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Table of Contents
Customer Privacy Notice for Account Users
Effective 12 January 2023
We’re committed to protecting and respecting your privacy.
We will:
Always keep your personal data safe and private
Never sell your personal data
Allow you to manage and review your marketing choices at any time
About us
You have a relationship with Paywicks when you first apply for or use a Paywicks
product or service. Paywicks provides the relevant product or service to you and
is responsible for processing your personal data for that product or service.
Paywicks is thus known as the ‘controller’ of your personal data.
Any of the services available to you through the Paywicks app or website
We may also collect your personal data from other people or companies. We
explain how this can happen in more detail in the What personal data do you
collect about me? section below.
When we say ‘personal data, we mean information that:
We know about you (for example, we know when you use your Paywicks card
to pay for things)
Can be used to personally identify you (for example, a combination of
your name and postal address)
This notice explains what information we collect, how we use it, and your
rights if you want to change how we use your personal data.
We may provide this notice in languages other than English. If there are
any discrepancies between other language versions and the English
language version, the English language version is authoritative.
If you have concerns about how we use your personal data, you can contact
[email protected].
What personal data do you
collect about me?
Type of personal data
Details
Information you give us
We collect the information you provide when you:
fill in any forms
correspond with us
respond to any of our surveys
register to use the Paywicks app
register, or approve a registration form, a child to use the Paywicks
open an account or use any of our services
give us access to your other financial accounts (for example, through Open Banking)
take part in online discussions or promotions
speak with a member of our social media or customer support teams (either on the phone or through the Paywicks app)
enter a competition or share information with us on social media
enter a competition or share information with us on social media
contact us for other reasons
We will collect the following information:
your name, address, and date of birth
your email address, phone number, and details of the device you use (for example, your phone, computer, or tablet)
your Paywicks username (this is random and is automatically assigned to you when you first join but you will be able to change it)
your registration information
details of your bank account, including the account number, sort code, and IBAN
details of your Paywicks debit cards and credit cards (or other debit or credit cards you have registered with us) including the card number, expiry date and CVC (the last three digits of the number on the back of the card)
copies of your identification documents (for example, your passport or driving licence) and any other information you provide to prove you are eligible to use our services
your country of residence, tax residency information, and tax identification number
information you provide when you apply for credit, including details about your, or your spouse’s, income and financial obligations
information you provide when you register or approve your children to use Paywicks
records of our discussions, if you contact us or we contact you (including records of phone calls)
your image in photo or video form (where required as part of our
Know-Your-Customer (KYC) checks, to verify your identity if you contact us when logged out of your Paywicks account, or where you upload a photo to your Paywicks account)
information about other people (such as a joint account holder, your spouse or family) when we ask you to give us this information to enable us to comply with our obligations under KYC, anti-money laundering laws and to assist with fraud monitoring
If you give us personal data about other people (such as a joint account holder, your spouse or family), or you ask us to share their personal data with third parties, you confirm that you have brought this notice to their attention beforehand.
Information collected from your use of our products and services
Whenever you use our website or the Paywicks app, we collect the following information:
technical information, including the internet protocol (IP) address used to connect your computer to the internet, your login information, the browser type and version, the time zone setting, the operating system and platform, the type of device you use, a unique device identifier (for example, your device's IMEI number, the MAC address of the device's wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system and the type of mobile browser you use
information about your visit, including the links you’ve clicked on, through and from our website or app (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling and clicks), and methods used to browse away from the page
information on transactions and your use of Paywicks products (for example, payments into and out of your account), including the date, time, amount, currencies, exchange rate, beneficiary details, details of the merchant or ATMs associated with the transaction (including merchants’ and ATMs’ locations), IP address of sender and receiver, sender's and receiver's name and registration information, messages sent or received, details of device used to arrange the payment and the payment method used
information stored on your device, including if you give us access to contact information from your contacts list. The Paywicks app will regularly collect this information in order to stay up to date (but only if you have given us permission)
Information about your location
If you turn location services on in the Paywicks app, we track your location using GPS technology.
Information from others
We collect personal data from third parties or other people, such as credit reference agencies, financial or credit institutions, official registers and databases, as well as joint account holders, fraud prevention agencies and partners who help us to provide our services.
This includes your credit record, information about late payments, information to help us check your identity, information about your spouse and family (if applicable in the context of an application for credit that you make) and information relating to your transactions.
When you ask us to, we’ll also collect personal data from accounts you hold with third party financial institutions (when you create a linked account by activating Open Banking in the Paywicks app). If you apply for our credit products, when you allow us, we may use this information for credit checks to improve your experience.
