1. Introduction
Deekaye Solutions Limited ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our services or visit our website. We are registered in England and Wales and operate as an intermediary connecting UK-based clients with FCA-regulated foreign exchange brokers and providing custom financial software solutions.
2. Information We Collect
2.1 Personal Information You Provide
We collect personal information that you voluntarily provide to us, including:
- • Contact Information: Full name, email address, phone number, postal address
- • Identity Information: Date of birth, nationality, passport or driving license details
- • Financial Information: Bank account details, transaction history, source of funds documentation
- • Business Information: Company registration details, business purpose, financial statements
- • Transaction Details: Transfer amounts, currencies, beneficiary information, purpose codes
- • Communication Records: Emails, chat logs, phone call recordings, support tickets
2.2 Information Collected Automatically
When you visit our website or use our services, we automatically collect:
- • Technical Data: IP address, browser type and version, device type, operating system
- • Usage Data: Pages visited, time spent on site, click-through rates, download errors
- • Location Data: General geographic location based on IP address
- • Cookies and Tracking: Session cookies, preference cookies, analytics cookies
2.3 Information from Third Parties
We may receive information about you from:
- • Credit reference agencies and fraud prevention services
- • Identity verification services and AML screening providers
- • Our FCA-regulated partner brokers
- • Public databases and registries
3. Legal Basis for Processing
Under GDPR, we process your personal data based on the following legal grounds:
- • Contract Performance: To provide our intermediary services and fulfill our obligations to you
- • Legal Obligation: To comply with AML, KYC, and other financial regulations
- • Legitimate Interests: To improve our services, prevent fraud, and ensure security
- • Consent: For marketing communications and non-essential cookies (where applicable)
4. How We Use Your Information
4.1 Service Provision
- • Connect you with appropriate FCA-regulated FX brokers
- • Facilitate cross-border payment processing and transfers
- • Provide custom software development and integration services
- • Offer consultation and advisory services
4.2 Regulatory Compliance
- • Conduct KYC (Know Your Customer) and AML (Anti-Money Laundering) checks
- • Monitor transactions for suspicious activity
- • Report to relevant authorities as required by law
- • Maintain records for regulatory inspection
4.3 Business Operations
- • Risk assessment and management
- • Customer support and communication
- • Service improvement and development
- • Marketing and business development (with consent)
5. Information Sharing and Disclosure
5.1 Partner Brokers
We share necessary information with FCA-regulated partner brokers to facilitate your transactions. All partners are contractually bound to protect your data and comply with UK data protection laws.
5.2 Service Providers
We may share information with trusted third-party service providers who assist us in:
- • Identity verification and compliance screening
- • Payment processing and banking services
- • IT infrastructure and software development
- • Customer support and communication platforms
- • Legal, accounting, and professional advisory services
5.3 Legal Requirements
We may disclose your information when required by law or regulation, including to:
- • HM Revenue & Customs (HMRC)
- • Financial Conduct Authority (FCA)
- • National Crime Agency (NCA)
- • Other regulatory bodies and law enforcement agencies
5.4 Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity, subject to the same privacy protections.
6. International Transfers
We may transfer your personal data outside the UK and EEA to:
- • Partner brokers and financial institutions in other countries
- • Service providers with international operations
- • Regulatory authorities in destination countries for compliance purposes
All international transfers are protected by appropriate safeguards, including Standard Contractual Clauses, adequacy decisions, or other legally recognized mechanisms.
7. Data Security
We implement comprehensive security measures including:
- • Encryption: End-to-end encryption for data transmission and storage
- • Access Controls: Role-based access and multi-factor authentication
- • Network Security: Firewalls, intrusion detection, and regular penetration testing
- • Data Backup: Secure, encrypted backup systems with disaster recovery procedures
- • Employee Training: Regular data protection and security awareness training
- • Incident Response: Comprehensive data breach response and notification procedures
8. Your Rights Under GDPR
As a data subject, you have the following rights:
8.1 Right of Access
Request copies of your personal data and information about how we process it.
8.2 Right to Rectification
Request correction of inaccurate or incomplete personal data.
8.3 Right to Erasure
Request deletion of your personal data (subject to regulatory retention requirements).
8.4 Right to Restrict Processing
Request limitation of processing in certain circumstances.
8.5 Right to Data Portability
Request transfer of your data to another service provider in a structured format.
8.6 Right to Object
Object to processing based on legitimate interests or for direct marketing purposes.
Note: Some rights may be limited by regulatory requirements to maintain financial records for compliance purposes.
9. Data Retention
We retain your personal data in accordance with legal and regulatory requirements:
- • Transaction Records: 5 years from completion (as required by AML regulations)
- • Identity Documentation: 5 years from end of business relationship
- • Communication Records: 7 years (as required by financial services regulations)
- • Marketing Data: Until consent is withdrawn or 3 years of inactivity
- • Technical Logs: 12 months for security and system integrity
After retention periods expire, we securely delete or anonymize your data unless continued retention is required by law.
10. Cookies and Tracking Technologies
We use cookies and similar technologies to:
- • Essential Cookies: Enable core website functionality and security
- • Analytical Cookies: Understand website usage and improve performance
- • Functional Cookies: Remember your preferences and settings
- • Marketing Cookies: Deliver relevant advertising (with consent)
You can manage cookie preferences through your browser settings or our cookie consent tool.
11. Updates to This Policy
We may update this Privacy Policy periodically to reflect changes in our practices, services, or legal requirements. We will notify you of significant changes by email or through prominent website notices. Continued use of our services after updates constitutes acceptance of the revised policy.
12. Contact Information and Complaints
Data Protection Officer
Email: dpo@deekaye.com
Phone: +44 20 8058 1582
Address: Deekaye Solutions Limited, 171 High Street, Hounslow, England, TW3 1QL
Regulatory Complaints
If you are unsatisfied with our response to your privacy concerns, you have the right to lodge a complaint with:
Information Commissioner's Office (ICO)
Website: ico.org.uk
Phone: 0303 123 1113
Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF