PRIVACY POLICY – MONESE LIMITED INTRODUCTION

Welcome to Monese Limited’s privacy notice.

Monese Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you:

  • Visit our website www.monese.com (Site) (regardless of where you visit it from);

  • Use our Monese mobile application (App) once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device;

  • Use any of the services accessible through the App or the Site (the Services); and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively you can download a pdf version of the policy here https://monese.com/privacy. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

  1. IMPORTANT INFORMATION AND WHO WE ARE

  2. THE DATA WE COLLECT ABOUT YOU

  3. HOW IS YOUR PERSONAL DATA COLLECTED

  4. HOW WE USE YOUR PERSONAL DATA

  5. DISCLOSURES OF YOUR PERSONAL DATA

  6. INTERNATIONAL TRANSFERS

  7. DATA SECURITY

  8. DATA RETENTION

  9. YOUR LEGAL RIGHTS

  10. GLOSSARY

  11. PPS as DATA CONTROLLER


1. Important information and who we are

1.1 Purpose of this privacy notice

This privacy notice aims to give you information on how Monese Limited and the Monese prepaid debit card issuer, Prepay Technologies Ltd, collects and process your personal data through your use of our Site or App, including any data you may provide through our Site or App when you subscribe to our Services pursuant to the Monese Personal Account Terms & Conditions and Monese Business Account Terms & Conditions, search for a product, take part in a competition, promotion, or survey or sign up to our newsletter.

Our Site and App are 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.

1.2 Controller

Monese Limited is the controller and responsible for your personal data (referred to as “Monese”, “we”, “us” or “our” in this privacy notice) that is generated in connection with your Monese personal account and/or Monese business account (Monese Account) on our Site and our App and in any contact we have with you, throughout the course of our relationship.

Prepay Technologies Ltd (PPS) is a separate controller in relation to your Monese Card Monese Card and/or Monese Business Card (“Monese Card”) and all necessary activities relating to the operation of the Monese Card. All details about how PPS will hold and process your data are set out in paragraph 11 of this Privacy Notice.

Both Monese and PPS have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to their processing of personal data in accordance with this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights. Please contact the relevant DPO you wish to speak to, using the details set out below.

1.3 Contact details

Our full details are:

Full name of legal entity: Monese Limited

Name or title of DPO: Data Protection Officer for Monese Limited

Email address: privacy@monese.com

Postal address: 85 Great Portland Street, First Floor, London, England W1W 7LT

PPS’ full contact details are:

Full name of legal entity: Prepay Technologies Ltd

Name or title of DPO: Data Protection Officer for Prepay Technologies Ltd

Email address: DPO@prepaysolutions

Postal address: PO Box 3883, Swindon SW3 9EA

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.

1.4 Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 17th October 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.

1.5 Third-party links

Our App and our Site 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 App or our Site, we encourage you to read the privacy notice of every website or App you visit.


2. THE DATA WE COLLECT ABOUT 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 as follows:

  • Identity Data includes your full name, username or similar identifier, date of birth, gender, nationality, personal description, photograph and video.

  • Contact Data may include contact address, email address and telephone numbers.

  • Contractual Data includes details about the contractual agreement we have in place with you.

  • Data on relationships with legal entities includes data submitted by you or obtained from public registers or through third party on representatives, directors and beneficial owners of a legal entity subscribing to our Services.

  • Financial Data includes information related to your Monese Account and related debit card(s).

  • Transaction Data includes details about the use of your Monese Account, debit card(s) and other details of products and Services you have obtained from us.

  • Due Diligence Data includes information we are required by law to process about you to comply with our obligations in relation to illegal activities involving money (for example, fraud, money laundering and terrorist financing) or in compliance with international sanctions, which processing data about the origin of funds and/or transaction parties, the purpose of our business relationship, account usage behaviour, political exposed status (i.e. are you a politically exposed person or PEP).

  • Technical Data includes browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, your login data, unique device identifier (for example, the IMEI number of any device you use to access our Site and/or App (Device), the MAC address of the Service’s wireless network interface, or the mobile phone number used by the Device) and other technology on a Device.

  • Locational Data includes information about your geographical location, this information may be provided by your mobile phone, the address where you connect a Device to the internet (internet protocol (IP) address), or a shop, where you buy something with your Monese Card.

  • Contractual Data includes details about the products and Services we provide to you and the terms under which we provide these.

