Privacy Policy

1. Who we are and how to contact us

PayNovo (“we”, “us”, “our”) is a consultancy specialising in foreign exchange cost reduction, payment optimization, and risk mitigation. We assist individuals and businesses moving thousands to millions at a time.

Our team provides tailored support and expert guidance to help businesses navigate international payments with confidence. Through our extensive partner network, we offer business and individual accounts that facilitate currency conversion in 130+ currencies and seamless transactions across 160+ countries.

Our mission is to simplify international trade by offering personalized solutions, industry expertise, and a powerful partner platform.

If you have any questions about this Privacy Policy or how we handle your personal data, please contact:

Email: info@paynovo.co
Postal address: [Registered office address], England

2. What this Privacy Policy covers

This Privacy Policy applies to:

• your use of the PayNovo website and any client portals we provide;
• enquiries, onboarding and consultancy interactions with PayNovo;
• marketing communications and events organised by or with PayNovo; and
• information we receive from or share with our regulated partners in connection with these activities.

This Privacy Policy does not cover how our regulated partners (for example, UK and EU authorised e-money or payment institutions) process your personal data when they provide regulated services to you. Their own privacy notices will apply to those activities.

3. The personal data we collect

We may collect and process the following categories of personal data:

3.1 Identification and contact details

• Name, job title and role;
• Business name and contact details;
• Residential or business address;
• Email address and phone number;
• Copies of ID documents where required by our partners (e.g. passport, driving licence).

3.2 Compliance and onboarding information

• Date of birth and nationality;
• Know-your-customer (KYC) and anti-money laundering (AML) information;
• Ultimate beneficial owner (UBO) and director information;
• Source of funds / source of wealth information (where required);
• Results of sanctions, politically exposed person (PEP) and adverse media screening, where carried out by our partners.

3.3 Transaction and usage data

• Information about currency requirements, payment corridors and typical transaction sizes;
• Details of your interactions with PayNovo, including meetings, calls and emails;
• Information about how you use our website and any portals we provide (e.g. pages visited, time spent, clicks).

3.4 Marketing and communication preferences

• Records of your preferences for receiving marketing and updates from us;
• Information you provide when you subscribe to newsletters, complete forms, or participate in surveys or events.

3.5 Technical data

• IP address, browser type and version, time zone setting and location;
• Device identifiers, operating system and platform;
• Information collected through cookies and similar technologies (see section 10).

4. How we collect your personal data

We collect personal data through:

• direct interactions – when you complete forms on our website, contact us by email or phone, or meet with our team;
• our partners – when authorised partners share information with us to enable onboarding, account management or joint support;
• automated technologies – when you interact with our website or portals, we may collect technical data using cookies and similar tools;
• publicly available sources – such as company registries, sanctions lists and professional networking sites; and
• third-party service providers – for example, credit reference agencies or identity verification providers engaged by our partners.

5. Purposes and legal bases for processing

We only process your personal data where we have a lawful basis under UK GDPR and EU GDPR. The main purposes and legal bases are:

5.1 To respond to enquiries and provide consultancy

We use your contact and business information to respond to your enquiries, understand your requirements, and deliver foreign exchange and payment optimisation consultancy.

Legal basis: legitimate interests (to operate our business and provide services to prospective and existing clients).

5.2 To introduce you to regulated partners and support onboarding

We may share your information with our regulated partners so they can assess your application, perform their own KYC/AML checks, and open accounts for you.

Legal basis: performance of a contract or taking steps at your request prior to entering into a contract; compliance with legal obligations (for our partners); legitimate interests (to facilitate the introduction and onboarding process).

5.3 To manage our relationship with you

This includes maintaining records of your preferences, handling support queries, managing appointments, and notifying you about changes to our terms or policies.

Legal basis: performance of a contract; legitimate interests (to keep our records up to date and manage the relationship).

5.4 Marketing and insights

We may send you information about services, market updates or events that we think may be of interest, and analyse engagement to improve our communications.

