Privacy Notice

Effective Date: 20 July 2026
Last Reviewed: 20 July 2026

1. Introduction

Bakhter Money Transfer Ltd. (“Bakhter“, “we“, “our“, or “us“) is committed to protecting your privacy and handling your personal information fairly, lawfully, and transparently.

This Privacy Notice explains how we collect, use, store, share, and protect your personal information when you use our money transfer services, visit our website, use our mobile application, contact us, or interact with us in any other way.

As a UK-based Small Payment Institution providing international money transfer services, we process personal information in accordance with:

• UK General Data Protection Regulation (UK GDPR);
• Data Protection Act 2018;
• Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“Money Laundering Regulations 2017”); and
• other applicable UK legal and regulatory requirements.

Please read this Privacy Notice carefully before using our services.

2. Who We Are

Bakhter Money Transfer Ltd. is the Data Controller responsible for your personal information.

Address

S5, Kingsbury House
468 Church Lane
London NW9 8UA
Online Office Only

Email: info@bakhtermoneytransfer.co.uk

Bakhter Money Transfer Ltd. is registered with the Information Commissioner’s Office (ICO).

If you have any questions regarding this Privacy Notice or how we process your personal information, please contact us using the details above. Privacy enquiries are managed by our designated compliance team and Money Laundering Reporting Officer (MLRO), where appropriate.

3. Information We Collect

Depending on the services you use, we may collect the following categories of personal information:

Identity Information

• Full name
• Date of birth
• Nationality
• Residential address
• Government-issued identification (passport, driving licence, national ID card)
• Photographs or images used for identity verification

Contact Information

• Email address
• Telephone number
• Postal address

Financial Information

• Debit or credit card details
• Bank account details
• Transaction history
• Payment information

Transaction Information

• Sender and recipient details
• Amount transferred
• Purpose of payment
• Destination country
• Transaction reference numbers

Technical Information

When you use our website or mobile application we may collect:

• IP address
• Browser type
• Device information
• Operating system
• Mobile application version
• Time zone
• Website usage information
• Cookies and similar technologies

Identity Verification Information

To comply with legal and regulatory obligations, we may collect:

• Facial images
• Selfie or liveness images
• Identity document images
• Results of electronic identity verification

4. How We Collect Your Information

We collect personal information:

• directly from you;
• when you complete transaction forms;
• when you use our website or mobile application;
• when you contact us by telephone, email or post;
• from identity verification providers;
• from fraud prevention and sanctions screening providers;
• from publicly available sources where permitted by law;
• from banks, payment providers and correspondent institutions;
• from regulatory or law enforcement authorities where required.

Where you provide personal information relating to another individual, you must ensure that you have the authority to provide that information.

5. How We Use Your Personal Information

We use your personal information to:

• provide our money transfer services;
• process payments and international remittances;
• verify your identity;
• comply with anti-money laundering and counter terrorist financing legislation;
• detect and prevent fraud and financial crime;
• comply with legal and regulatory obligations;
• communicate with you regarding your transactions;
• manage customer accounts;
• improve our services;
• respond to enquiries and complaints;
• maintain business records;
• administer our website and mobile application;
• send marketing communications where permitted by law or where you have consented.

6. Our Lawful Basis for Processing

Under UK GDPR we process personal information using one or more of the following lawful bases:

Performance of a Contract

Where processing is necessary to provide the money transfer service you have requested.

Legal Obligation

Where processing is required to comply with legal obligations, including anti-money laundering legislation, sanctions requirements, fraud prevention, accounting obligations and regulatory reporting.

Legitimate Interests

Where processing is necessary for our legitimate business interests, including improving our services, protecting our business against fraud, maintaining security, handling complaints and defending legal claims, provided these interests do not override your rights and freedoms.

Consent

Where required by law, such as for certain marketing communications, we will ask for your consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

7. Anti-Money Laundering Requirements

As a regulated money remittance business, we are legally required to carry out customer due diligence and other checks to prevent money laundering, terrorist financing and proliferation financing.

We are required by law to collect and use certain personal information for these purposes.

Personal information collected for anti-money laundering purposes will only be used:

• to verify your identity;
• to conduct sanctions and politically exposed person (PEP) screening;
• to monitor transactions;
• to detect suspicious activity;
• to comply with our legal and regulatory obligations; or
• as otherwise permitted or required by law.