  • Usage Data includes information about how you use our Site, App, products and Services.

  • Marketing and Communications Data includes your preferences in receiving marketing communications from us and our third parties, your communication preferences and what we learn about you in relation to marketing from letters, emails and conversations between us.

We 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 data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site and/or App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Some of the personal data we collect is classified as Special Categories of Personal Data (also known as sensitive personal data – further defined here ). In particular, we may process personal data that relates to biometric data (voice and face recognition only) and any criminal convictions and offences. Where we process such sensitive personal data (for example, during video calls and recordings of phone conversations or when we are collecting Due Diligence Data), we will usually do so on the basis that it is necessary for reasons of substantial public interest, to meet regulatory requirements relating to unlawful and dishonest acts, to establish, exercise or defend any legal claims, or in some cases, with consent. In any case, we will carry out the processing in accordance with applicable laws.

2.1 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 we have or are trying to enter into with you (for example, to provide you with products or Services (i.e. access to our Site or App)). 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.


3. HOW IS YOUR PERSONAL DATA COLLECTED?

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

  • Direct interactions. You may give us your Identity, Contact, Financial and Due Diligence Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • download or register the App

  • create a Monese Account on our App;

  • enter into any transactions via the App;

  • subscribe to our Service or publications;

  • apply for our products or Services;

  • request marketing to be sent to you;

  • enter a competition, promotion or survey;

  • participate in discussion boards or other social media functions on our Site or App; or

  • communicate with us via email, on-line chat, video call and/or phone call or give us some feedback.

  • Automated technologies or interactions. As you interact with our Site and/or App, we may automatically collect Technical Data about your equipment like the type of Device you use, your Device’s operating system, browsing actions and patterns, App activity and version. We collect this personal data by using cookies, App session logs and other similar technologies. We may also receive Technical Data about you if you visit other websites and/or apps employing our cookies. Please see our cookie policy for further details.

  • Third parties or publicly available sources.

  • We work closely with third parties who may provide us with Identity, Contact and Due Diligence Data (including, for example, business partners based inside and outside the EU, sub-contractors in delivery services and advertising networks based inside and outside the EU, analytics providers based inside and outside the EU, search information providers such as Google based outside of the EU, fraud prevention agencies based inside and outside the EU, customer service providers based inside and outside the EU, social media organisations such as Facebook or Twitter based outside of the EU). We will also receive Identity, Contact and Due Diligence Data about you from third parties we use to screen you for PEP status, screen sanctions lists, perform criminal history checks and verify your identity based inside and outside the EU.

  • Technical Data from the following parties:

a) analytics providers such as Google and Branch Metrics Inc based outside the EU;

b) advertising networks such as Google based outside the EU; and

c) search information providers such as Google based outside the EU.

  • Identity, Contact, Diligence, Financial and Transaction Data from providers of technical and payment services (including domestic, European and international payment systems), such as SWIFT based inside and outside of the EU.

  • Identity, Contact Data and Due Diligence Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.


4. HOW WE USE YOUR PERSONAL DATA

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

  • Where we need to perform the contract we are about to enter into or have entered into with you.

  • Where it is in our legitimate interests to detect, prevent and investigate fraud, money laundering, terrorist financing and other crimes.

  • Where we need to comply with a legal or regulatory obligation, for example, to cooperate with our regulators and/or law enforcement bodies.

  • In the case of Special Categories of Personal Data, where processing of such data is in the substantial public interest (for example, for us to comply with our regulatory requirements).

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to certain marketing activities. You have the right to withdraw consent to marketing related processing at any time by visiting the settings section in our App.

4.1 Purposes for which we will use your personal data

We use your personal data in the following ways:

  • personal data that you provide to us is used to:

  • provide you with the information, products and Services that you request from us (including access to your Monese Account on our App and our money management services)

  • perform payment transactions requested by you on your Monese Account via both national and international payment systems - comply with rules and obligations specified in card certification schemes such as when a chargeback request is filed or a card related dispute has been lodged

  • to protect against fraud and comply with our regulatory and anti-financial crime regulations

manage and administer our business

  • perform customer surveys, market analyses and statistics so we can improve our Services and user experience, and develop new offerings based on our customers preferences and feedback

  • notify you about changes to our Services and help you to solve any difficulties you may encounter while using our products and Services

  • assess the quality of our customer services and to provide staff training. Calls to our customer support may be recorded and monitored for these purposes

perform analysis on customer complaints for the purposes of preventing errors and process failures and rectifying negative impacts on customers

  • provide you with information about new products and Services including personalised offers and information about upcoming campaigns and games in accordance with your marketing preferences and location (see Marketing )

  • attract customers with similar preferences and interests as yourself via retargeting/remarketing campaigns by means of Facebook custom audiences. Some of the data that we disclose to Facebook is Aggregated Data or anonymised data. We will only disclose your personal data to Facebook if we have your consent or it is in our legitimate interests to do so.

