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Legal

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GENERAL

Information Security Policy

Account Opening Privacy Notice

Next of Kin / Beneficiary fund access policy

PERSONAL BANKING

Privacy policy

Terms of Service

Acceptable Use Policy

Consumer Card Terms (US)

Consumer Card Terms (International)

E-Sign & Electronic Communications Notice

BUSINESS BANKING

Terms and Conditions

Privacy policy

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Authorized User Agreement

Business Card Terms (International)

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E-Sign & Electronic Communications Notice

UK Privacy Policy

1. Introduction

This Privacy Notice explains how Grey Finance LTD ("Grey", "we", "us" or "our") collects, uses, shares and protects your personal information across our websites, applications, products, and related services (collectively, the “Services). we are committed to protecting your privacy and ensuring transparency in our data processing activities. This Privacy Notice  forms part of our Terms of Use.

This Privacy notice applies to your use of our Services through any device, including desktop, mobile, or tablet. It does not apply to services not owned or controlled by Grey, including third-party websites or platforms. Such third parties operate under their own privacy policies, and Grey is not responsible for their data handling practices.
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2. Who We Are

Grey Finance LTD is registered in England and Wales (company number 13849254) with our registered office at Suite Q, Athene House 86 The Broadway, Mill Hill, London, United Kingdom, NW7 3TD. We act as the data controller for the personal information we collect and process about you.

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3. Information We Collect and  Process 

To gain full access to our website and services, you must register for a Grey account. When you register for an account, we collect Personal Information which you voluntarily provide to us. Personal Information refers to information relating to an identified person or information that can be used to identify you, (e.g. name, email, address, bank details, telephone number). It may also include anonymous information that may be linked to you specifically, (e.g. IP address).

The Personal Information we have about you is directly made available to us when you:

  1. Sign up for a Grey Account;
  2. Use any of our services;
  3. Contact us or our customer support team;
  4. Fill our online forms;

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3.1 Core Data Categories

Type of Data What We Collect Why We Need It
Identity Data Full legal name and any previous names
Date and place of birth
Gender
Nationality and citizenship status
National Insurance number or tax identification number
Unique identifiers (account numbers, customer reference)
To verify your identity
To comply with anti-money laundering regulations
To fulfil our regulatory obligations as an e-money institution
Contact Data Residential address
Email addresses (personal and business)
Telephone numbers
Correspondence preferences
Emergency contact details
To communicate with you about your account
To send mandatory service notifications
To verify your residence
To prevent fraud
Financial Data Bank account details (account numbers, sort codes, IBANs)
Payment card information
Source of funds and wealth information
Income details
Tax residency status
To process your transactions
To prevent financial crime
To assess financial risk
To comply with tax regulations
Transaction Data Payment records (incoming and outgoing)
Transaction timestamps and locations
Merchant details
Transaction purposes and categories
Currency conversion details
Standing orders and direct debits
To maintain accurate transaction records
To provide transaction history
To detect suspicious activities
To improve our services
Technical Data IP addresses and connection data
Device identifiers and specifications
Operating system information
Browser type and version
Time zone and language settings
Mobile device information
To ensure secure access
To optimise service delivery
To prevent unauthorised access
To improve user experience
Profile Data Account preferences
Security settings
User behaviour patterns
Service usage history
Customer feedback
Survey responses
To personalise our services
To improve user experience
To maintain account security
To develop new features
Usage Data Login patterns
Feature utilisation
Navigation behaviour
Session duration
App/website interaction patterns
Error logs
To improve service functionality
To identify technical issues
To enhance user interface
To develop new features
Marketing and Communications Data Marketing preferences
Communication opt-ins/opt-outs
Preferred contact methods
Interest categories
Campaign response history
To manage marketing consents
To personalise communications
To respect your preferences
To improve our marketing efforts
Special Categories of Personal Data We generally do not actively collect or process special category data. However, we may incidentally process such data when:
It appears in identity documents (e.g., photograph in passport)
It's relevant for providing specific services
You choose to share it with us
To verify identity documents
To provide accessible services
To meet specific regulatory requirements

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3.2 Lawful Bases for Processing

We process your data based on the following legal grounds:

  • Contractual necessity
  • Legal obligations
  • Legitimate interests
  • Consent

Each of them is discussed in more detail below.

