privacy policy

‍“Jenzy,” “we,” “us,” and “our” refers to:
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Jenzy Ltd, a company registered in England and Wales with its registered office at 20 Wenlock Road, London, N1 7GU.

We are committed to protecting your privacy and handling your personal data in a transparent, secure, and lawful manner.

‍About This Privacy Notice

‍For the purposes of data protection law, we are a data controller in respect of your personal data. We are responsible for ensuring that we use your personal data in compliance with data protection law.

This privacy notice applies if you are an end user of Relay by Jenzy or a representative, director, or shareholder of one of our institutional clients. The privacy notice sets out the basis on which any personal data about you that you provide to us, that we create, or that we obtain about you from other sources, will be processed by us. Please take the time to read and understand this privacy notice.

Important Note: Relay by Jenzy does not custody funds. We facilitate cross-border payments and remittances through licensed financial partners and service providers who handle the actual transfer of funds, compliance screening, and regulatory requirements on our behalf.

‍Personal Data We Collect About You

‍We will collect and process the following personal data about you:

‍Information You Provide to Us

‍Information about you that you give us by filling in forms or by communicating with us, whether in-person, by phone, email, or otherwise. This information may include:

Full name
Date of birth
Contact details (postal/shipping address, billing address, email address, and phone number)
Country of residence
Government-issued ID or passport information
On-chain wallet address (for cryptocurrency-related transactions)
Bank account details or open banking credentials (shared securely with our licensed partners)
Photograph (for identity verification purposes)
Business name and industry (for institutional clients)
Information about the beneficial owners, authorised users, or contact persons (for business clients)

‍Information We Collect or Generate About You

‍Contact details (postal/shipping address, billing address, email address, and phone number)
Country of residence

Transaction data, including:
Date of transaction(s)Transaction amount
Transaction currency
Counterparty information (recipient/sender details)
Payment method
Payment type
Transaction status and history
Device and usage information relating to your interaction with our platform
Communication records with our team

‍Information We Obtain From Third Parties

‍Information provided by KYC/KYB (Know Your Customer/Know Your Business) licensed partners to carry out background screening checks (e.g., sanctions screening, PEP lists, adverse media checks)
Information provided by wallet screening and transaction monitoring providers to verify that the wallet and funds being used are not connected to fraudulent or criminal activity
Information from our licensed financial partners necessary to process transactions and comply with regulatory requirements

‍Uses of Your Personal Data

‍Your personal data may be stored and processed by us in the following ways and for the following purposes:

‍For End Users

‍To verify that you are who you say you are (identity verification)
To confirm that you have the legal authority and sufficient capacity to conduct transactions
To ensure you are not associated with fraud, sanctions violations, criminal activity, or other prohibited activities
To process your cross-border payment or remittance requests through our licensed partners
To communicate with you regarding your transactions, account, or our services
To comply with legal, regulatory, and tax obligations
To detect, prevent, and address fraud, security, or technical issues
To maintain and improve our platform and services

‍For Institutional Clients and Their Representatives

‍To communicate with you regarding your organisation's use of our services
To verify that your organisation and its beneficial owners, authorised users, or contact persons are who they say they are
To ensure your organisation is eligible to use our services
To conduct background checks relating to fraud, sanctions, crime, and regulatory compliance
To process transactions and facilitate fund transfers through our licensed partners
To comply with legal and regulatory obligations applicable to your organisation

‍Legal Basis for Processing

‍We are entitled to use your personal data in these ways because:

We have legal and regulatory obligations that we must discharge (including AML/CFT, sanctions compliance, and tax reporting requirements)
We may need to in order to establish, exercise, or defend our legal rights or for the purpose of legal proceedings
The use of your personal data as described is necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates), including operating our platform, preventing fraud, and ensuring the safety and security of our users and services
We have your consent to process certain data in specific ways (which you may withdraw at any time, subject to legal obligations)

‍Disclosure of Your Information to Third Parties

‍We will take steps to ensure that your personal data is accessed only by our employees and authorised service providers who have a legitimate need to do so for the purposes described in this notice.