Information from social media
Occasionally, we’ll use publicly available information about you from selected social media websites or apps to carry out enhanced due diligence checks. Publicly available information from social media websites or apps may also be provided to us when we conduct general searches on you (for example, to comply with our anti-money laundering or sanctions screening obligations).
Information from publicly available sources
We collect information and contact details from publicly available sources, such as media stories, online registers or directories, and websites for enhanced due diligence checks, security searches, and KYC purposes.
What is your legal basis for
using my personal data?
We must have a legal basis (a valid legal reason) for using your personal data.
Our legal basis will be one of the following:
Keeping to our contracts and agreements with you
We need certain personal data to provide our services and cannot provide them
without this personal data.
Legal obligations
In some cases, we have a legal responsibility to collect and store your
personal data (for example, under anti-money laundering laws we must hold
certain information about our customers).
Legitimate interests
We sometimes collect and use your personal data because we have a legitimate
reason to use it and this is reasonable when balanced against your human
rights and freedoms.
Substantial public interest
Where we process your personal data, or your sensitive personal data
(sometimes known as special category personal data), to adhere to government
regulations or guidance, such as our obligation to support you if you are or
become a vulnerable customer.
Consent
Where you've agreed to us collecting your personal data, or sensitive
personal data, for example when you tick a box to indicate you’re happy for
us to use your personal data in a certain way.
We explain more about how we use your personal data in the How do you use my
personal data? section below.
How do you use my personal
data?
What we use your personal data for
Our legal basis for using your personal data
Providing our services
Whenever you sign up with Paywicks, apply for or use a productor service, we’ll use your personal data to:
check your identity, and the identity of joint account holders (as part of our KYC process)
decide whether or not to approve your application
meet our contractual and legal obligations relating to any products or services you use (for example, making payments into and out of your Paywicks account, withdrawing cash or making payments with your Paywicks card)
help you understand your spending behaviour, how you use Paywicks products and services, and to help you save money (for example, by providing you with product usage and spending insights)
recover debt and exercise other rights we have under any agreement with you
provide you with customer support services. We may record and monitor any communications between you and us, including phone calls, to maintain appropriate records, check
your instructions, analyse, assess and improve our services, and for training and quality control purposes
Keeping to contracts and agreements between you and us
Legitimate interests (we need to be efficient about how we meet our obligations and we want to provide you with good products and services)
Legal obligations
Protecting against fraud
We use your personal data to check your identity to protect against fraud, keep to financial crime laws and to confirm that you’re eligible to use our services. We also use it to help us better understand your financial circumstances and manage fraud risks related to your Paywicks account.
Legitimate interests (to develop and improve how we deal with financial crime and meet our legal responsibilities)
Legal obligations
Marketing and providing products and services that might interest you
We use your personal data to do the following:
to personalise your in-app experience and marketing messages about our products and services so they’re more relevant and interesting to you (where allowed by law). This may include analysing how you use our products, services and your transactions
if you agree, provide you with information about our partners’ promotions or offers which we think you might be interested in
if you agree, allow our partners and other organisations to provide you with information about their products or services
measure or understand the effectiveness of our marketing and advertising, and provide relevant advertising to you
ask your opinion about our products or services
Remember, you can ask us to stop sending you marketing information by adjusting your marketing choices (the How do you use my personal data for marketing? section below explains how to do this).
Legitimate interests (to send direct marketing, ensure our direct marketing is relevant to your interests, develop our products and services, and to be efficient about how we meet our legal and contractual duties)
Consent (where we’re legally required to get your consent to send you direct marketing about our products or services, or partners’ promotions or offers, or for you to receive marketing from other organisations)
To keep our services up and running
We use your personal data to manage our website and the Paywicks app, (including troubleshooting, data analysis, testing, research, statistical and survey purposes), and to make sure that content is presented in the most effective way for you andyour device.
We also use your personal data to:
verify your identity if you contact our customer support or social media teams
allow you to take part in interactive features of our services
tell you about changes to our services
help keep our website and the Paywicks app safe and secure
Keeping to contracts and agreements between you and us
Legitimate interests (to be efficient about how we meet our obligations and keep to regulations that apply to us and to present content as effectively as possible for you)
Consent (where required by law)
Helping with social interactions
We use your personal data to help with social interactions through our services, or to add extra functions in order to provide a better experience.
