply to:
- Personal information covered by certain sector-specific privacy laws, including the Gramm-Leach-Bliley Act and its implementing regulations, the California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994; or other information subject to a CCPA exception.
For Vermont residents:
We will not share information we collect about you with non-affiliated third parties, except as permitted by law, including, for example with your consent or to service your account. We will not share information about your creditworthiness with our affiliates, other than as permitted by Vermont law, unless you authorise us to make those disclosures.