  • personal data that we receive from third parties is combined with the personal data that you provide to us and used for the purposes described above.

  • personal data about your use of our Site and App is used to:

  • to provide you with our Services (including money management)

administer our Site and App and for internal operations, including troubleshooting, data analytics, testing, research, statistical and survey purposes

  • to improve our Site and App to ensure that content is presented in the most effective manner for you and for your Device.

  • to allow you to participate in interactive features of our Site and App, when you choose to do so

  • as part of our efforts to keep our Site and App safe and secure

  • to protect against fraud and comply with our regulatory and anti-financial crime regulations to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you based on your preferences (also see Marketing )

  • personal data that we collect from your Device (for example, location data) is used to:

  • protect against fraud and other financial crime

  • to provide you with our money management services

  • to deliver any relevant marketing to you based on your location

  • Fraud Prevention Agencies

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights can be found under paragraph 12.

We will always tell fraud prevention agencies if you give us false or fraudulent information. They will also allow other organisations (in the UK or abroad), including law enforcement agencies, to access this information to prevent and detect fraud or other crimes.

You can ask us for the details of the fraud prevention agencies we share information with.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

4.2 Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

  • Promotional offers from us

We may use your personal data and location 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.

You may receive promotional communications from us via email, SMS, in-app messages, telephone or post if you have requested information from us or signed up to use our Services, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that communication.

  • Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Monese group of companies for marketing purposes See Internal Third Parties as set out in the Glossary for further information on the Monese Group.

  • Retargeting

Sometimes we use social media sites to retarget/remarket our products and Services to a similar audience as that of our existing customer base. Some of the data that we disclose to social media sites is Aggregated Data or anonymised data. We will only disclose your personal data to social media sites if we have your consent or it is in our legitimate interests to do so.

  • Opting out

You can ask us or third parties to stop sending you our marketing messages at any time by logging into our App and checking or unchecking relevant boxes under account settings, to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time here.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/Service purchase, product/Service experience or other transactions.

4.3 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 our Site may become inaccessible or not function properly. For more information about the cookies we use, please see https://monese.com/cookies.

4.4 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 at privacy@monese.com

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.


5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary.

  • External Third Parties as set out in the Glossary.

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

If we are under a duty to disclose or share your personal data to comply with any legal or regulatory obligation, we will only disclose to the extent required to comply with such obligation.


6. International transfers

Some of our external third parties are based outside the European Economic Area (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 ensuring at least one of the following safeguards is implemented:

  • Subject to the following paragraphs, we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en)

  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

  • 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 the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

  • Where we share data with fraud and crime prevention agencies and fraud and/or criminal history checking service providers in the EEA, they may transfer your data outside of the EEA, in this case they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the EEA and/or they may require the recipient to subscribe to certain standards, intended to enable secure data sharing.

Please contact us at privacy@monese.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.


7. Data security

We have put in place appropriate physical and technological 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.

Our internal control systems regarding information security are fully ISO standard 27001:2013 (Information Security Management) compliant.

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.


8. Data retention

HOW WILL YOU USE MY PERSONAL 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. In practice this means that we will keep:

  • basic information about our customers (including Contact, Identity, Due Diligence, Financial and Transaction Data) for 6 years after they cease being customers (unless we are required to keep it longer; for example, due to a court order or investigation by law enforcement agencies or regulators)

  • complaint records for 3 years

  • your communications with us are retained for the period of our contractual relationship and deleted 6 months after the business relationship between us has come to an end

  • Technical Data regarding your use of our Site and App and Location Data we have collected from your Device will be deleted or anonymized 6 months after the end of our business relationship

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.


9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact us at privacy@monese.com

9.1 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.

9.2 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.

9.3 Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


10. Glossary

10.1 Lawful Basis

Performance of a contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best Service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at privacy@monese.com.

