1. Who is responsible
For the website and preliminary assessment, the controller is SKY7 Fintech Solutions Ltd, a company incorporated in England and Wales (company number 15764792), with its registered office at 128 City Road, London EC1V 2NX, United Kingdom. Send privacy questions, requests or concerns to onboarding@ibancloud.com, or write to our registered office marked “IBAN Cloud privacy”.
This notice covers visitors, people making enquiries and individuals named in a preliminary assessment. A later engagement or a provider’s own onboarding process may require additional information and a further privacy notice.
2. Information we receive
The questions adapt to the applicant and the services requested. We receive information directly from you, or from a person authorised to submit it on your behalf. Depending on the route, it can include:
- Contact information: name, email address, telephone or other contact details, role and organisation.
- Personal circumstances: date of birth, nationality, residence and tax-residence countries, address, occupation, and high-level source-of-funds or wealth information.
- Business and institutional information: activity, ownership, directors and beneficial owners, permissions, markets, expected volumes, counterparties and payment flows. Some of this identifies individuals.
- Relevant compliance context: political exposure, sanctions status, account history and the risk or control information requested by your questionnaire. The individual route also asks about financial-crime investigations, proceedings or convictions and related high-level context.
- Correspondence: the assessment you submit and messages exchanged to clarify or follow up on it.
- Technical information: connection and request data such as IP address, browser information, requested URL and time; service and security events processed by providers that support the website and communications; and your cookie-preference record.
3. Before and after submission
Until you submit, your answers remain in your browser for the current session and are not retained by us. Closing or reloading the page clears your progress. Your browser’s own autofill or device history is controlled by your browser settings.
When you submit the questionnaire, we receive your answers for the purposes described in this notice. Service providers acting on our behalf process the submission and help us operate and protect the service. Submitting an assessment does not open an account or amount to a banking decision.
After submission, we retain the assessment and related correspondence in the systems we use to handle enquiries, subject to the retention terms below.
Do not provide identity-document or tax identification numbers, bank or card details, passwords, private keys, document links or files. Do not include health information, political or religious opinions or detailed criminal allegations in general free-text answers. Contact us before providing information that may need additional safeguards.
4. Why we use information
We use enquiry information to understand the account requirement, respond, identify information gaps and consider relevant provider introductions. For an individual requesting services for themselves, the ordinary personal-data basis is taking steps at their request before a possible contract (UK GDPR Article 6(1)(b)). For corporate representatives and people named in a business enquiry, we rely on legitimate interests in assessing and responding to that enquiry (Article 6(1)(f)), taking account of the people affected.
We use necessary technical and correspondence records to operate the website, prevent abuse, investigate service issues and maintain a record of requests. Our basis is legitimate interests in a reliable, secure service and handling disputes. Where a specific legal obligation requires processing, Article 6(1)(c) applies to that obligation; we do not treat all preliminary screening as a legal obligation.
Certain compliance information can require an additional legal condition beyond an ordinary personal-data basis. A general form declaration does not authorise unrestricted processing of special-category or criminal-offence information. Any additional collection must be necessary for the specific purpose and covered by the relevant condition and safeguards.
With your separate cookie consent, Google Analytics measures use of our content pages to help improve the website. Measurement stays off on the questionnaire, and we do not send your answers to analytics. You can withdraw analytics consent through Cookie settings. Submitting an enquiry does not subscribe you to marketing. Withdrawing consent does not make earlier lawful processing unlawful.
6. International processing
Some service providers operate internationally, and a requested cross-border introduction may involve processing outside the UK or the country where you are located. An account-country preference does not determine where website or enquiry data is processed.
Applicable data-protection rules may require an adequacy decision or another valid transfer mechanism and safeguards for a particular transfer. Contact onboarding@ibancloud.com for information about the recipients, locations and transfer arrangements relevant to your enquiry. We do not promise that all information remains in the UK or EEA.
7. How long information is kept
We do not retain unsubmitted questionnaire answers after you close or reload the page. The cookie-preference record lasts up to 180 days unless you clear it sooner.
Submitted assessments and correspondence are kept for as long as needed to assess the request and conduct relevant follow-up. The retention decision takes into account whether the enquiry remains active, whether an engagement follows, the information’s sensitivity, applicable record-keeping duties, and a specific need to deal with complaints or legal claims. Not every enquiry needs the same period.
You can ask onboarding@ibancloud.com about the retention applicable to your enquiry or request deletion. Information no longer needed for a lawful purpose should be deleted; a deletion request may be limited by a specific legal retention requirement or other applicable exception.
8. Your choices and rights
Submitting an assessment is voluntary. Fields marked as required are needed for the selected online assessment, not a statement that the law requires you to provide them to us. If you prefer not to provide a requested detail, contact us to discuss an alternative; missing information may limit what we can assess.
Depending on the applicable law and processing basis, you may request access, correction, deletion, restriction or a portable copy of your personal information. You can also withdraw consent where it is the basis for processing. Use onboarding@ibancloud.com; we may need proportionate information to verify your identity and will respond within the applicable legal timescales.
You have the right to object to processing based on legitimate interests because of your particular situation, and to object to any direct marketing. We will assess an objection in accordance with applicable law; not every right applies without exceptions in every circumstance.
You can complain to the UK Information Commissioner’s Office, or another competent data-protection authority where applicable. You do not have to contact us first, although we welcome the opportunity to address a concern.
9. Human review and information security
The questionnaire applies rules to show relevant questions and check that answers are complete and correctly formatted. It does not assign an approval score or make an automated account-opening decision with legal or similarly significant effects. Provider selection and follow-up involve human review, and providers control their own onboarding decisions.
The assessment is not an end-to-end encrypted document room. Submitted information is processed in systems used by us and by the service providers described above. No internet-based submission or communication service can be guaranteed entirely secure, so keep disclosures proportionate and contact us before providing supporting evidence that may need additional safeguards.
The service is not intended for children under 18. If you believe a child’s information was submitted, contact us so that we can assess and address it.