Version 1.0, October 2026
This policy explains how Swift Finance Ltd uses the personal data of the people who use its online money transfer service and of the people they send money to.
1. Who we are
Swift Finance Ltd is a payment institution authorised by the Financial Conduct Authority (firm reference 805769) and supervised by HM Revenue and Customs under the Money Laundering Regulations 2017. We are the controller of your personal data and are registered with the Information Commission (ICO) under reference ZA354921. Our Managing Director is our Data Protection Officer. You can contact us about your data by email or by telephone, using the contact details shown on the Contact Us page of our website.
2. The data we hold
- About you: name, date of birth, address, contact details, identity document, a selfie to verify your identity, proof of address, account and device details including IP address, payment details, transaction history, screening results, your risk rating, the checks we have made, any evidence of the source of your funds or wealth that we ask for, and our correspondence and call recordings.
- About your beneficiary: name, country, payout details and screening results. We receive these details from you.
The selfie is biometric data. Screening results and any suspicion of money laundering or fraud may be criminal offence data. We use both only where the law allows (section 4).
3. Why we use your data and our lawful basis
- Contract: to open your account and carry out your transfers.
- Legal obligation: to check your identity, screen you and your beneficiary against sanctions and other lists, keep records and report where the law requires, under the Money Laundering Regulations 2017, the Proceeds of Crime Act 2002, the Payment Services Regulations 2017 and sanctions law. Data collected for these checks is used only to prevent money laundering and terrorist financing, unless another law allows otherwise or you agree.
- Legitimate interests: to prevent fraud and protect the service, where your rights do not override these interests.
- Consent: to send you marketing by email or text message. If you are already our customer, we may also send you messages about our own similar services unless you have told us not to. You can refuse marketing when you sign up and at any time, and every message tells you how to opt out.
The law requires us to collect the data we use for identity checks and screening, and we need your and your beneficiary's details to carry out your transfers. Without them we cannot open your account or make a transfer.
4. Biometric and criminal offence data
We use your selfie only to verify your identity, and screening results only to meet our legal duties, under the substantial public interest conditions in Schedule 1 of the Data Protection Act 2018 for preventing unlawful acts and meeting regulatory requirements.
5. Automated checks
Identity verification, screening and the compliance rules on our platform run automatically. Where a check raises an issue, a member of our staff reviews it before a decision is made on your account or transfer.
6. Who we share your data with
We share your data only as needed to provide the service or meet a legal duty: with our providers (cloud hosting provider, identity verification supplier, compliance check provider, email risk check provider, payment gateway, bank, payout provider and telephone system provider), and with the National Crime Agency, the Financial Conduct Authority, HM Revenue and Customs, the Office of Financial Sanctions Implementation, the police or a court where the law requires; with the Financial Ombudsman Service if you refer a complaint to it; and with Report Fraud where we report a suspected fraud. Each provider that processes your data for us acts only on our instructions under a written contract.
7. Where your data is held and transfers outside the UK
Your data is held on our platform, which is hosted by our cloud hosting provider. Sending money abroad means your beneficiary's details and the payment instruction go to our payout provider in the destination country; this is necessary to carry out the transfer you ask for. Any other transfer of your data outside the UK is made only where UK adequacy regulations cover the country or appropriate safeguards, such as the International Data Transfer Agreement, are in place.
8. How long we keep your data
We keep identity records for at least five years after our business relationship with you ends, and transaction records for at least five years after the relationship ends or, for a one-off transaction, after the transaction is complete, as the Money Laundering Regulations 2017 require. We then delete them securely, unless the law requires us to keep them longer or we have been told of an investigation. Marketing preferences are kept until you withdraw your consent.
9. Keeping your data secure
Connections to our website, apps and platform are encrypted, access to your data is limited to staff who need it, and card payments are processed by our payment gateway under the Payment Card Industry Data Security Standard. Please keep your password secure and tell us at once if you think someone else knows it.
10. Your rights
You have the right to be informed about how we use your data; to access it; to have it corrected; to have it erased; to restrict or object to its use; to data portability; and not to be subject to a decision based solely on automated processing that has legal or similarly significant effects without the safeguards the law requires. We answer requests free of charge within one month; for complex or numerous requests we may extend this by up to two further months and will tell you why. We verify your identity before we answer. Some rights are limited by law: we cannot erase records we must keep under the Money Laundering Regulations 2017 before the end of the retention period, and we may withhold information where disclosing it would be likely to prejudice the prevention or detection of crime.
11. Cookies
Our website and apps use essential cookies to work. We set other cookies only with your consent, which you can change at any time in your browser or app settings. Cookies are kept only for as long as each one needs to work, or for the period shown when you give your consent.
12. Complaints
If you are unhappy with how we use your data, please contact us first. You also have the right to complain to the Information Commission (ICO) at www.ico.org.uk.
13. Changes to this policy
We review this policy every year and whenever our use of personal data changes. The current version is always available on our website.