Last Updated: 23-Apr-2025

Effective Date: 23-Apr-2025

This Privacy Policy explains how Zambezi FX Ltd trading as Sahwira Money (“we”, “us”, or “our”)

Collects, uses, shares, and protects personal data obtained through our website: www.sahwiramoney.com (“Service”).

In accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018.

1.Data Controller

Zambezi FX Ltd

20-22 Wenlock Road

London, N1 7GU, UK

Email: compliance@zambezifx.com

Phone: +44 800 009 6282

2.Personal Data We Collect

We may collect the following categories of personal data:

–Full name

–Email address

–Telephone number

–Social media profiles (if linked to our services)

–Date of birth

–Residential address

–Identification documents (e.g., passport or national ID)

–Proof of address (e.g., utility bills)

–Bank or payment details

–IP address and device/browser information

This information is collected when you:

–Register for our services

–Complete a transaction

–Verify your identity (Know Your Customer – KYC)

–Contact us for support or feedback

–Interact with our website or digital platforms

3.Lawful Basis for Processing

We process your personal data under the following lawful bases:

–Contractual necessity: to provide services under our Terms of Use

–Legal obligation: to comply with anti-money laundering (AML) laws, HMRC and FCA requirements

–Legitimate interests: to improve our services, prevent fraud, and maintain security

–Consent: for direct marketing and promotional messages, where required

4.How We Use Your Data

Your data may be used for:

–Verifying your identity and fulfilling regulatory KYC obligations

–Processing transactions and managing accounts

–Preventing fraud, terrorism financing, and other financial crimes

–Communicating with you (e.g., support, updates)

–Marketing (only with your consent)

5.Sharing Your Data

We may share your data with:

–FCA and HMRC-regulated partners and service providers as follows:

–Payment processors and financial institutions

–Identity verification and fraud prevention agencies

–Communication gateways

–Analytics and technology providers assisting us in website performance

–Regulators, courts, or law enforcement, if legally required

We ensure all third parties adhere to equivalent data protection standards,

and sign data processing agreements where appropriate.

6.International Data Transfers

Where your data is transferred outside the UK, we ensure adequate safeguards are in place, such as:

–Adequacy regulations

–Standard Contractual Clauses (SCCs)

–Binding Corporate Rules

7.Data Retention

We retain personal data:

–As long as you maintain an account with us

–For a minimum of 5 years after the end of a business relationship or transaction, in accordance with AML requirements

–Longer if required by applicable laws, regulations, or for dispute resolution

8.Your Rights

Under the UK GDPR, you have the right to:

–Access your personal data

–Rectify inaccurate or incomplete data

–Request erasure (‘right to be forgotten’)

–Restrict or object to data processing

–Data portability

–Withdraw consent (where processing is based on consent)

–Lodge a complaint with the Information Commissioner’s Office (ICO)

To exercise these rights, email: compliance@zambezifx.com

9.Cookies and Tracking

We use cookies and similar technologies to improve website functionality and user experience.

For details, please refer to our Cookie Policy.

10.Security Measures

We implement appropriate technical and organisational measures to secure your data, including:

–Encrypted data transmission (SSL/TLS)

–Firewalls and access controls

–Secure server environments

However, no system is completely secure. You share data at your own risk.

11.Third-Party Links

Our website may link to external sites. We are not responsible for their privacy practices.

Please review their policies before providing personal data.

12.Changes to This Policy

We may update this policy to reflect legal, regulatory, or operational changes.

Material changes will be posted here with a new “Last Updated” date.

Where required, we will notify you in advance.

13.Contact & Data Protection Officer

If you have concerns or wish to exercise your rights, contact:

14.Data Protection Officer

Zambezi FX Ltd t/a Sahwira Money

Email: compliance@zambezifx.com

20-22 Wenlock Road, London, N1 7GU, United Kingdom