Privacy Notice

1. 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.

2. About us

   For the purpose of this Privacy Notice Digital Moneybox Limited (Moneybox) of Suite 1.07, 1-2 Hatfields, London, SE1 9PG is the ‘Data Controller’, however at times may hold this position jointly with Greyfriars Asset Management LLP (being the ‘Platform Provider’ as defined in the Customer Terms & Conditions) (together we or us, as the context requires). Both Moneybox and the Platform Provider are registered with the Information Commissioner’s Office.

   Moneybox has appointed a Data Protection Officer who is responsible for overseeing questions in relation to this Privacy Notice, including any requests to exercise your legal rights. The Platform Provider has also appointed a Data Protection Officer. To contact our Data Protection Officer (or the Data Protection Officer of the Platform Provider), please address:

   (a) postal correspondence to the Data Protection Officer, Moneybox, Suite 1.07, 1-2 Hatfields, London, SE1 9PG; or

   (b) emails to dpo@moneyboxapp.com

   and we will ensure your query is responded to by our Data Protection Officer in liaison with the Platform Provider’s Data Protection Officer, where applicable.

3. 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.

4. Information we may collect:

   Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data whether the identity has been removed (anonymous data).

   1. Information you give us

      During the course of opening and maintaining a Moneybox account, the information you give to us may include:

         (a) Identity Data such as your name, date of birth, copies of personal identification documents (such as your passport or driving licence, which may also indicate ID numbers, nationality and sex) and photographs or other descriptions of your likeness. If you open a Moneybox Junior ISA, the information you give to us may also include the name and date of birth of your child.

         (b) Contact Data such as your address, email address and telephone number (and in the case of a Moneybox Junior ISA, the address of your child).

         (c) Financial Data such as your national insurance number, bank account and other financial details (and in the case of a Moneybox Junior ISA, the national insurance number of your child, if known).

         (d) Transaction Data such as your transaction information (for example purchase item, price, location, date) if you use our ‘Round up Service’ (as defined in our Customer Terms & Conditions) and you may also provide your account credentials (such as user name and password) for your selected online banking account or payment card so that your account transactions can be accessed (on a read-only basis) to provide you with the Round up Service. Remember, you do not have to sign up to our Round up Service if you don’t want to. Over time, more and more banks and account providers will be in a position to participate in the government’s Open Banking initiative, enabling us to provide you with the Round up Service through a direct API connection. Where such an API connection exists, you will not need to provide your account credentials in the App to access the Round up Service, rather you will authorise access directly with your bank or account provider.

      You may also provide us with certain information by filling in other forms, entering competitions or promotions or by corresponding with us by phone, email, text message or through our live in-App chat function.

      We do not collect any special categories of personal data about you (this includes details about your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health or your biometric or genetic information).

   2. Information we collect or receive from other sources

      We work closely with third parties (for example: 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) and may receive the following information about you when you visit our website or use our App:

         (a) Technical Data such as your IP address, URL, browser information, plug-in types, operating system and platform as well as your login information to the Moneybox App.

         (b) Profile Data such as your preferences, feedback and survey responses.

         (c) Usage Data such as information about how you use our website, App, products and services.

         (d) Marketing and Communications Data such as your preferences in receiving marketing from us and your communication preferences (which we may also collect directly from you).

      We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this does not directly or indirectly reveal your identity.

   3. Cookies

      We, or our third party providers, may also use cookies to collect information about you. This helps us to provide you with a good experience while you use our website and our App. See our Cookie Policy for more details.

   4. Links to other websites

      Our website or App may, from time to time, contain links to and from the 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.

   5. If you fail to provide personal data

      Where we need to collect personal data by law, or under the terms of a contract with 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.

5. What we do with your information

   We will only use your personal data when the law allows us to. Most commonly we will use your personal data:

      (a) to provide you with the products and services you have selected;

      (b) where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and

      (c) where we need to comply with a legal or regulatory obligation.

   Generally we do not rely on consent as a legal basis for processing your personal data, other than in relation to the Round up Service, as this is regulatory requirement. You can withdraw your consent to this processing at any time by turning off the Round up Service from within the App.

