1. Who we are

This Privacy & Cookie Policy explains how Soni Transfer Ltd (“Soni Transfer”, “we”, “us”, “our”) collects, uses, and protects your personal data.

• Company number: 10832378
• Registered office: 9 Waterloo Road, Birmingham, B66 4JX, United Kingdom
• ICO registration: ZA499115
• FCA registration: Small Payment Institution, ref. 798474

Soni Transfer acts as a data controller under UK and EU data protection law. Our services are intended for customers aged 18 and over.

2. What data we collect

• Identity data: full name, date of birth, nationality, ID documents, proof of address.
• Contact data: residential address, email, telephone number.
• Financial data: payment card details, bank account information, source of funds.
• Recipient data: beneficiary name, address, phone number (with their consent).
• Technical data: IP address, browser type/version, device type, login timestamps.
• Behavioural data: pages visited, clicks, drop-offs on our website or app.
• Support data: enquiries, complaints, correspondence.
• Marketing data: preferences, opt-in/opt-out status.

We may receive data from third parties, including your bank, KYC/AML providers, credit/fraud-prevention agencies, and public sources. We do not knowingly collect data from children.

3. Why we use your data and lawful bases

We will only process your personal data where we have a lawful basis
under UK GDPR or EU GDPR:

• Contract: to provide our remittance service and manage your account.
• Legal obligation: to comply with AML/CTF, tax, and record-keeping laws.
• Legitimate interests: to prevent fraud, keep systems secure, improve services.
• Consent: for marketing communications and non-essential cookies.

We do not sell your data to third parties.

4. Automated decisions and manual review

We use automated checks to help verify identity, prevent fraud and financial crime, and protect our services. These processes may automatically decline or pause an application or transaction.

If this happens, you will be notified, and you can request an explanation and a manual review

5. How we share your data

• Payment providers (banks, card processors)
• Payout partners in Gambia
• KYC/AML and fraud-prevention agencies
• Regulators and law enforcement where legally required
• Credit reference agencies (if applicable)



All third parties are required by contract to use personal data only for specified purposes
and to apply appropriate security measures.

6. International transfers

Some data may be transferred outside the UK/EU. We ensure safeguards like UK IDTA, EU SCC addendums, and transfer impact assessments.

7. Vulnerable customers

We record limited info to tailor our services for customers needing additional support (health or financial difficulties).

8. How we protect your data

• Encryption of data in transit and at rest
• Firewalls and intrusion detection
• Access controls and multi-factor authentication
• PCI-DSS compliant card processing
• Staff training on data protection and AML
• Breach response procedures, notifying ICO/EU DPAs and affected customers

9. How long we keep your data

• KYC/transaction data: 5 years after last transaction
• Complaints: 6 years after resolution
• Marketing data: until unsubscribe or 24 months of inactivity
• Cookies/analytics data: according to Cookie Policy

10. Your rights

You have rights under UK & EU GDPR, including access, rectification, erasure, restriction, portability, objection, withdraw consent, and not to be subject to automated decisions.

11. Cookies and tracking

We use essential, analytics, and marketing cookies. Non-essential cookies are only used with your consent. You can withdraw consent anytime via our cookie banner.

12. Changes to this policy

We may update this policy. Latest version will always be on our website. Significant changes will be communicated by email.

13. Contact us

• Email: support@sonitransfer.com
• Post: 9 Waterloo Road, Birmingham, B66 4JX, United Kingdom
• Phone/WhatsApp: +447438473456
• ICO (UK): www.ico.org.uk / 0303 123 1113
• EU residents: contact local Data Protection Authority EDPB