Privacy Notice
Why we have a privacy notice
We are committed to respecting and protecting your privacy. This Privacy Notice sets out the type of information we collect from you and what we do with that information.
Other relevant policies and terms
What information does Moneybox collect?
How does Moneybox collect information from you?
What does Moneybox do with this information?
If you fail to provide personal data
Changes to this Privacy Notice
Who we are
The Moneybox Group consists of the parent company, Digital Moneybox Limited (“Moneybox”), a private limited company with the registered company number 0959775, and the following subsidiary companies:
- Moneybox Mortgages Limited (12954235)
- Moneybox Share Nominee Limited (12140599)
- Moneybox Pension Trustee Limited (13817702)
All Moneybox Group companies have the registered office address of 1-2 Hatfields, London, SE1 9PG.
Digital Moneybox Limited is also registered with the Financial Conduct Authority (FCA) with the FCA registration number 712935, and 729703 for payment services activities.
Moneybox has appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Notice, including any requests to exercise your legal rights.
To contact our Data Protection Officer, please contact us by:
- postal correspondence to: Data Protection Officer, Moneybox, 1-2 Hatfields, London, SE1 9PG; or,
- emails to dpo@moneyboxapp.com
This Privacy Notice is issued on behalf of the Digital Moneybox Limited. As such, any references to “Moneybox”, “we”, “us”, or “our” in this Privacy Notice are references to Digital Moneybox Limited, which is responsible for processing your data.
Other relevant policies and terms
This Privacy Notice should be read together with our Website & App Terms of Use, our Cookie Policy, and if you have signed up to a Moneybox account, our Customer Terms & Conditions. If you are using our mortgage service through Moneybox Mortgages Limited, please see the Moneybox Mortgages Limited Privacy Notice and our Moneybox Mortgages Terms of Business.
Our commitment
Moneybox is committed to protecting your personal information and other data provided to us. Information from which you could be identified (“personal data”), will only be used in accordance with this Privacy Notice. We will be the data controller for your data when you purchase a product or service with us. We may also act as a data processor where you gained access to our products or services through a third-party.
This Privacy Notice supplements any other notices you may receive from Moneybox about the use of your personal data and is not intended to override them.
Lawful basis of processing
Under data protection laws Moneybox must have legal grounds to process your personal data. Moneybox considers the following grounds to be relevant:
- Consent: where you have explicitly given Moneybox permission to collect, use and store your personal data for a specific reason or reasons. Generally we do not rely on consent as a legal basis for processing your personal data, but when we do you can withdraw your consent at any time.
- Performance of a contract: in order to provide a service or product.
- Legal obligation: where processing of the data is required by law, for example carrying out anti-money laundering checks. We are also required by law to retain certain information of people that register to open an account and of customers beyond the date when they cease to be our customers.
- Legitimate interest: where it is reasonable to achieve our and others legitimate interests, such as to understand how you interact with our app and to send communications about products and services we think will be of interest to you.
More detail on the legal basis for the different ways we use your data is presented in the table later in this Privacy Notice.
What information does Moneybox collect?
Moneybox might collect, store and use the following types of information about you depending on the Moneybox products and services you use:
- Identity data: including name, date of birth, national insurance number, any documents used to verify your identity such as passport or driving licence. If you open a Moneybox Junior ISA, the information you give to us will also include the name and date of birth of your child.
- Contact data: including postal address, email address, telephone number.
- Financial data: including bank account details, bank statements, payment card details, salary and occupation details.
- Transaction data: including details about payments into and withdrawals from Moneybox, investments made with Moneybox, and your bank or credit card transactions if you used Open Banking to link to these to use the round-up service.
- Technical data: including internet protocol (IP) address, your login data, operating system and version, time zone setting and location, browser type and version, and other associated device type information required to access the app.
- Profile data: including username and password, feedback and survey responses.
- Usage data: including information about how you use our app, and the products and services.
- Marketing and communications data: including communications with Moneybox (in-app chat, email, phone call), your preferences in receiving marketing from us and our third parties, and your communication preferences.
- Bank account or credit card credentials: including username, password and any other information required to use Open Banking to connect your bank account or credit card to use our round-up service. These credentials are not stored by Moneybox.
- Special category data: including information you choose to share with us about medical conditions, and trade union or political party membership costs if that is included in your bank or credit card transactions that you have linked to the round-up service.