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3.2.1 Contractual Necessity

We process data where it is required for the purposes of entering into or fulfilling a contract between us. This includes situations required to:

  • To provide our services
  • To execute your payment instructions
  • To maintain your account
  • To deliver our core financial services

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3.2.2 Legal Obligations

We process data where it is required to fulfil our legal obligations. These legal obligations include but are not limited to:

  • Anti-money laundering checks
  • Counter-terrorist financing verification
  • Counter-proliferation financing compliance
  • Regulatory reporting requirements
  • Tax compliance obligations
  • Financial crime prevention

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3.2.3 Legitimate Interests

We process data for our legitimate interests where necessary and proportionate:

Legitimate Interest Purpose Data Involved Justification
1. Fraud Prevention and Detection Identify, prevent, and mitigate fraudulent activities. Transaction histories, account details, behavioural data Protects Grey and you from financial loss and security breaches.
2. Direct Marketing of Own Products and Services Inform you about new products, services, promotions, or updates. Contact information, transaction history, preferences Facilitates business growth and your engagement, with opt-out options available.
3. Improving Products and Services Analyse your data to enhance offerings and develop new features. Usage patterns, feedback, demographic information Enhances your satisfaction and maintains competitive advantage.
4. Customer Support and Service Management Handle your inquiries, resolve issues, and provide effective support. Contact information, account details, communication history Essential for maintaining high-quality customer service and operational efficiency.
5. Operational Efficiency and Business Management Manage day-to-day operations, including account management and billing. Financial records, account information, employee data Necessary for the smooth functioning and sustainability of the business.
6. Risk Management and Assessment Evaluate and manage risks such as credit, operational, and compliance risks. Financial data, credit histories, transaction records Helps in making informed decisions and maintaining financial stability.
7. Security of Systems and Data Protect IT systems from cyber threats, unauthorised access, and breaches. Access logs, security protocols, user credentials Ensures the integrity and confidentiality of sensitive information.
8. Communication of Important Information Send essential updates, changes in terms, and policy updates to customers. Contact information, account details Keeps customers informed and ensures compliance with regulatory requirements.
9. Data Analytics and Reporting Conduct internal analyses, performance monitoring, and generate reports. Aggregated transaction data, user behaviour metrics Supports business intelligence and informed strategic decision-making.
10. Compliance with Legal and Regulatory Obligations Ensure adherence to legal and regulatory requirements. Varies depending on the obligation (e.g., AML, Consumer Duty, Vulnerable Customer Treatment, Complaints Management, etc.) Maintains compliance with laws and regulations, which may overlap with legitimate interests.

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3.2.4 Consent

Lastly, we rely on your consent and where appropriate, we obtain your explicit consent for:

  • Marketing communications
  • Special category data processing
  • Cookies and tracking technologies
  • Third-party data sharing

Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

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Data Protection Principles

4.1 Security Measures

We take your data’s security seriously and have put in place strong measures to keep it safe. These include:

  • Encrypting your data: This applies both when it’s being sent over networks (in transit) and when it’s stored (at rest).
  • Restricting access: Only authorised individuals with proper credentials can access your data.
  • Regular checks: We routinely assess and update our security systems to stay ahead of potential risks.
  • Training our team: All staff undergo regular training to ensure they understand and comply with data protection practices.
  • Preparedness for incidents: If there’s ever a security issue, we have clear procedures in place to handle it quickly and minimise any impact.

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5. Data Retention

We keep your personal data for as long as necessary to meet regulatory and legal requirements, fulfil business needs, and improve our services. Specifically:

Retention Period Types of Data
5 years from the end of your business relationship with us or your last transaction - whichever is later Identity Data
Contact Data
Financial Data
Transaction Data
Technical Data
Profile Data
Usage Data
Until there is valid consent Marketing and Communications Data

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6. Categories of Recipients of Personal Data

6.1 Overview of Data Sharing

We share your personal data with various recipients to provide our services, meet regulatory obligations, and maintain security. All data sharing is conducted in accordance with applicable data protection laws and subject to appropriate safeguards.

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6.2 Categories of Recipients

Type Purpose Data Shared
Service Providers and Business Partners Transaction processing
Payment execution
Account funding
Financial settlements
Identity Data
Contact Data
Financial Data
Transaction Data
Technical Data
Technology and Infrastructure Providers Service delivery
System maintenance
Security operations
Technical support
Financial Data
Transaction Data
Technical Data
Usage Data
Profile Data
Identity and Verification Partners Identity verification
Document authentication
Address validation
Identity Data
Special Categories of Personal Data
Regulatory and Compliance Partners Fraud detection
Regulatory compliance
Risk assessment
Statutory reporting
Identity Data
Contact Data
Financial Data
Transaction Data
Technical Data
Professional Services Providers Legal compliance
Audit requirements
Professional advice
Service optimization
Identity Data
Contact Data
Financial Data
Transaction Data
Profile Data
Regulatory and Law Enforcement Bodies Regulatory supervision
Compliance monitoring
Statutory reporting
Investigation assistance
Identity Data
Contact Data
Financial Data
Transaction Data
Technical Data
Profile Data
Usage Data

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7. International Transfers

If your data needs to be transferred outside the UK or the European Economic Area (EEA), we ensure it’s handled with the same level of protection as required under UK laws. This includes:

  • Implementing safeguards and using standard contractual clauses approved for international data transfers.
  • Using proper mechanisms to ensure that all transfers comply with data protection regulations.
  • We make sure your data privacy rights are upheld, no matter where your information is processed.

We are committed to treating your data with the utmost care, ensuring compliance with all relevant laws and maintaining the highest standards of security.