This information will not be used for direct marketing unless a separate lawful basis exists.

8. Identity Verification

To comply with our legal obligations, we use Veriff to assist with electronic identity verification.

This process may require you to upload identification documents and provide a facial image or selfie so your identity can be verified against your identity document.

These checks help us prevent fraud, identity theft and financial crime.

Where automated verification cannot confidently verify your identity, additional checks or manual review may be required before your transaction can proceed.

9. Who We Share Your Information With

We only share personal information where necessary.

This may include:

• banks and payment institutions;
• payment processors;
• identity verification providers, including Veriff;
• fraud prevention and sanctions screening providers;
• IT and cloud hosting providers;
• professional advisers;
• auditors;
• regulators;
• law enforcement agencies;
• courts where legally required;
• our payout partner(s) in Afghanistan for the purpose of completing your money transfer.

All third-party service providers are required to protect your information and only process it in accordance with applicable data protection laws.

10. International Transfers

As an international money transfer provider, some personal information may be transferred outside the United Kingdom where necessary to complete your transaction.

This may include transfers to our payout partner(s) in Afghanistan and certain technology service providers.

Where personal information is transferred internationally, we will ensure that appropriate safeguards are in place as required by UK data protection law.

You may contact us if you would like further information about the safeguards we use.

11. How Long We Keep Your Information

We only retain personal information for as long as necessary to fulfil the purposes for which it was collected or to comply with legal obligations.

Where required under the Money Laundering Regulations 2017, we generally retain customer due diligence records and sufficient transaction records for five years after:

• the end of the business relationship; or
• the completion of an occasional transaction.

After this period, personal information will normally be securely deleted unless we are required or permitted by law to retain it for longer, including for legal proceedings or regulatory investigations.

12. Marketing Communications

We may send you information about our products and services by SMS or email where permitted by law.

You may opt out of receiving marketing communications at any time by:

• clicking the unsubscribe link contained within our emails;
• following the opt-out instructions contained in SMS messages; or
• contacting us directly.

Please note that opting out of marketing communications will not prevent us from sending service-related communications about your transactions or your account.

13. Your Rights

Under UK GDPR, you may have the right to:

• request access to your personal information;
• request correction of inaccurate information;
• request deletion of your personal information in certain circumstances;
• request restriction of processing;
• object to processing carried out under legitimate interests;
• request transfer of your personal information where applicable;
• withdraw consent where processing is based on consent.

Some of these rights may be restricted where we are legally required to retain or process personal information under anti-money laundering legislation or other legal obligations.

14. Automated Decision Making

Some fraud prevention, sanctions screening and identity verification checks may involve automated processing.

Where a decision cannot be confirmed automatically, your application or transaction may be reviewed manually before a final decision is made.

You may contact us if you believe an automated decision has affected you unfairly.

15. Data Security

We maintain appropriate technical and organisational security measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

Access to personal information is limited to employees, contractors and service providers who require it to perform their duties.

Although no method of transmitting information over the internet or storing data electronically can be guaranteed to be completely secure, we continually review and improve our security measures to help protect your personal information.

16. Cookies

Our website uses cookies and similar technologies to improve functionality, analyse website usage and enhance your browsing experience.

Further information is available in our separate Cookie Policy.

17. Children’s Privacy

Our services are intended for individuals aged 18 or over.

We do not knowingly collect personal information from children.

If we become aware that we have collected personal information from a child without appropriate legal authority, we will take reasonable steps to delete that information.

18. Changes to this Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in legal requirements, regulatory guidance or our business practices.

The latest version will always be published on our website together with the effective date.

Where changes are significant, we will take reasonable steps to notify customers where appropriate.

19. Contact Us

If you have any questions about this Privacy Notice or how your personal information is handled, please contact us:

Bakhter Money Transfer Ltd.

S5, Kingsbury House
468 Church Lane
London NW9 8UA
Online Office Only

Email: info@bakhtermoneytransfer.co.uk

If you remain dissatisfied with how we have handled your personal information, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). We encourage you to contact us first so that we have the opportunity to resolve your concerns.