For example, if you give us permission, we'll use the contacts list on your phone so you can easily make payments to, or message, your contacts using the Paywicks app.
Legitimate interests (to develop our products and services and to be efficient in meeting our obligations)
Consent (to access information held on your phone, for example, contacts in your contacts list, to track you when you have location services switched on)
Providing location-based services
If you turn location services on in the Paywicks app, we use your personal data to:
provide you with products and services
provide relevant advertising to you (for example, information about nearby merchants)
protect against fraud
Keeping to contracts and agreements between you and us
Legitimate interests (to develop and market our products and keep to regulations that apply to us)
Consent (to track you when you have location services switched on)
Preparing anonymous statistical datasets
We prepare anonymous statistical datasets about our customers’ spending patterns:
for forecasting purposes
to understand how customers use Paywicks
to comply with governmental requirements and requests
These datasets may be shared internally or externally with others, including non-Paywicks companies. We produce these reports using information about you and other customers. The information used and shared in this way is never personal data and you will never be identifiable from it. Anonymous statistical data cannot be linked back to you as an individual.
For example, some countries have laws that require us to report spending statistics and how money enters or leaves each country. We’ll provide anonymised statistical information that explains the broad categories of merchants that Paywicks customers in that country spend their money with. We’ll also provide information about how Paywicks customers top up their accounts and transfer money. However, we won’t provide any customer-level information. It will not be possible to identify any individual Paywicks customer.
Legitimate interests (to conduct research and analysis, including to produce statistical research and reports)
Legal obligations
Improving our products and services
We use your personal data to help us develop and improve our current products and services. This allows us to continue to provide products and services that our customers want to use.
Legitimate interests (to understand how customers use our products so we can develop new products and improve the products we currently provide)
Meeting our legal obligations, enforcing our rights and other legal uses
We use your personal data:
to share it with other organisations (for example, government authorities, law enforcement authorities, tax authorities, fraud prevention agencies)
to recover debts from you (for example, where you hold a credit product with us or have a negative balance in your account)
if this is necessary to meet our legal or regulatory obligations
to identify and support vulnerable customers by analysing your behaviour in the Paywicks app, customer support communications and through transactions (for example, we will try to identify whether you are potentially vulnerable so we can provide you with enhanced support. Identifying and supporting vulnerable customers is a legal requirement for us in some countries)
in connection with legal claims
to help detect or prevent crime
You can find out more in the Do you share my personal data with anyone else? section below.
Sometimes, we’re legally required to ask you to provide information about other people. For example, we might ask you to explain:
your relationship with a joint account holder or somebody who pays money into your Paywicks account
how somebody got the money in the first place to pay it into your Paywicks account
Legitimate interests (for example, to protect Paywicks during a legal dispute)
Substantial public interest (if we process your sensitive personal data to keep to legal requirements that apply to us)
Legal obligations
Sometimes, we help you to provide services to customers. For example, we can
provide payment processing services to you. Where this happens, you’re
responsible for deciding if we collect your customers’ personal data and how we
should process it on your behalf.
Do you make automated
decisions about me?
Depending on the Paywicks products or services you use, we may make automated
decisions about you. This means that we may use technology that can evaluate
your personal circumstances and other factors to predict risks or outcomes. This
is sometimes known as profiling. We do this for the efficient running of our
services and to ensure decisions are fair, consistent and based on the right
information. Where we make an automated decision about you, you have the right
to ask that it is manually reviewed by a person. You can find out more about this
in the What are my rights? section below.
For example, we may make automated decisions about you that relate to:
Approving credit applications:
Credit and affordability checks to see whether we can accept your credit
application
Setting credit limits
Monitoring credit agreements:
Assessing how you’re repaying any credit product you hold with us
Amending your credit limit
Terminating your credit agreement
Opening accounts:
KYC, anti-money laundering and sanctions checks
Identity and address checks
Detecting fraud:
Monitoring your account to detect fraud and financial crime Our legal
basis is one or more of the following:
Keeping to contracts and agreements between you and us
Legal obligations
Legitimate interests (to develop and improve how we deal with financial
crime and meet our legal responsibilities)
Do you run credit checks
on me?
We, and our lending partners, can use credit reference agencies (or other
providers of credit information in some countries) to run credit checks if you
apply (or tell us you want to apply) for a credit product through Paywicks.
If you give us access to other accounts you hold with other financial
institutions, through Open Banking, where you agree, we’ll use available
information to carry out credit checks on you.