10.2 Monese Card

Monese Card is a prepaid debit card related to Monese Personal Account or Monese Business Account issued pursuant the Personal Account Terms and & Conditions or Business Account Terms & Conditions

10.3 Special Categories of Personal Data

Includes data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

10.4 Third Parties

Internal Third Parties - Group companies, affiliates and branches of Monese Ltd of which there is only one: Monese Ltd Eesti Filiaal, Estonia (Registry number: 12835419).

External Third Parties

  • Service providers acting as processors based in the EU and US who provide:

  • IT and system administration services such as analytics and search engine providers

  • data storage, server, hosting and security providers

  • delivery service providers

  • payment service providers and processors and providers of technical and payment services (including domestic, European and international payment systems).

  • customer service and support systems providers, so we can communicate with you via email, chat, video or phone call.

  • third parties who assist with our marketing communications and who provide automation and analytics platforms

  • criminal history check providers and verification of identity providers

  • We will share your Identity, Contact, Transaction, Contractual and Usage Data with PPS. PPS is a separate controller of your Identity, Transaction and Usage Data. In order to provide you with the Monese Card, PPS will share your Identity and Transaction Data with its service providers based in the EU and US, including MasterCard, card manufacturers, suppliers of identity validation services and us. Please click here for further information.

  • Advertisers and advertising networks and social media companies based in EU and/or US that require some personal data to select and serve relevant adverts to you and others. We limit the information about identifiable individuals that we disclose to our advertisers. For example, we may provide them with a hashed ID (data hashed by modern pseudonymous methods, including MD5 and SHA-256 double-hashing processes) which is used to match with data already held by the advertiser, advertising network or social media company (as opposed to providing your Contact Data).

  • The Financial Conduct Authority (FCA) acting as processor, joint controller or controller based in the United Kingdom for the purposes of compliance with the Electronic Money Regulations 2011 and related legislation and policies. Please be aware that the FCA has a legal duty to co-operate and exchange information with other government and regulatory agencies in the United Kingdom and internationally.

  • Fraud Prevention Agencies in UK, for example, NCA and CIFAS and providers we use to process and check Due Diligence Data based in the UK, EU and US, including compliance system providers for sanctions and politically exposed persons (PEP) checks.

HM Revenue & Customs, The Financial Ombudsman Service, the UK Financial Services Compensation Scheme or other government or regulatory agencies acting as processors, joint controllers or controllers based in the United Kingdom.

  • If you ask us to, we will share information with any third party that provides you with account information or payment services. Where you ask us to do this, you are allowing that third party to access information relating to your account. We are not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provide to you.

10.5 Your Legal Rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request 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, though we may need to verify the accuracy of the new data you provide to us.

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.

Object to 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.

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.

Request the transfer of your personal data to you or to a third party. 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.

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.


11. PPS AS DATA CONTROLLER

Your Monese Card and/or Monese Account is issued by PPS (see details below). PPS is the Data Controller in relation to your Monese Card and all necessary activities relating to the operation of the Monese Card including: allowing you to receive, activate and use your Monese Card; activating, managing and using your online Monese Account where applicable; making and receiving payment transactions, meeting legal requirements regarding your Monese Account and Monese Card; answering your requests and providing information to you.

  • Contact details for the PPS Data Protection Officer click here

  • The purposes and legal basis for processing your personal information

PPS will use your personal data in the following circumstances:

  • where PPS need to perform a contract they are about to enter or have entered with you

  • where PPS need to comply with a legal or regulatory obligation.

The purposes for which PPS process your personal data are:

  • to provide you with a Monese Card

  • to perform payment transactions requested by you on your Monese Card via both national and international payment systems

  • to comply with rules, contractual and legal obligations PPS is subject to

PPS does not use your personal data for marketing purposes and will not share your information with third parties for marketing purposes.

Categories of personal data and collection

PPS collects, uses, stores and transfers different kinds of personal data about you which has been grouped together as follows:

  • Identity Data - full name and date of birth

  • Contact Data - contact address, email address(es) and telephone numbers

  • Transaction Data - details about use of your Monese Card and payments to and from your Monese Account with us

  • Contractual information - details about the products or services we provide to you

  • Due Diligence Data - details about you that are stored in documents in various formats, or copies of them. This could include things like your passport, drivers licence or birth certificate collected to fulfil customer due diligence requirements, that we are required by law to collect and process.

Personal data will only be collected directly and voluntarily from you as part of the application process or as a result of transactions relating to your Monese Card(s). Some personal data may be verified by PPS with use of publicly accessible sources to fulfil our customer due diligence requirements, that we are required by law to carry out.

