Privacy Policy
Last updated: 1 January 2026
1. Who We Are
Honest Pam Inc. ("Honest Pam", "we", "us", "our") is a company registered in England and Wales (Company No. 00000000), with its registered office at 1 Canada Square, Canary Wharf, London E14 5AB. We are a regulated financial services provider. We are the data controller for personal data collected through our website and services.
2. Data We Collect
We collect the following categories of personal data: • Identity data: full name, date of birth, nationality, government-issued ID • Contact data: email address, telephone number, postal address • Financial data: bank account details, transaction history, source of funds documentation • Technical data: IP address, browser type, device identifiers, cookies • Usage data: pages visited, time on site, referral source • Communications data: emails, messages, and call recordings with our team
3. How We Use Your Data
We use your personal data to: • Provide and manage our services to you • Conduct KYC/AML verification as required by law • Process transactions and settle payments • Communicate with you about your account and our services • Comply with legal and regulatory obligations • Improve our website and services • Detect and prevent fraud and financial crime
4. Legal Basis for Processing
We process your personal data on the following legal bases: • Contract: processing necessary to perform our contract with you • Legal obligation: processing required to comply with HMRC and other regulatory requirements • Legitimate interests: fraud prevention, security, and service improvement • Consent: where you have given explicit consent (e.g. marketing communications)
5. Data Sharing
We share your personal data with: • Regulatory authorities (HMRC, NCA) as required by law • KYC/AML screening providers (Refinitiv, Jumio) • Banking and payment partners for transaction processing • Cloud infrastructure providers (AWS, operating under data processing agreements) • Professional advisers (lawyers, auditors) under confidentiality obligations We do not sell your personal data to third parties.
6. Data Retention
We retain personal data for a minimum of 5 years after the end of our relationship with you, as required by the Money Laundering Regulations 2017. Transaction records are retained for 7 years.
7. Your Rights
Under UK GDPR, you have the right to: • Access your personal data • Correct inaccurate data • Request erasure (subject to legal retention requirements) • Object to processing • Data portability • Withdraw consent at any time To exercise your rights, contact hello@honestpam.com. We will respond within 30 days.
8. Contact
For privacy enquiries, contact our Data Protection Officer at hello@honestpam.com. You have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.