How does Moneybox collect information from you?
- Directly: including when you register or log on to the app, when you choose to use a Moneybox product or service via the app, when you enter information into calculators, questionnaires or surveys, transfer products to us, upload documentation, communicate with us by in-app chat, email, phone or post, make an enquiry.
- Automatically:including your use and browsing patterns, and technical data about the device you are using to access the app, which is collected using cookies, server logs and other similar technologies. Please see our Cookie Policy for further information.
- From third parties/public sources: including business partners, technical, payment and delivery service providers, advertising networks, tracking and analytics providers (including Google), search information providers, lead generation agencies and credit reference agencies. Some specific information from third parties includes:
- transaction information from banks or credit card providers if you connect to these using Open Banking to use the round-up service;
- identity data from public sources such as Companies House and the Electoral Register, and other entities based inside and outside the UK; and
- third-party providers and public sources to secure information related to financial crime, fraud, sanctions and politically exposed persons.
What does Moneybox do with this information?
Moneybox may use your personal data for the following purposes:
- Provide the requested products and services to you.
- Monitor traffic patterns and usage of the app to help improve the app design and layout.
- Identify, troubleshoot and resolve any issues.
- Provide customer service, including responding to your enquiries and fulfilling any requests.
- Keeping a record of your relationship with us.
- To generate aggregated or anonymised statistics for internal business purposes.
- Analyse and profile personal data to evaluate certain things such as estimating how likely you are to be interested in other Moneybox products available to you to personalise your experience of the Moneybox app with more relevant screens, features or in-app messages, and send more relevant communications or present more relevant marketing.
- To help Moneybox provide relevant support based on information you have chosen to share with us relating to medical need or personal circumstances, and we may limit messages or marketing that are not appropriate to you.
- Carry out checks to prevent financial crime.
- Send you important information about Moneybox products, services and other technical notices, updates, security alerts, and support and administrative messages.
- To enable you to participate in a prize draw, competition or complete a survey.
- To deliver relevant app and website content, marketing communications and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
- Comply with legal obligations, and to establish, exercise, or defend against legal claims.
More detail on what data Moneybox uses for different purposes and the legal basis for its use is presented in the table below.
| Processing purposes | Legal basis | Types of personal information |
|---|---|---|
| To register you as a customer and maintain records of your relationship with us. | Performance of a contract. |
|
| To process and deliver your products and services, including managing payments (including round-ups), fees and charges, reporting to HMRC. |
Performance of a contract.
|
|
| To manage our relationship with you, including notifying you about changes to terms & conditions and this privacy notice. | Performance of a contract.
Legal obligation. Legitimate interests (to keep our records updated and to study how customers use our products and services). |
|
| To provide customer service including responding to your queries and fulfilling requests, and providing any additional support relating to medical need or personal circumstances. | Legitimate interest (for ensuring the safety, security, and performance of our app).
Consent |
|
| To enable you to participate in a prize draw, competition or complete a survey. | Performance of a contract.
Legitimate interests (to study how customers use our products and services, and better inform us how to develop them, to grow our business). |
|
| To develop and administer our business, products, services, features, app and website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting. | Legitimate interests (for running our business, provision of administration and IT services, and network security).
Legal obligation. |
|
| To monitor traffic patterns and usage of the app to understand IT performance, make improvements and protect our business and customers. | Legitimate interest (for monitoring and understanding IT performance for stability and improvement, and ensuring the integrity and security of the systems we use. |
|
| To use data analytics, including profiling, to personalise your experience of the Moneybox app with more relevant screens, features, products or in-app messages, and send more relevant communications or present more relevant marketing. We will also use this information to improve our app, website, products, services, marketing, customer relationships and experiences. We may also exclude you from some marketing if it is not relevant to your circumstances. | Legitimate interests (to define types of customers for our products and services, to keep our website and app updated and relevant, to develop our business and to inform our marketing strategy). |
|
| To deliver relevant app and website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. | Legitimate interests (to study how our customers use our products and services, to develop them, grow our business, and to better inform our marketing strategy). |
|
| To market to non-Moneybox customers including via our social media channels | Legitimate interest (to identify marketing target group)
Consent (to directly contact non-Moneybox customers). |
|
| To de-identify your data (anonymise or aggregate). | Legitimate interest (to increase data security and protection, and to use for analysis to grow and enhance our business). |
|
| Comply with legal obligations, and to establish, exercise, or defend against legal claims. | Legal obligation.