   We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

   Purpose/ Activity	Type of data	Lawful basis for processing
   To register you as a customer	- Identity - Contact - Financial	Performance of a contract with you
   To process and deliver your selected products and services, including managing payments, fees and charges and HMRC reporting.	- Identity - Contact - Profile - Marketing and Communications - Transaction - Technical - Usage - Financial	-Performance of a contract with you - Necessary for our legitimate interests (to recover debts due to us) - Your consent in the case of Transaction Data, as required by regulation
   To manage our relationship with you, including notifying you about changes to terms & conditions and this privacy notice	- Identity - Contact - Profile - Marketing and Communications - Transaction - Technical - Usage - Financial	- Performance of a contract with you - Necessary to comply with a legal requirement - Necessary for our legitimate interests (to keep our records up dated and to study how customers use our products and services)
   To enable you to participate in a prize draw, competition or complete a survey	- Identity - Contact - Profile - Marketing and Communications - Transaction - Usage - Financial	- Performance of a contract with you - Necessary for our legitimate interests (to study how customers use our products and services, to develop them, to grow our business)
   To administer and protect our business, App and website), including, security, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting	- Identity - Contact - Profile - Marketing and Communications - Transaction - Technical - Usage - Financial	- Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of any business reorganisation - Necessary to comply with a legal obligation
   To deliver relevant App and website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	- Identity - Contact - Profile - Marketing and Communications - Transaction - Technical - Usage	Necessary for our legitimate interests (to study how customers use our products and services, to develop them, to grow our business, and to inform our marketing strategy)
   To use data analytics to improve our App, website, products, services, marketing, customer relationships and experiences	- Profile - Transaction - Technical - Usage	Necessary for our 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 de-identify your data (anonymise or aggregate)	- Identity - Contact - Profile - Marketing and Communications - Transaction - Technical - Usage - Financial	Necessary for our legitimate interests (to increase data security and protection, to grow our business)
   To make suggestions and recommendations to you about products or services that may be of interest to you, via electronic means or otherwise such as email, SMS, pop ups or push notifications, targeted social media and our in-App secure notification centre	- Identity - Contact - Profile - Transaction - Technical - Usage	Necessary for our legitimate interests (to develop our products and services, and grow our business)

6. Disclosing your information

   We may share your information with selected third parties including:

   (a) business partners, service providers, suppliers and sub-contractors for the performance of any contract we enter into with them or you, including (but not limited) to:

         (i) the ISA manager and Platform Provider (Greyfriars Asset Management LLC) and the administrative services provider Quai Administration Services Ltd the set up and management of your selected products (and likewise, the Product Provider shares your information with us);

         (ii) Yodlee Inc. to facilitate the Round up Service (if selected, and where no direct API integration is available);

         (iii) GoCardless Ltd to facilitate direct debits;

         (iv) Onfido Ltd to conduct the required background, credit and compliance checks;

         (v) Intercom R&D Unlimited Company to facilitate the in-App chat function; and

         (vi) Linktexting to facilitate app links sent from our website;

   (b) analytics and search engine providers that assist us in the improvement and optimisation of our site (for example Google for the purpose of its Google Analytics service);

   (c) 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;

   (d) if we, or substantially all of our assets, are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets; and

   (e) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our Website & App Terms of Use, our Customer Terms & Conditions and other agreements; or to protect our rights, property, or safety or those of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

   We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow out 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.

7. Storing your information

   1. 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. We ask you not to share this password or PIN with anyone.

   2. Out of the EEA

      Some of our external third parties are based outside the European Economic Areas (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:

      (a) 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;

      (b) using specific contracts approved by the European Commission which give personal data the same protection is has in Europe (known as ‘model contracts’); or

      (c) where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

   3. 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.

8. 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 request within one month, but occasionally this may take longer if your request is particularly complex or you have made a number of requested (we will notify you and keep you updated).

   1. Access to your personal data

      You have the right to request access to your personal data (commonly known as a data subject access request. If you would like a copy of the information held on you, please contact our Data Protection Officer (see above for details).

   2. Correction of your personal data

      You have the to request a 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.

   3. Erasure of your personal data

      You have the right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove 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.

   4. 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.

   5. 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

   6. 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.

   7. 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.

   8. Withdrawing consent to marketing

      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 support@moneyboxapp.com.

9. 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. Remember, you will be bound by this notice.

   Version 2.0.0