We’ll also share your personal data with credit reference agencies (or other
providers of credit information) to:
Confirm details you have provided when you apply for products or services
Make an assessment about whether to accept your credit application
Determine an appropriate credit limit for you
When you enter into a credit agreement with us, we may continue sharing
information with credit reference agencies or other providers of credit
information (for example, information about your repayments and whether
you repay in full or on time).
We’ll carry out additional credit checks on you from time to time to make
sure that your financial wellbeing hasn’t changed over the course of the
year.
The personal data we share with, and receive from, credit reference
agencies (or other providers of credit information) when you apply for
or use a Paywicks credit product will vary depending on the country you
live-in. We’ll provide full details when you apply for a Paywicks credit
product.
Our legal basis is one or more of the following:
Consent (where we are required to collect your consent by law)
Legal obligations
Keeping to contracts and agreements between you and us (where you
take out a credit product with us)
Legitimate interests (to develop and, in the future, offer credit
products to our customers).
How do you use my personal
data for marketing?
If you sign up to our services, and where national laws allow, we’ll assume you
want us to contact you by post, push notification, email and text message with
information about Paywicks products, services, offers and promotions. Where
national laws require us to get your consent to send marketing messages, we’ll
do so in advance.
We use your personal data to personalise marketing messages about our products
and services so they are more relevant and interesting to you (where allowed by
law). This may include analysing how you use our services and your transactions.
You can object to profiling for direct marketing purposes. You can also adjust
your preferences or tell us you don't want to hear from us at any time. Just use
the privacy settings in the Paywicks app or tap the unsubscribe links in any
marketing message we send you.
If you do not want to receive personalised marketing messages, and opt out from
receiving them, you will not receive any marketing communications. However, you
may still receive generic information about our products and services in the
Paywicks app.
We won't pass your details on to any organisations outside Paywicks for marketing
purposes without your permission. You can find out more in the Do you share my
personal datawith anyone else? section below.
Our legal basis is:
Consent (where we are required by law to collect your consent); or
Legitimate interests (to send you marketing and to provide information
relevant to your interests).
What are my rights?
Your right
What it means
You have the
right to be told how we
use your personal data
We provide
this privacy notice to explain how
we use your personal data.
If you ask, we’ll provide a copy of the
personal data we hold about you. We
can’t give you any personal data about
other people, personal data which is
linked to an ongoing criminal or fraud
investigation, or personal data which is
linked to settlement negotiations with
you. We also won't provide you with any
communication we've had with our legal
advisers.
You can ask us to
correct your personal
data if you think it's wrong
You can have incomplete or inaccurate
personal data corrected. Before we
update your file, we may need to check
the accuracy of the new personal data
you have provided.
You can ask us to
delete your personal
data
use your personal data
You can ask
us to delete your personal data if:
Just to let you know, we may not be able
to agree to your request. As a regulated
financial services provider, we must
keep certain customer personal data even
when you ask us to delete it (we've
explained this in more detail below). If
you've closed your Paywicks account, we
may not be able to delete your entire
file because these regulatory
responsibilities take priority. We’ll
always let you know if we can't delete
your personal data.
You can object to
us processing your
personal data for marketing purposes
use your personal data
You can tell us to stop using your
personal data, including profiling you,
for marketing.
You can object to
us processing other
personal data (if we’re using it for
legitimate interests)
If our legal basis for using your
personal data is 'legitimate
interests' and you disagree with us
using it, you can object.
However, if there is an overriding
reason why we need to use your
personal data, we will not accept
your request.
If you object to us using personal
data which we need in order to
provide our services, we may need to
close your account as we won’t be
able to provide the services.
You can ask us to
restrict how we use
your personal data
You can ask us to suspend using your
personal data if:
You can ask us to
transfer personal
data to you or another company
If we can, and are allowed to do so
under regulatory requirements, we’ll
provide your personal data in a
structured, commonly used,
machine-readable format.
You can withdraw
your permission
If you’ve given us the consent we
need to use your personal data, you
can withdraw it at any time by
changing your privacy settings in
the Paywicks app or sending an email
to [email protected]
(Please note, it will have been
lawful for us to use the personal
data up to the point you withdraw
your permission.)
You can ask us to
carry out a human
review of an automated decision we
make about you
If we make an automated decision
about you that significantly affects
you, you can ask us to carry out a
manual review of this decision.
Your ability to exercise these rights will depend on a number of factors. Sometimes, we won’t be able to agree to your request (for example, if we have a legitimate reason for not doing so or the right does not apply to the particular information we hold about you).
How do I exercise my rights?