Legal basis: legitimate interests (for B2B communications) or consent where required by law. You can opt out of marketing at any time by using the unsubscribe link in emails or contacting us.

5.5 Compliance, risk management and business operations

We process data to prevent fraud, manage risk, maintain security, comply with legal and regulatory obligations, and maintain appropriate business records.

Legal basis: compliance with legal obligations; legitimate interests (to protect our business and our partners, and to ensure the security of our systems).

6. Sharing your data

We may share your personal data with:

• Regulated partners – authorised e-money and payment institutions in the UK, EU and other jurisdictions, for onboarding, account opening, transaction execution and ongoing support.
• Service providers – companies that provide IT, hosting, security, CRM systems, communications tools, analytics and other support services to PayNovo.
• Professional advisers – including lawyers, auditors and consultants, where necessary for the establishment, exercise or defence of legal claims or for compliance and governance.
• Public authorities – regulators, law enforcement or courts, where we are required to do so by law or where disclosure is necessary to protect our rights or the rights of others.

We do not sell your personal data. Where we share data with partners or service providers, we require them to protect it in accordance with applicable data protection laws and appropriate contractual safeguards.

7. International transfers

PayNovo and many of our partners operate internationally. This means your personal data may be transferred to and processed in countries outside the UK and the European Economic Area (EEA), including where some of our partners and service providers are based.

When transferring personal data outside the UK or EEA, we will ensure that appropriate safeguards are in place, such as:

• an adequacy decision by the UK government and/or European Commission; or
• standard contractual clauses approved by the UK government and/or European Commission, together with additional safeguards where required.

8. How long we keep your data

We keep personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

• Enquiry and marketing data is typically retained for as long as we maintain an active relationship with you, and for a reasonable period afterward to manage follow-ups and our records.
• Data used in connection with introductions to regulated partners may be retained to evidence the nature of referrals, for compliance and for handling any disputes.
• Where legal or regulatory obligations apply (for example, under AML regulations), retention periods may be longer and are determined by the relevant laws and guidance.

When data is no longer needed, we will securely delete or anonymise it.

9. Your data protection rights

Under UK GDPR and EU GDPR, you may have the following rights in relation to your personal data, subject to certain conditions and exemptions:

• Right of access – to obtain confirmation of whether we process your personal data and a copy of that data.
• Right to rectification – to have inaccurate or incomplete data corrected.
• Right to erasure – to ask us to delete your data in certain circumstances (“right to be forgotten”).
• Right to restriction – to request that we limit the processing of your data in certain cases.
• Right to data portability – to receive your data in a structured, commonly used and machine-readable format and transmit it to another controller.
• Right to object – to object to processing based on legitimate interests or for direct marketing.
• Rights relating to automated decision-making – where automated decisions produce legal or similarly significant effects on you.

To exercise any of these rights, please contact info@paynovo.co. We may need to verify your identity before responding.

You also have the right to lodge a complaint with your local supervisory authority. In the UK, this is the Information Commissioner’s Office (ICO). If you are located in the EU, you may contact your local data protection authority.

10. Cookies and similar technologies

We use cookies and similar technologies to operate our website, enhance your experience, and understand how the site is used. Cookies may:

• be strictly necessary for the site to function (for example, to remember your cookie choices);
• help us analyse website traffic and performance; or
• support our marketing and communications.

Where required by law, we will request your consent before placing non-essential cookies on your device. You can change your cookie preferences at any time via your browser settings or any cookie management tools we provide.

11. Security

We take reasonable technical and organisational measures to protect personal data against loss, misuse and unauthorised access, alteration or disclosure. These measures include access controls, encryption in transit where appropriate, and regular security assessments of our systems and service providers.

No system can be guaranteed to be completely secure. If you believe your personal data may have been compromised in connection with PayNovo, please contact us immediately.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will post the updated version on this page with a new “Last updated” date at the top.

We encourage you to review this page periodically to stay informed about how we handle your personal data. If changes are material, we may notify you by email or through the website.