Privacy Policy

Foren (formerly Leatherback) is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store and share it, and the rights you have over it.

Definitions

Personal Information (Personal Information Protection and Electronic Documents Act): Any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:

• Age, name, ID numbers, income, ethnic origin, or blood type;
• Opinions, evaluations, comments, social status, or disciplinary actions; and
• Employee files, credit records, loan records, medical records, existence of a dispute between a consumer and a merchant, intentions (for example, to acquire goods or services, or change jobs).

Personal Data (General Data Protection Regulation): Any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as:

• Name
• Identification number
• Location data
• Online identifier

One or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

For the purposes of this document, “personal data” will be used to reference both personal information as defined above, and personal data as defined above.

Personal Data we collect about you

We only collect the personal data we require from you for a specific and legitimate business purpose when:

• You sign up to use our services (e.g., when you provide us with personal details like your name and email address so we are able to contact you).
• We provide our services to you
• You participate in discussion boards or other social media functions on our Website or App, through entering a competition, promotion, or survey
• You report any issues with our services

The personal data we collect from you may include your:

• Name
• Address
• Contact information (e.g., Email address or phone number)
• Financial information, including credit card, debit card, or bank account information
• Payment purpose
• Geographical location
• Social security number
• Personal description

Personal data automatically collected from you

With each visit to our website or use of our services, we may automatically collect the following personal data:

• Technical information, including:
  • The Internet protocol (IP) address used to connect your computer to the Internet
  • Your login information
  • Browser type and version
  • Time zone setting
  • Browser plug-in types and versions
  • Operating system and platform
• Information about your visit, including:
  • The full Uniform Resource Locators (URL) clickstream to, through and from Our sites (including date and time)
  • Products you viewed or searched for
  • Page response times
  • Download errors
  • Length of visits to certain pages
  • Page interaction information (such as scrolling, clicks, and mouse-overs)
  • Methods used to browse away from the page
  • Any phone number used to call our customer service number

Personal data we receive from other sources

We may receive personal data about you if you use any of the other websites we operate or other services we provide including your:

• Name
• Contact information (e.g., Email address or phone number)
• Address

We also work closely with third parties such as payment partners, analytics providers, search information providers and credit reference agencies, and may receive personal data about you from them, including:

• Name
• Contact information (e.g., Email address or phone number)
• Address
• Credit information
• Research and analytics information
• Financial information

Where we receive personal data about you from another source, we will ensure this is in full compliance with applicable legislation.

Legal Basis for Processing Personal Data

The lawful basis we use for collecting and processing your personal data in Europe (as required by current legislation) are as follows:

• Where it is necessary for entering into or performing a contract with you.
• Where we have a legitimate interest to do so, provided your rights do not override those interests.
• Where you have consented to its uses.
• Where we believe it is in your vital interests to share your personal details.
• Where required to comply with our legal obligations.

Ways we Use your Personal Data

We use your personal data to:

• Carry out our obligations relating to your contract with us and to provide you with relevant information, products, and services
• Verify your identity before collecting, using, or disclosing your personal data
• Comply with any applicable legal and/or regulatory requirements
• Notify you about changes to our services
• Keep our services safe and secure
• Administer our services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
• Improve our services and to ensure that they are presented in the most effective manner
• Allow other Foren customers to request or send money to you through our services when providing matching information for your phone number or email
• Measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you
• Allow you to participate in interactive features of our services when you choose to do so
• Provide you with information about other similar goods and services we offer
• Combine information we receive from other sources with the information you provide to us. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive)

How we Protect your Personal Data

To protect your personal and financial data against unauthorized access, use, disclosure, copying, or modification, we employ stringent technologies and security measures. These measures include:

• Physical access controls, including:
  • Locked filing cabinets
  • Restricted access to offices
  • Alarm systems
  • A clean-desk policy
  • Secured premises
• Organizational measures, including:
  • Limiting access on a “need-to-know” basis
  • Security clearances and classifications
  • Confidentiality agreements
  • Specific security procedures
  • Information security training
  • Regular internal monitoring of information security systems
  • Regular independent monitoring and audit of information security systems
• Technological safeguards, including:
  • Identification requirements to establish legitimate identity for accessing personal information
  • Authentication (e.g., passwords)
  • System access controls
  • Secure channels for transmissions of personal information
  • Encryption of sensitive data in-storage and in transit
  • Firewalls and intrusion detection systems and procedures
  • Automatic audit trails for personal information processing systems
  • System security maintenance controls including logs
  • Security incident procedures and logs

If, at any time, we determine that a breach of our security safeguards poses a real risk of significant harm to you, we will notify you as soon as feasible and in alignment with applicable legislation.

