PRIVACY POLICY

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how the Company collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a service.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

Piggy Tech Limited is the controller and responsible for your personal data (collectively referred to as "COMPANY", "we", "us" or "our" in this privacy notice).

Piggy Tech Limited is made up of different legal entities, details of which can be found here  - (https://www.heypiggybank.com/public/assets/pdf/Group%20Strucutre%20April%2018.pdf). This privacy notice is issued on behalf of the Piggy Tech Limited Group so when we mention "COMPANY", "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the Piggy Tech Limite Group responsible for processing your data. Piggy Tech Limited will be the controller for your data when you purchase a product or service with us. Piggy Tech Limited  is responsible for this website.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: Piggy Tech Limited of

Name or title of data privacy manager: Ben Duncan

Email address: trust@heypiggybank.com

Postal address: Wisteria Grange Barn, Pikes End, Pinner, London, HA5 2EX

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 23 April 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our website and using our products and services you are accepting and consenting to the practices described in this policy.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

INFORMATION WE COLLECT FROM YOU

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

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

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 if you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

HOW YOUR PERSONAL DATA IS COLLECTED

We use different methods to collect data about you including through:

as outlined above.

HOW WE USE YOUR DATA

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

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, 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.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer, to verify your identity, to open an account, provide services to you and manage our relationship with you (e.g. inform you of changes and correspond with you)

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

1. Performance of a contract with you

2. Necessary to comply with a legal obligation

3. Necessary for our legitimate interests (e.g. risk management and fraud prevention)

4. Consent

To enable you to use your account to make and receive payment transactions.

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

1. Performance of a contract with you

2. Necessary to comply with a legal obligation

3. Necessary for our legitimate interests (e.g. risk management and fraud prevention)

4. Consent

To administer and protect our business, your account and our website, to improve our website and products/services (including troubleshooting, data analysis, testing, system maintenance, support, security, reporting, complying with our regulatory obligations and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(d) Transaction

(e) Usage

1. 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 a business reorganisation or group restructuring exercise)

2. Necessary to comply with a legal obligation

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

1. Performance of a contract with you

2. Necessary to comply with a legal obligation.

3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).

To give you, or allow selected third parties to give you, information about goods and services we think you may be interested in.

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

1. Consent

2. Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business,to inform our marketing strategy to develop new products/services and grow our business)

To enable you to partake in a prize draw, competition or complete a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

 

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

 

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

 

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

 

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

 

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside our group of companies for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at trust@heypiggy.co.uk or by deleting your account via the customer dashboard.

COOKIES 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy in Appendix 1 of this document.

CHANGE OF PURPOSE


We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

WHO WE MAY DISCLOSE YOUR INFORMATION TO

You agree that we may disclose your personal information to:

You agree that we can and will disclose your personal information to third parties:

In addition to the disclosures detailed in this section, we may also disclose your personal information where it is necessary to do so: for compliance with a legal obligation; in order to protect the vital interests of you or another natural person; and for the establishment, exercise or defence of legal claims.

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 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.

HOW WE USE YOUR INFORMATION TO MAKE AUTOMATED DECISIONS

We may use systems to make automated decisions based on information we hold about you. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. These automated decisions can affect the products, services or features we may offer you now or in the future. The following are some of the ways we may use systems to make automated decisions:

Tailoring products and services

We may use your data along with that of other customer in order to study and learn about our customers’ needs, and to make decisions based on what we learn. This helps us to design products and services for different customer groups, and to manage our relationships with them.

Fraud detection

We use your personal information to help determine if your account is being used fraudulently or for money-laundering. If there is a risk of fraud, or money laundering, we may suspend or terminate your account and refuse access to your account.

Opening accounts

We may use automated checks to help determine if you satisfy our criteria for an account, including fraud, money laundering and eligibility checks.

Your rights with respect to automated decisions

You can ask that we do not make our decision based on the automated decision alone.

You can object to an automated decision, and ask that a person reviews it.

If you want to know more about these rights, or to exercise them, please contact us.

WHERE WE STORE AND TRANSFER YOUR PERSONAL DATA

All information you provide to us will be transferred and stored in a jurisdiction located in the European Economic Area (EEA). However, we may transfer some or all of your data to countries outside of the EEA which may not offer the same level of protection as the GDPR with respect to the processing of your personal data. The General Data Protection Regulations is the legal instrument that deals with the protection of your data (‘GDPR’).

Where your data is transferred to such countries it will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission (EC)  can by found on the EC’s website:

https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

Where data is to be transferred to a group company in a country outside of the EEA which may not offer the same level of protection as the GDPR with respect to the processing of your personal data, we will ensure that the group company agrees to binding corporate rules in accordance with Article 47 of the GDPR. Further information can by found on the EC’s website: :

https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/binding-corporate-rules_en 

Where we transfer data to organisations 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 the Europe and the US. For further details, see EC’s website page:

https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en#eu-us-privacy-shield 

DATA 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 they 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 we are legally required to do so.

KEEPING AND DELETING YOUR DATA

We will only retain 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 for personal data, 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 requirements.

By law we are required to keep certain data for minimum periods, namely:

The majority of personal data we hold will be deleted 10 years after the termination of any agreement you have with us unless it is needed for other necessary or legitimate purposes.

In some circumstances you can ask us to delete your data: see request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR RIGHTS

Under the GDPR you have the right to:

If you wish to exercise any of these rights you will need to contact us using the contact details above. In the case of exercising your right to access, you will also need to provide appropriate evidence of your identity.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). 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.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

CHANGES TO OUR PRIVACY POLICY

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

Unless we have legal grounds to do otherwise, we will provide you with at least 30 days' prior notice of the effective date of the revised privacy policy.

CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to the contact details at the start of this policy.


Appendix 1

COOKIE POLICY