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. You can also write to our registered office marked “IBAN Cloud privacy”.
This notice covers site visitors, people who contact us and people named in a preliminary assessment. A later engagement may need more information and a further privacy notice. So may a provider’s own onboarding process.
2. Information we receive
The questions depend on who is applying and the services they need. We receive data from you or from someone authorised to send it on your behalf. Depending on the route, this can include:
- Contact details: name, email address, phone or other contact details, role and organisation.
- Personal details: date of birth, nationality, countries of residence and tax residence, address and occupation. We may also ask for a broad outline of the source of your funds or wealth.
- Business and institution details: activity, ownership, directors and beneficial owners, permissions, markets, expected volumes, counterparties and payment flows. Some of these details identify people.
- Compliance details: political exposure, sanctions status and account history. We also ask for risk or control details that relate to your questionnaire. The individual route asks about financial-crime investigations, proceedings or convictions, with broad context.
- Correspondence: the assessment you send and messages to clarify it or follow up.
- Referral source: if you follow a referral link, a source label is carried in the website address and included with your submitted enquiry. This tells us the referring source; it is not a unique visitor identifier. We do not store it in a referral cookie or other browser storage.
- Technical data: your IP address, browser details, requested URL and time, and other connection and request data. This also includes service and security events handled by providers that support the website and our communications. We also keep your cookie-choice record.
3. Before and after submission
Until you submit, your answers stay in your browser for the current session. We do not retain them. Closing or reloading the page clears your progress. Your browser settings control its own autofill and device history.
When you submit the questionnaire, we receive your answers for the uses set out in this notice. Service providers acting on our behalf process the form and help us run and protect the service. Sending an assessment does not open an account or amount to a banking decision.
After you submit, we keep the assessment and related messages in the systems we use to handle enquiries. The retention terms below apply.
Do not provide identity-document or tax identification numbers, bank or card details, passwords or private keys. Do not send 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 sharing data that may need extra safeguards.
4. Why we use information
We use your enquiry to learn what you need from an account and respond to you. We check for gaps in the details and consider relevant provider introductions.
Where a referral source accompanies your enquiry, we use it to identify the source of the request and coordinate introductions. Our basis is our legitimate interest in managing incoming enquiries and referral relationships.
For a person seeking services for themselves, we take steps at their request before a possible contract. This is our ordinary personal-data basis under UK GDPR Article 6(1)(b). For people who represent a company or are named in a business enquiry, we rely on legitimate interests (Article 6(1)(f)). These are our interests in assessing and responding to that enquiry. We take account of the people affected.
We use necessary technical records and correspondence to run the website, prevent abuse and look into service issues. We also use them to keep a record of requests. Our basis is legitimate interests in a reliable, secure service and handling disputes. If a specific legal obligation requires us to process data, Article 6(1)(c) applies to that obligation. We do not treat all preliminary screening as a legal obligation.
Some compliance data may need a further legal condition as well as an ordinary personal-data basis. A general form declaration does not allow unrestricted processing of special-category or criminal-offence information. Any further collection must be necessary for the specific purpose. The relevant legal condition and safeguards must also cover it.
With your separate cookie consent, Google Analytics measures use of our content pages. This helps us improve the website. Measurement stays off on the questionnaire. We do not send your answers to analytics. You can withdraw analytics consent through Cookie settings. Sending an enquiry does not sign you up for marketing. If you withdraw consent, earlier lawful processing stays lawful.
6. International processing
Some service providers work across borders. A cross-border introduction you request may also involve data use outside the UK or the country where you are located. Your choice of account country does not decide where website or enquiry data is processed.
Data-protection rules may require an adequacy decision for a transfer, or another valid transfer mechanism and safeguards. Contact onboarding@ibancloud.com to ask who receives data, where it goes and which transfer arrangements apply 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 keep answers you have not submitted after you close or reload the page. Your cookie-choice record lasts up to 180 days unless you clear it sooner.
We keep submitted assessments and correspondence for as long as needed to assess the request and follow up. We consider whether the enquiry is still active and whether an engagement follows. We also consider how sensitive the data is and any record-keeping duties that apply. A specific need to handle a complaint or legal claim can also affect how long we keep it. Not every enquiry needs the same period.
You can ask onboarding@ibancloud.com how long we keep data for your enquiry or request deletion. Data no longer needed for a lawful purpose should be deleted. A specific legal duty to keep it, or another exception that applies, may limit a deletion request.
8. Your choices and rights
You can choose whether to submit an assessment. Required fields are needed for the online assessment you select. This does not mean the law requires you to give us those details. If you prefer not to share a detail, contact us to discuss another option. Missing data may limit what we can assess.
Your rights depend on the law and the basis on which we process your data. You may request access, correction, deletion, restriction or a portable copy of your personal data. You can also withdraw consent where it is our basis for processing. Send requests to onboarding@ibancloud.com. We may need proportionate details to check your identity. We will reply within the legal timescales that apply.
You have the right to object to processing based on legitimate interests because of your particular situation. You can also object to any direct marketing. We will assess an objection under the law that applies. Rights may have exceptions; they do not all apply in every case.
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. We welcome the chance to address a concern.
9. Human review and information security
The questionnaire uses rules to show relevant questions. It checks that answers are complete and in the right format. It does not assign an approval score or make an automated account-opening decision with legal or similarly significant effects. People review provider choices and follow-up. Providers control their own onboarding decisions.
The assessment is not an end-to-end encrypted document room. Submitted data is processed in systems we use and those of the service providers described above. No online form or communication service can be guaranteed fully secure. Keep what you share proportionate to the request. Contact us before sending supporting evidence that may need extra safeguards.
The service is not intended for children under 18. If you think a child’s data was submitted, contact us so we can assess and address it.