Legitimate interest (to protect against legal claims). |
|
| Detect, investigate, and prevent financial crime. | Legitimate interest (for detecting, investigating, and preventing financial crime)
Legal obligations |
|
Links to other websites
Our app may, from time to time, contain links to and from the apps or websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract and may therefore be unable to provide you with one or more of our products or services.
Disclosing your information
We may share your information between companies within the Moneybox Group and with selected third parties or categories of third parties including:
- Moneybox Group companies to allow us to offer or provide you with products or services.
- Payment processing services to allow us to process your payments.
- Other financial institutions that we partner with or represent to allow us to offer you certain products and services, or who you ask us to deal with (such as when making a transfer).
- Our service providers (including their subcontractors) who help us to offer the Moneybox service.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site (for example Google for the purposes of its Google Analytics service).
- Marketing partners to allow us to analyse and improve the effectiveness of our marketing and to be able to target or exclude you from specific marketing campaigns.
- HM Revenue & Customs to allow us to verify information you have provided to us.
- Credit reference agencies and other identity services to allow us to verify information you have provided to us. Moneybox does not report your account activity to credit reference agencies and leaves no hard imprint on your credit file.
- Individuals you have authorised to represent you and you have given instructions to us to disclose information on your account.
- Law enforcement agencies in relation to financial crime.
- Where we must disclose or share your personal information in order to comply with a legal obligation or in order to enforce or apply our Terms and Conditions and other agreements, or to protect our rights, property, or safety of us or our customers. This may include exchanging information with other organisations for financial crime prevention.
- If we sell or buy any business or assets, in which case we may need to disclose your personal information to the prospective seller or buyer of such business or assets or where we transfer or delegate our rights or obligations as allowed under our terms and conditions.
We require all third parties to ensure the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Storing your information
Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where legally required to do so.
Where we have given you, or where you have chosen, a password or personal identification number (PIN) which enables you to access certain parts of our website or app, you are responsible for keeping this password or PIN confidential. You must not share this password or PIN with anyone.
Outside the EEA
Transfers of data from the UK to the European Economic Area (EEA) is permitted by the UK government. Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by:
- only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- using the International Data Transfer Agreement approved by the Information Commissioner’s Office which gives personal data the same protection it has in the UK.
Data retention
We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.
Your rights
We will need to confirm your identity and ensure your right to access your personal data or to exercise any of the other rights listed below. We may also need further information from you in order to speed up your request. You will not have to pay a fee to access your personal data (or to exercise any of the other rights listed below), however we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We try to respond to all legitimate requests within one month, but occasionally this may take longer if your request is particularly complex, or you have made a number of requests (if this is the case, we will notify you and keep you updated).
Access to your personal data
You have the right to request access your personal data (commonly known as a data subject access request (SAR)). If you would like a copy of the information held on you, please contact our Data Protection Officer (see the beginning of this Notice for details).
Correction of your personal data
You have the right to request the correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
Erasure of your personal data
You have the right to request the erasure of your personal data. This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Objection to processing of your personal data
You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Restriction of processing your personal data
You have the right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Transfer of your personal data
You have the right to request the transfer of your personal data to you or to a third party. Subject to the rules and regulations that govern the products and services we provide, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdrawing consent
You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Withdrawing marketing consent
By submitting your personal information, you agree that Moneybox may use your information for marketing purposes (including electronic marketing). Moneybox will not disclose your information to any third party for marketing purposes, without your further consent. You have the right, at any time, to ask us not to process your personal information for marketing purposes. You can do so by emailing us at dpo@moneyboxapp.com.
Contact the Information Commissioner’s Office
You have the right to contact the Information Commissioner’s Office (ICO) who are an independent body and complain to them if you are unhappy with how we have used your data.
The ICO’s details are:
- Postal correspondence: The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
- Helpline: 0303 123 1113
- Website: ico.org.uk
Changes to this Privacy Notice
We may make changes to this Privacy Notice, so please review it every now and then. If appropriate we will notify you by email about changes. This Privacy Notice was last updated on the 18th of May 2023.
Version 4.0