Sending personal data outside of the EEA

PPS will only send your personal data outside of the European Economic Area (EEA) in compliance with applicable law, including to:

  • Follow your instructions

  • Comply with a legal duty

In relation to personal data processed by MasterCard, certain processors used by MasterCard are located outside of Europe. Personal data processed by MasterCard is subject to MasterCard Binding Corporate Rules, which you have enforcement rights under as a third-party beneficiary.

Recipients (or categories of recipients) of personal information

PPS is committed to ensuring that your information is secure with us and with third parties who act on our behalf. These third parties include MasterCard, card manufacturers based inside/outside the EU, suppliers of identity validation services based inside and outside the EU, IVR and call recording (telephone) suppliers based inside and outside the EU and Monese Ltd.

We use safeguards to make sure that your information remains confidential and accurate and we may monitor or record calls, emails, text messages or other communications in order to protect you and us.

Retention of personal information

We do not keep your personal data for longer than we need to, which in respect of your name, your Monese Card and Account details and records of transactions you have made or received is usually up to 7 years after the end of the relationship between us. We may delete some data upon termination of the contract such as records of communication to or from you, unless we are required to keep it for longer (for example due to a court order or investigation by law enforcement agencies or regulators, or due to any legal requirement we are subject to).

Your Rights

You have certain legal rights to control what we do with your information, and see paragraph 10.5 for a summary of your legal rights.

To exercise any of your legal rights in respect of the personal data we process about you, you can email PPS at dpo@prepaysolutions.com or you can write to PPS DPO at PO Box 3883, Swindon SN3 9EA.

Your right to lodge a complaint with the Information Commissioner’s Office

If you wish to raise a complaint on how we have handled your personal information, you can contact our Data Protection Officer. We hope that we can address any concerns you may have, but if we fail to address your complaint you can contact the Information Commissioner’s Office (https://ico.org.uk/).

Financial crime prevention

PPS will use your personal data to help decide if your account(s) may be being used for fraud or money-laundering. We may detect that an account is being used in ways that fraudsters work or we may notice that an account is being used in a way that is unusual.

If we think there is a risk of fraud, we may stop activity on the accounts or refuse access to them. We might also check and share your information with fraud prevention agencies. If fraud is identified or suspected, these agencies may keep a record of that information and we may refuse to provide any further services to you. In addition, law enforcement agencies may access and use this information.

If you choose not to give personal information

If you choose not to give us your personal information, it may mean that we cannot perform services needed to run your Monese Card. It could mean that we cancel your Monese Card or other services you have with us.

12 FAIR PROCESSING FOR SHARING DATA WITH FRAUD PREVENTION AGENCIES

Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.

WHAT WE PROCESS AND SHARE

The personal data you have provided, we have collected from you, or we have received from third parties may include your:

  • name

  • date of birth

  • residential address and address history

  • contact details such as email address and telephone numbers

  • financial information

  • employment details

  • identifiers assigned to your computer or other internet connected device including your Internet Protocol (IP) address

  • vehicle details

When we and fraud prevention agencies process your personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.

We, and fraud prevention agencies, may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

AUTOMATED DECISIONS

As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if:

  • our processing reveals your behaviour to be consistent with that of known fraudsters or money launderers; or is inconsistent with your previous submissions; or

  • you appear to have deliberately hidden your true identity.

You have rights in relation to automated decision making: if you want to know more please contact us using the details above.

CONSEQUENCES OF PROCESSING

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested, or to employ you, or we may stop providing existing services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details above.

DATA TRANSFERS

Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.

YOUR RIGHTS

Your personal data is protected by legal rights, which include your rights to:

  • object to our processing of your personal data;

  • request that your personal data is erased or corrected;

  • request access to your personal data.

For more information or to exercise your data protection rights please, please contact us using the contact details above.

If you are unhappy about how your personal data has been used please refer to our complaints policy. Complaints can be sent to: privacy@monese.com. You also have a right to complain to the Information Commissioner's Office (www.ico.org.uk) which regulates the processing of personal data.

Get access to our latest features, offers & thrifty tips

${message}

You can unsubscribe at any time by clicking the unsubscribe link in the footer of any email you receive from us, or by contacting us at info@monese.com. By clicking this tick-box, you agree that we may process your information in accordance with the terms of our privacy policy