Privacy notice for UK personal account customers

This privacy notice explains what personal data we collect, what we do with it, who we share it with, how long we keep it for and what legal rights you have.

For UK customers, Monese Ltd and Monese Finance Ltd are what are known as the data controllers of your personal data. This means they are responsible for deciding how your personal information is used, and for our credit and insurance products they do this jointly.

For customers in the European Economic Area (EEA), Monese EU is the data controller of your personal data.

When we refer to “Monese”, “we”, “us” or “our” in this notice, it is a reference to the companies mentioned above, depending on where you are based. If you are not sure which is the relevant company, please check your account terms or contact Monese’s Data Protection Officer (see below). Certain sections of this notice may only apply to customers who hold certain accounts with us (for example, Credit Products). If this is the case, we have made this clear in this privacy notice.

1. The personal data we hold about you

Your identity and contact data

This includes personal information about you (for example your name, date of birth, residential address, nationality, passport number) and your contact details.

In most cases the information is provided by you during the set up and management of Monese services, in the form of identity documents, your video selfie and any other personal data you have shared with us. In some cases, it may be provided by a third party where you have given your consent for them to share it with us.

We may be provided with additional identity and contact data by third parties that we use to perform due diligence (for example, fraud prevention agencies). In addition, we may source identity and contact data from publicly available sources such as Companies House and Electoral Registers.

Financial and service data

This is information about your Monese accounts, related debit cards and any other products and services that you have obtained from us. It includes things like account numbers, account balances and information about transactions. The information is generated as you use our services and in some cases it is shared with us by the organisations we use to provide our services.

Where you have linked your Monese account to one of our partner services (for example the Avios rewards programme) we may hold financial data for these services.

Information you permit us to access on your phone

This is information stored on your phone that you explicitly permit us to access (for example, your address book, photos and geolocation data).

Technical data

This is information about the phone you use (for example the browser version, time zone settings, phone operating system, IMEI number, IP address and other technical settings). This information is collected automatically when you use the Monese app.

Analytics

This includes information about how you interact with our services. We collect this information automatically when you visit our website or use the Monese app. Our use of cookies to help us achieve this is explained in our cookie policy.

Special category data

This is information that is considered more sensitive by regulators and includes your race, ethnic origin, political views, religion, trade union membership, genetics, biometrics, health and sexual orientation. With the exception of the video selfie and photo ID that you provide so we can verify your identity, we do not process this category of data. However, it is possible that we may hold special category data when you provide it to us, e.g. if it is included on documentation (for example your ID document) or when third parties provide it to us (for example details of criminal activities from the police). When this is the case, we will only process this information in strict accordance with the law.

2. What do we do with your personal data

We only use your personal data in order to provide great financial services and where there is a lawful basis to do so.

To fulfil our contract with you, we will use your personal data to:

• Administer and provide our financial and other related services (for example, account top-ups, payments, direct debits, standing orders and international transfers, as well as additional account benefit services).
• To develop and provide a high-quality user experience through the Monese app.

To fulfil our legal obligations we will use your personal data to:

• Verify your identity when you apply for a Monese account.
• Check applications against certain fraud prevention and sanctions databases.
• Implement measures to identify and prevent financial crime (for example, money laundering, fraud and terrorist financing).
• To make responsible lending decisions.

It is in our legitimate interests to use your personal data to:

• Keep you informed of the status of the Monese services you use.
• Provide a world class customer service experience.
• Perform a soft credit search to assess your suitability for our services.
• Check applications against certain fraud prevention databases.

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, in order to protect our business and to comply with the laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.

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 money laundering or known fraudulent conduct; 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 below. We also utilise the latest technology to make automated decisions for the verification of identities and the identification of financial crime. You can contact us to ask for a person to review an automated decision.

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 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.

Where it is necessary for our legitimate interests, we will use your personal data to:

• Provide you with information about Monese products and services that we think you may like. This only applies where you have signed up for a Monese account after 10 August 2020, otherwise we will only provide you with this information if you have provided your consent.
• Undertake analysis on our customers to better understand how to improve our products and services. This may involve us processing your data (including your transactions) or working with third parties (in which case we will not directly identify you or any other customers) to help better profile our customers and improve how we market our products. We will ensure that appropriate safeguards are put in place with such third parties so that your data is kept secure. See below for more information about processing by third party advertising partners for Monese’s analytics purposes.

With your consent, we will use your personal data to:

• Provide you with information about Monese products and services that we think you may like. This only applies if you signed up for a Monese account prior to 10 August 2020, otherwise we rely on our legitimate interests as described below.
• Invite you to participate in market research activities (such as focus groups, interviews and surveys).
• Provide you with information about third party products and services that we think you may like.
• Market our products.
• Operate our Hub (where you may choose to take advantage of a wide range of our partners’ products and services).

If we ask you for permission to process your personal data, you can refuse, or withdraw your permission at any time, by using the details at the end of this privacy notice or, if in relation to cookies or similar, through the cookie policy. To withdraw your consent to receive marketing message, you can set your preferences in the Monese app settings, or by following the opt-out link contained in marketing emails.

