Privacy Policy
How we collect, use, and protect your personal data.
1. Who We Are
Lanova Pay Ltd ("we", "us", or "our") is the Data Controller responsible for your personal information. We are committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
- Company Number: 15855855
- Registered Address: Level 39, One Canada Square, Canary Wharf, London, E14 5AB.
- Data Protection Contact: privacy@lanovapay.com
2. The Data We Collect
We collect different types of data depending on how you interact with us.
A. Data We Collect Now (Pre-Launch)
- Contact Information: Name and email address (e.g., when you join our waitlist or contact support).
- Technical Data: IP address, browser type, and device information collected via cookies to ensure website security.
- Marketing Preferences: Your consent to receive launch updates.
B. Data We Will Collect (Upon Launch)
Once our services are live and you open an account, we will collect:
- Identity Data (KYC): Passport/ID copies, selfie verification, and proof of address (required by Anti-Money Laundering laws).
- Financial Data: Bank account details, transaction history, and source of funds information.
- Beneficiary Data: Names and account details of people you send money to.
3. How We Use Your Data
Current Purposes (Waitlist Phase)
- To communicate with you: Sending you updates about our launch status (Lawful Basis: Consent).
- To improve our website: Analyzing site traffic to prepare for launch (Lawful Basis: Legitimate Interest).
- Security: Protecting our infrastructure from cyber-attacks (Lawful Basis: Legitimate Interest).
Future Purposes (Operational Phase)
- To provide payment services: Executing your transfers (Lawful Basis: Performance of Contract).
- Regulatory Compliance: Conducting fraud checks and identity verification (Lawful Basis: Legal Obligation).
4. Disclosure of Your Data
We do not sell your data to third parties. We may share your data with:
- Service Providers: IT and cloud hosting providers (e.g., AWS, Google Cloud) acting as processors.
- Professional Advisers: Lawyers, bankers, and auditors.
- Regulators: The Financial Conduct Authority (FCA) or HMRC, if required by law.
Note: Upon launch, we may also share data with banking partners and payment schemes (e.g., Faster Payments) to facilitate your transactions.
5. International Transfers
As a UK-based company, we primarily store data in the UK or the European Economic Area (EEA). If we transfer data outside these regions, we ensure a similar degree of protection is afforded to it by using UK government-approved contracts (International Data Transfer Agreements).
6. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.
- Waitlist Data: Retained until you withdraw your consent or request deletion.
- Transaction Data (Future): Once live, we are required by law to keep financial records for a minimum of 5 to 7 years.
7. Your Legal Rights
Under the UK GDPR, you have rights including:
- Right to Access: Request a copy of the personal data we hold about you.
- Right to Rectification: Request correction of inaccurate data.
- Right to Erasure: Request deletion of your data (subject to legal retention requirements).
- Right to Withdraw Consent: Unsubscribe from our waitlist at any time.
To exercise any of these rights, please email privacy@lanovapay.com.
8. Complaints
We take your privacy seriously. If you have a concern, please contact us first so we can resolve it.
You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).