Cookies

Our Services use cookies to distinguish you from other users. This helps us to provide you with a good experience and also allows us to improve our Services. For detailed information on the cookies we use and the purposes for which we use them see the Cookies Policy Page.

Your Rights

Subject to applicable laws, you may contact us to exercise your right to access personal data we hold about you. When exercising your right, we will always inform you of any lawful reason that may require us to continue processing your personal data such as if required for the prevention or detection of a crime.

You have the right to:

• Request from us information about whether we process your personal data and to ask questions about how we collect, store and process that data
• Access free information about the personal data we hold about you
• Know whether your personal data is transferred to a third country or international organisation and the associated safeguards we employ to protect it
• Receive any personal data we hold about you in a commonly used and machine-readable format
• Request we correct your personal data where this data is inaccurate or incomplete, and to have this corrected without undue delay
• Request that we delete any personal data we process about you, where the processing is no longer necessary for the purposes we have identified to you
• Remove your previously provided consent for our processing of your personal data, and for us to stop processing your personal data specific to that consent. To withdraw a consent that you have provided to us, please click here.
• Object to our processing of your personal data and/or restrict our processing of your personal data, subject to applicable laws and regulations

Sharing and Storing your Personal Data if you are a citizen of the European Economic Area (EEA)

In order to provide our Services to you, it is sometimes necessary for us to transfer your personal data to third parties that are based outside of the European Economic Area. In these cases, we ensure that both ourselves and our partners take adequate and appropriate technical, physical and organisational security measures to protect your personal data. We also ensure we have appropriate contractual protections (e.g. BCR, Standard Contractual Clauses) in place with these parties receiving the personal data outside the EEA.

Your personal data may also be stored outside of the EEA or processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things:

• The fulfilment of your payment order
• The processing of your payment details
• The provision of support services

By submitting your personal data, you agree to this transfer, storing and processing. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy.

Sharing your Personal Data with Third Parties

Foren will not share or sell your personal data to our affiliates or third parties without your consent, unless required or permitted by law.

Under certain circumstances, your personal data, including some or all of the categories of data set out under “Personal Data we collect about you”, will be shared with our affiliates and Third parties for the purposes of:

• Fulfilling your payment order
• Processing your payment details
• Helping you to achieve your financial goals
• Better understanding your financial needs
• Providing technical support services
• Conducting research and analytics
• Complying with obligations imposed by contracts, legislation, or regulations

External Sites

Our website 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.

Retaining your personal data

The period for which we will retain your personal and transactional data is dependent upon any statutory required retention periods we are required to comply with as a regulated financial institution. After the expiration of that period, we shall securely destroy your personal data, as long as it is no longer required for the fulfilment of any contract, initiation of a contract or in relation to other legal proceedings.

Changes to Our Privacy Policy

Any changes we may make to our Privacy Policy at a later date will be posted on this page and, where appropriate, we will notify you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

Responsible Authority for UK/EU Citizens

For the purpose of the Data Protection, the Data Protection Act 2018, and the General Data Protection Regulation, (the “Regulation”). The responsible authority for the collection, processing and use of personal data is:

LeatherBack Ltd (LeatherBack, “us”, “our” “we”) a global company with company number 12291057 and our registered office is at 77 Marsh Wall Street, London, E14 9SH

If you have any questions about how we protect or use your data, please email us at dpo@leatherback.co

Privacy Contact

If you have any inquiries relating to this Privacy Policy, would like to lodge a complaint regarding Foren’s Privacy policies and/or practices, or would like to exercise your rights of access to the personal data Foren holds about you, please contact:

Foren’s Privacy Policy contact

Email: dpo@leatherback.co

Mailing Address: 77 Marsh Wall Street, London, E14 9SH

If you have concerns with our adherence to applicable privacy legislation or the principles in this Policy, you have the right to contact the relevant regulatory and/or data protection authority.

In Uk, please contact the Information Commissioner’s Office (ICO)

In Canada, please contact the Office of the Privacy Commission of Canada. ■