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8. Your Privacy Rights

8.1 Core Rights

As a data subject, you are entitled to specific rights under data protection laws to give you control over your personal information. These include:

  • Access your data: Request a copy of the personal data we hold about you.
  • Correct inaccuracies: Ask us to fix any errors or incomplete information in your records.
  • Erase your data: Request deletion of your data, provided there’s no overriding legal or regulatory reason for us to keep it.
  • Restrict processing: Limit how we use your data, for instance, while you’re disputing its accuracy or lawfulness.
  • Data portability: Obtain a copy of your data in a portable format to transfer it to another service.
  • Object to processing: Refuse the use of your data for certain purposes, such as direct marketing or automated decision-making.

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8.2 Additional rights

In addition to the core rights, you may:

  • Withdraw consent: If we rely on your consent to process your data, you can revoke it at any time.
  • Complain to authorities: File a complaint with your local data protection authority if you believe your rights have been violated.
  • Challenge automated decisions: Contest decisions made solely by automated systems that significantly affect you, and request human intervention.
  • Request processing limitations: Temporarily or permanently limit certain types of data processing.

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8.3 Exercising your rights

We’ve made it easy for you to exercise your privacy rights:

  1. Reach out directly for guidance or to submit a request.
  2. Submit a rights request via the designated section in our app.
  3. Send an email to dpo@grey.co with your request details.

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8.4 Response times

We aim to address your requests promptly and efficiently:

  • Within 1 business day of receiving your request, we’ll provide initial acknowledgement.
  • We will provide you with a full response usually within 1 month.
  • If your request requires extensive investigation, we may extend the deadline by 2 months to provide a full response, but we’ll keep you informed every step of the way.

We value your privacy and are committed to respecting your rights. Please don’t hesitate to reach out if you have any questions or concerns about how your data is handled.

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9. Cookies and Tracking

We use cookies and similar technologies to enhance your experience with our services. These tools help secure our systems, remember your preferences for a more personalised experience, and analyse how our services are used so we can improve their performance.

Cookies enable our servers to recognise information such as IP addresses, the date and time of visits, and general web traffic patterns. This helps us monitor usage, improve functionality, and prevent fraudulent activities.

Our cookies do not store personal or sensitive information. Instead, they contain a unique random reference that allows us to recognise your browser and provide relevant content when you return to the site.

If your browser or browser add-on allows it, you may choose to disable cookies on our website. However, doing so may affect certain features and your overall experience. By continuing to use our website without disabling cookies, you consent to their use.

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10. Updates to This Notice

10.1 Changes and Notifiactions‍

This privacy notice may be updated from time to time to ensure it remains accurate and reflective of:

  • New features, functionalities, or service updates
  • Changes in laws, regulations, or guidance from authorities
  • Enhancing your understanding and clarity
  • Changes in how we collect, use, or handle your data

We are committed to keeping you informed about any significant changes to this notice but you should still visit this page from time to time. If you keep using our Services, you consent to all amendments of this Privacy Policy.

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11. Contact Information

11.1 General Enquiries

For day-to-day questions and account support, we're here to help:

  • Through our app's chat feature (fastest response)
  • By email at support@grey.co 

Our support team can assist with account questions, transaction issues, and general matters. Most queries can be resolved quickly through these channels.

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11.2 Data Protection Queries

For questions or concerns about your data privacy or this notice, you can contact our Data Protection Officer (DPO) at dpo@grey.co.

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11.3 Complaints

If you are dissatisfied with how we handle your personal data, we encourage you to reach out so we can address your concerns.

  • Contact our DPO: We will work to resolve your issue promptly and transparently.
  • Escalate to the ICO: If you feel your complaint remains unresolved, you can contact the UK’s Information Commissioner’s Office (ICO). More details on how that can be done can be found here: https://ico.org.uk/global/contact-us/contact-us-public/ 

Last updated:

May 11, 2026

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Grey is a financial technology company, not a bank. Banking services are provided by licensed banking partners. United Kingdom services are regulated by the FCA. Canadian services are offered by Grey Finance Inc with registered address at 1285 West Broadway Suite 600 Vancouver BC V6H 3X8. Canada. Grey Finance Inc. is regulated by FINTRAC. US services are offered by Grey Inc. with its registered address at 651 N Broad St, Suite 206 Middletown DE 19709 US. Grey Inc is regulated by FinCEN. Copyright © Grey Inc. [YEAR].

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Grey is a financial technology company, not a bank. Banking services are provided by licensed banking partners

Canadian services are offered by Aboki Finance Inc with registered address at 1285 West Broadway Suite 600 Vancouver BC V6H 3X8. Canada. Aboki Finance Inc. is regulated by FINTRAC.

US services are offered by Grey Inc. (formerly Aboki Africa Inc.) with its registered address at 651 N Broad St, Suite 206 Middletown DE 19709 US. Grey Inc is regulated by FinCEN.

Copyright © Grey Inc. 2023.