‍We May Share Your Personal Data:

‍With Our Licensed Partners and Service ProvidersLicensed financial institutions and payment processors who handle the actual transfer of funds on your behalf
KYC/KYB providers and compliance vendors who conduct identity verification and background screening
Wallet screening and transaction monitoring providers
Data storage and cloud infrastructure providers
Analytics and reporting providers
These third parties are subject to strict confidentiality requirements and data processing agreements that obligate them to protect your personal data and use it only as described in this privacy notice
For Business Reasons
If we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes
If we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer
As Required by Law
To the extent required by law, including if we are under a duty to disclose your personal data to comply with any legal obligation, court order, government request, or to establish, exercise, or defend our legal rights

Important: We do not share your personal data with third parties for marketing purposes without your explicit consent.

‍Transfers of Personal Data Outside the European Economic Area (EEA) and UK

‍The personal data that we collect from you may be transferred to, and stored at, a destination outside the EEA/UK. It may also be processed by staff operating outside of the EEA/UK who work for our affiliates, our licensed partners, or our service providers.

Where we transfer your personal data outside the EEA/UK, we will ensure that it is protected in a manner consistent with how your personal data is protected by us in the EEA/UK. This is done through:

Transferring data to countries approved by the European Commission/UK Government as providing an adequate level of protectionRequiring recipients to have adhered to binding corporate rules (for intra-group transfers)

Requiring recipients to sign contracts based on "model contractual clauses" approved by the UK Government/European Commission, obliging them to protect your personal data
Other mechanisms permitted by applicable data protection lawIn all cases, we ensure that any transfer of your personal data is compliant with data protection law.
You can obtain more details of the protection given to your personal data when it is transferred outside the EEA/UK (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us as described in the "Contacting Us" section below.

‍Retention of Personal Data

‍How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

Purpose of use: We will retain data for as long as is necessary for the purpose for which it was collected (e.g., for the duration of your relationship with us and to fulfill your transaction requests)
Legal obligations: Laws and regulations may set minimum periods for which we must retain your personal data, particularly in relation to anti-money laundering, counter-terrorism financing, tax, and consumer protection requirements
Dispute resolution: We may retain data longer if necessary to resolve disputes or defend against legal claims
Legitimate business interests: We may retain certain anonymised or aggregated data for analytics and service improvement purposes
After the retention period expires, we will securely delete or anonymise your personal data unless we have a legal obligation or legitimate reason to retain it.

‍Your Rights

‍You have a number of legal rights in relation to the personal data that we hold about you. These rights include:

Right of access: The right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you
Right to withdraw consent: The right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so
Right to data portability: In some circumstances, the right to receive your personal data in a structured, commonly used, and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us
Right to rectification: The right to request that we correct your personal data if it is inaccurate or incomplete
Right to erasure: The right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data, but we are legally entitled to retain it (particularly for AML/CFT and regulatory compliance purposes)
Right to restrict processing: The right to object to, and the right to request that we restrict, our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to or ask us to restrict our processing of your personal data but we are legally entitled to continue processing your personal data and/or to refuse that request
Right to lodge a complaint: The right to lodge a complaint with the data protection regulator if you think that any of your rights have been infringed by usYou can exercise your rights by contacting us using the details set out in the "Contacting Us" section below. We will respond to your request within the timeframe required by applicable data protection law.

‍Further Information About Your Rights

‍Further information about your rights may be obtained by contacting the supervisory data protection authority located in your jurisdiction

:In the UK: Information Commissioner's Office (ICO) - https://ico.org.uk/
‍In the EU: A list of National Data Protection Authorities can be found at the European Commission's website

‍Data Security

‍We take the security of your personal data seriously. We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. However, no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

‍Changes to This Privacy Notice
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‍We may update this privacy notice from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the updated privacy notice on our platform or by sending you an email to the address associated with your account. Your continued use of Relay by Jenzy following the posting of revised privacy notice means that you accept and agree to the changes.

‍Contacting Us

‍If you would like further information on the collection, use, disclosure, transfer, or processing of your personal data, or to exercise any of the rights listed above, please address questions, comments, and requests to:hello@relay.ingWe will endeavour to respond to your request as soon as possible and in accordance with applicable data protection law.
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