3. Who we share your personal data with

We will share your personal data with organisations and partners that enable and improve the Monese services you use or where we are required by law or court order. This includes:

• Group companies, affiliates and branches of Monese Ltd.
• Any third party after a restructure, sale or acquisition of any Monese company or debt, as long as that person uses your information for the same purposes you originally gave it to us for.
• Organisations that help us to verify your identity.
• Organisations that help us to provide our financial service. This includes:
  • Card issuers.
  • Independent third-party service providers who you (or a third party properly authorised to give instructions on your behalf) ask us to share information with (for example, providers of payment-initiation or account-information services). If we share your information with these third parties, we will have no control over how they use it. You (or the person with authority over your account) will need to agree this direct with the third party.
• Prepay service providers.
• PrePay Technologies Limited which is a separate independent Data Controller in relation to data processed in connection with 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; making and receiving payment transactions, meeting legal requirements regarding your Monese Account and Monese Card; answering your requests and providing information to you. The PrePay Technologies Limited privacy notice is available on its website: https://eps.edenred.com/privacy-policy-0.
• Payment service providers and technical and non-technical processors.
• The providers of our IT and cyber security services.
• Credit reference agencies. For details on how they use your personal data, see https://www.equifax.co.uk/crain, https://www.experian.co.uk/crain/index.html and https://www.transunion.co.uk/crain.
• Organisations that provide our customer service tools.
• Any organisations that enable the Monese services that you use.

To fulfil our legal obligations, we may share your personal data with:

• Government and law enforcements agencies in the pursuit of financial crime prevention and in the fight against terrorism (if there is no clear legal obligation for Monese to share the data then we may still share data where it is in the legitimate interests of Monese and the receiving organisation, for example because there is a strong suspicion of criminal activity).
• Tax authorities
• Fraud prevention agencies and providers of due diligence services.
• Any organisation that we are legally required to do so.

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

‍Where you have provided your consent, we may share your personal data with:

• Organisations that provide marketing and advertising services.
• Organisations that provide services in the Monese Hub.
• Anyone you give us explicit permission to do so.

To provide a truly borderless service we partner with and use service providers that are based outside the UK or EEA. We will only partner with organisations that meet the UK and EU data privacy requirements and where an appropriate contractual agreement is in place to protect our customers’ personal data.

In all cases, we will only share the personal data that is absolutely necessary to provide our services, fulfil our obligations to you and to fulfil any legal or regulatory requirements.

Processing by third party advertising partners for Monese’s analytics purposes

Our third party advertising partners will process your data (which will not directly identify you or any other customers) in order to provide advertising related services for us such as marketing analytics and marketing and performance optimisation but also for their own additional purposes. The table below provides a link to each partner’s privacy notice in case you want to learn more about what they do with your data.

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How to opt out of processing by third party advertising partners You can opt-out of ads tracking by adjusting your device settings. Do this by going into your phone’s device settings and opting out from there.

If you are on iOS, go to Settings > Privacy > Tracking and move the toggle to switch off.

If you are on Android, go to settings > Google > Ads > Opt out of ads personalisation and switch off by tapping the toggle on your screen to grey/off.

4. How long we keep your personal data

We hold our customers’ personal data only as long as necessary to meet our legal and regulatory obligations and where:

• The relevant local law requires us to hold your personal information for a longer period, or delete it sooner.
• You exercise your right to have your personal data erased from our systems (where it applies).
• We have a legitimate reason to keep it (for example, helping us to respond to queries or complaints, to show that we have given you fair treatment, in the fight against financial crime).
• Fraud prevention agencies can hold your personal data for different periods of time, including if you are considered to pose a fraud or money laundering risk.

5. Your rights

You have certain rights relating to your personal data:

The right to access personal data we hold about you

You may request access to all the personal data we hold about you. This is known as a ‘subject access request’.

The right to have your personal data erased from our systems

You may request access to all the personal data we hold about you. This is known as a ‘subject access request’.

If you believe that any of the personal data we hold about you is inaccurate, you have the right to have it updated (for example, you may wish to update your personal or contact details).

You may object to, or request that we restrict the processing of your personal data (for example, you may withdraw your consent for marketing at any time).

You may ask that we provide a copy of your personal data in a structured, commonly used and machine-readable format. You can request that we provide this to you directly, or that we transfer the data to a third party of your choosing.

Where we have used technology to make an automated decision, or to evaluate your suitability for a Monese service, you have the right to challenge the decision directly with a member of our customer service team.

To exercise any of these rights, simply submit a request to the customer service team via the chat function in the Monese app, or by emailing privacy@monese.com. We will aim to fulfil all requests within one calendar month.

6. Making a complaint

If you are unhappy about our management or use of your personal data you are entitled to make a complaint. We would prefer that complaints are emailed to complaints@monese.com, but you may register your complain via any of our customer service channels.

If we fail to resolve your complaint to your satisfaction, you may pursue your complaint via the relevant Data Protection Authority. For the UK this is the Information Commissioner’s Office. (see https://ico.org.uk/make-a-complaint/). Outside of the UK, you can contact the Belgian

Data Protection Authority (https://www.gegevensbeschermingsautoriteit.be/citizen/actions/lodge-a-complaint) or your local Data Protection Authority.

If you have any questions or would like to know more, don’t hesitate to contact our Data Protection Officer at dpo@monese.com, or write to us at Eagle House, 163 City Road, London EC1V 1NR.