Privacy Policy
Larimar Pay – DS Fleming Investments Ltd
Version: 1.0
Date: 01/12/2025
1. Introduction
Larimar Pay values the privacy of all users and is committed to protecting personal information in accordance with:
- UK GDPR
- Data Protection Act 2018
- ICO guidelines
- RemitJunction’s regulatory and compliance framework
This policy explains how Larimar Pay collects, uses, shares, and protects personal data.
2. Who We Are
Larimar Pay is a trading name of: DS Fleming Investments Ltd Company No: 16702029
Registered Address: 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ
Larimar Pay provides front-end digital services to facilitate remittances and related financial services. All regulated payment services are powered by RemitJunction Limited, FCA-registered and responsible for all regulated data.
3. Roles Under GDPR
RemitJunction Limited
Data Controller for:
- KYC documents
- Identity verification
- Transaction data
- AML screening
- Regulatory reporting
Larimar Pay (DS Fleming Investments Ltd)
Data Processor / Joint Controller (limited scope) for:
- Customer contact details
- Support interactions
- Marketing preferences
- Analytics and UX behaviour
- Referral program data
Note: Larimar Pay does not store or process sensitive identity documents.
4. What Data We Collect
We collect only data necessary for our front-end services:
Personal Data:
- Name
- Email address
- Phone number
- Country of origin/residence
- Communication preferences
- Device information
- Usage analytics
We do NOT collect:
- Passport copies
- ID documents
- Utility bills
- Bank statements
- Biometric data
This is exclusively collected/stored by RemitJunction.
5. Purpose of Processing
We process data to:
- Create user accounts
- Provide customer support
- Improve the user experience
- Send service notifications
- Provide marketing/loyalty offers
- Ensure platform safety
We do not use data for automated decision-making or profiling beyond analytics tools.
6. Legal Basis
We rely on:
- Consent (marketing)
- Legitimate interest (customer support, fraud prevention)
- Contractual necessity (operating the platform)
7. Sharing of Data
We share customer data only with:
- RemitJunction (for regulated service delivery)
- Secure service providers (hosting, analytics, messaging)
- Compliance partners approved by RemitJunction
We never sell data to third parties.
8. International Transfers
Where data is transferred outside the UK, we ensure:
- Standard Contractual Clauses
- Secure encrypted transmission
- Compliance with UK GDPR
9. Data Retention
Larimar Pay retains:
- Account information: While the customer remains active
- Marketing data: Until consent is withdrawn
- Support records: 6 years (standard UK business practice)
KYC/transaction data retention is handled by RemitJunction.
10. User Rights
Users may exercise:
- Right to access
- Right to rectification
- Right to erasure
- Right to restriction
- Right to data portability
- Right to withdraw marketing consent
Requests can be submitted at: [email protected]
11. Security Measures
We implement:
- Encryption
- Access controls
- Secure hosting
- Audit logs
- Data minimisation
- Staff training
- Secure password policies
12. Cookies
Our website and app may use cookies for:
- Analytics
- Performance monitoring
- User login sessions
Users can disable cookies anytime.
13. Changes to this Policy
We will update this policy as needed following regulatory or technical changes.
14. Contact
For privacy enquiries: Data Protection Lead – Larimar Pay
71–75 Shelton Street, London WC2H 9JQ
For regulated transaction data: RemitJunction Limited (Data Controller)