The type of personal information we collect
In order to enable us to deal with your inquiries, open and operate an account or to generally provide you with our products and services and comply with laws and regulations, we may need to and/or may be required to collect, record, hold, use, disclose and store (i.e. “process”) personal information and financial information about you, including but not limited to:
- personal information to establish your identity and background;
- personal information that you provide when you apply for any of our products and services.
How we collect personal information
We obtain personal information in various ways, including but not limited to:
- when you register an account with Luno through our website;
- through your relationship with us, for example information provided by you when using our products or services, when taking part in customer surveys, competitions and promotions;
- from an analysis of the way you use and manage your account with us, from the transactions you make and from the payments which are made to/from your account;
- when you contact Luno through various methods such as application forms, email, letters and telephone calls. If you contact us or we contact you using telephone, we may monitor or record the phone call for quality assurance, training and security purposes;
- when we obtain any data and information from third parties (e.g. credit reference agencies, regulatory and enforcement agencies, identity verification services) and/or
- from such other sources in respect of which you have given your consent to disclose information relating to you and/or where not otherwise restricted.
How we use your personal information
Other than as stated above, we may use your personal information for one or more of the following purposes:
- to verify your account in accordance with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations;
- to assess your application for our products and services;
- to manage and maintain your account with us;
- to better manage our business and your relationship with us;
- to improve our products and services and to develop new products and services;
- to notify you about benefits and changes to the features of products and services;
- to administer offers, competitions and promotions;
- to respond to your enquiries and complaints and to generally resolve disputes;
- to update, consolidate and improve the accuracy of our records;
- to produce data, reports and statistics which have been anonymised or aggregated in a manner that does not identify you as an individual;
- to conduct research for analytical purposes including but not limited to data mining and analysis of your transactions with us;
- to meet the disclosure requirements of any law binding on Luno;
- for audit, compliance and risk management purposes;
- to assess financial and insurance risks;
- to conduct anti-money laundering checks; for crime detection, prevention and prosecution; to comply with any sanction requirements;
- for any other purpose that is required or permitted by any law, regulations, guidelines or relevant regulatory authorities.
Disclosure of personal information
As a part of providing you with our products and services, and for the management and operations of these products and services, and to comply with legal and regulatory requirements, we may be required or need to disclose information about you and your account with us to the following third parties:
- companies and organisations that act as our agents, affiliates and/or professional advisers;
- companies and organisations that assist us in processing or otherwise fulfilling transactions that you have requested;
- law enforcement, regulatory and governmental agencies;
- your advisers (including but not limited to accountants, auditors, lawyers, financial advisers or other professional advisers) where authorised by you;
- any other person notified by you as authorised to give instructions or to use the accounts, facilities, products or services on your behalf.
The aforementioned third parties may in some instances be located outside of your country.
We will otherwise treat your personal information as private and confidential and will not disclose your information to anyone outside Luno except:
- where you have given permission;
- where we are required or permitted to do so by law;
- where required or authorised by any order of court, tribunal or authority, whether governmental or quasi-governmental with jurisdiction over Luno;
- where we may transfer rights and obligations pursuant to our agreement with you;
- where we are required to meet our obligations to any relevant regulatory authority (whether in or outside your country).
Security of your personal information
Luno places great importance on ensuring the security of your personal information. We regularly review and implement up-to-date technical and organisational security measures when processing your personal information. Employees of Luno are trained to handle the personal information securely and with utmost respect, failing which they may be subject to disciplinary action.
Additional matters relating to personal information
Retention of personal information
Incomplete personal information
Where indicated (for example in application forms or account opening forms), it is obligatory to provide your personal information to us to enable us to process your application for our products or services. Should you decline to provide such obligatory personal information, we may not be able to process your application/request or provide you with our products or services.
Your right to access and update your personal information
You have a right to access your personal information. Please contact customer support if you wish to have access to your personal information. Luno will take steps to verify your identity before fulfilling your request.
If there are any changes to your personal data or if you believe that the personal data we have about you is inaccurate, incomplete, misleading or not up-to-date, please contact us so that we may take steps to update your personal data. Luno may use its discretion in allowing the corrections requested and/or may require further documentary evidence of the new information to avoid fraud and inaccuracy.
Contacting Luno in relation to personal information