To exercise any of your rights set out in the previous section, you can contact us through the Paywicks app or send us an email at [email protected].
For security reasons, we can't deal with your request if we’re not sure of your identity, so we may ask you for proof of ID.
If a third party exercises one of these rights on your behalf, we may need to ask for proof that they’ve been authorized to act on your behalf.
When you exercise one of your rights or update your privacy settings in the Paywicks app, it may take us up to one month to respond or implement your changes.
Paywicks will usually not charge you a fee when you exercise your rights. However, we’re allowed by law to charge a reasonable fee or refuse to act on your request if it is manifestly unfounded or excessive.
If you’re unhappy with how we’ve handled your request you can complain to your local data protection authority.
Do you share my personal
data with anyone else?
Paywicks
We do not share your personal data with other companies but could:
How do you protect my personal data?
We recognize the importance of protecting and managing your personal data. Any personal data we process will be treated with the utmost care and security. This section sets out some of the security measures we have in place.
We use a variety of physical and technical measures to:
How long will you keep my personal data?
We’ll generally keep your personal data for six years after our business relationship with you ends, or such period as may be required by applicable local laws.
We’re required to keep your personal data for this long by anti-money laundering and e-money laws. We may keep your personal data for longer because of a potential or ongoing court claim, or for another legal reason.
How will you keep me updated about how you use my personal data?
If we change the way we use your personal data, we’ll update this notice and, if appropriate, let you know by email, through the Paywicks app, or through our website.
Will my personal data go
outside the United Kingdom
or Europe?
As we provide an international service, we may need to transfer your personal data outside the United Kingdom or European Economic Area (EEA) to help us provide our services.
For example, if you make an international payment, we’ll send funds to banks outside of the United Kingdom or EEA. We might also send your personal data outside of the United Kingdom or EEA to keep to global legal and regulatory requirements, and to provide ongoing support services.
We may send your personal data outside of the United Kingdom or EEA to:
Keep to global legal and regulatory requirements
Provide ongoing support services
Credit reference agencies, fraud prevention agencies, law enforcement authorities
Enable us to provide you with the products or services you have requested
If we transfer your personal data to another country that doesn’t offer a standard of data protection equivalent to the United Kingdom or EEA, we will make sure that your personal data is sufficiently protected. For example, we’ll make sure that a contract with strict data protection safeguards is in place before we transfer your personal data. In some cases, you may be entitled to ask us for a copy of this contract.
If you would like more information, please contact us by sending an email to [email protected].
How do you protect my
personal data?
We recognize the importance of protecting and managing your personal data. Any personal data we process will be treated with the utmost care and security. This section sets out some of the security measures we have in place.
We use a variety of physical and technical measures to:
Keep your personal data safe
Prevent unauthorized access to your personal data
Make sure your personal data is not improperly used or disclosed
Electronic data and databases are stored on secure computer systems with control over access to information using both physical and electronic means. Our staff receives data protection and information security training. We have detailed security and data protection policies that staff is required to follow when they handle your personal data.
While we take all reasonable steps to ensure that your personal data will be kept secure from unauthorized access, we cannot guarantee it will be secure during transmission by you to our app, website, or other services. We use HTTPS (HTTP Secure), where the communication protocol is encrypted through Transport Layer Security for secure communication over networks, for all our apps, web, and payment-processing services.
If you use a password for the Paywicks app or our website, you will need to keep this password confidential. Please do not share it with anyone.
When you use our public services, which include our social network accounts and the Paywicks Community forum, do not share any personal data that you don't want to be seen, collected, or used by other customers, as this personal data will become publicly available.
How long will you keep my
personal data?
We’ll generally keep your personal data for six years after our business relationship with you ends, or such period as may be required by applicable local laws.
We’re required to keep your personal data for this long by anti-money laundering and e-money laws. We may keep your personal data for longer because of a potential or ongoing court claim, or for another legal reason.
How will you keep me updated
about how you use my
personal data?
If we change the way we use your personal data, we’ll update this notice and, if appropriate, let you know by email, through the Paywicks app, or through our website.
Do you use cookies?
We use cookies to analyze how you use our website.
We can also use pixels or web beacons in the direct marketing emails that we send to you. These pixels track whether our email was delivered and opened and whether links within the email were clicked. They also allow us to collect information such as your IP address, browser, email client type, and other similar details. We use this information to measure the performance of our email campaigns, and for analytics.
You can control whether you receive direct marketing emails through the privacy settings in the Paywicks app.
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