Privacy Policy
WE ARE 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
2Pay Limited (No.12276058) is Registered by the Financial Conduct Authority (FCA) (Firm Reference 916914). Registered address: 109 Lodge Lane, Liverpool, Merseyside, England, L8 0QF, United Kingdom.
- Why do I need to read this policy?
We will collect your personal data when you use:
- our website at 2pays.co.uk;
- the 2Pay app; or
- any of the services you can get access to through the 2Pay app or website.
When we say ‘personal data’, we mean information which can be used to personally identify you (for example, a combination of your name and postal address).
THIS POLICY CONTAINS IMPORTANT INFORMATION
This policy explains what information we collect, how we use it, and your rights if you want to change how we use your personal data.
If you have concerns about how we use your personal data, you can contact our Data Protection Officer at info@2pays.co.uk
Your personal data
- What personal data do you collect about me?
WE COLLECT DIFFERENT TYPES OF PERSONAL DATA FROM YOU AND OTHERS
The information below explains what personal data we collect and use.
Information you give us
We collect information you provide when you:
- fill in any forms;
- correspond with us;
- register to use the 2Pay app;
- open an account or use any of our services;
- take part in online discussions, surveys or promotions;
- speak with a member of our customer support team (either on the phone or through the 2Pay app);
- enter a competition; or
- 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 2Pay username (this is random and is automatically assigned to you when you first join but you will be able to change it), password and other registration information;
- Details of your bank account, including the account number, sort code and IBAN;
- Details of your 2Pay 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);
- Identification documents (for example, your passport or driving licence), copies of any documents you have provided for identification purposes, and any other information you provide to prove you are eligible to use our services;
- Information you provide when you apply for credit, including details about your income and financial obligations;
- 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-Client (KYC) checks or where you upload a photo to your 2Pay account).
If you give us personal data about other people (such as your spouse or family), or you ask us to share their personal data with third parties, you confirm that you have brought this policy to their attention beforehand.
We collect personal data from third parties, such as credit-reference agencies, financial or credit institutions, official registers and databases, as well as 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 will also collect personal data from accounts you hold with third party banks (and some accounts with third party providers that aren’t banks) so that you can see everything in one place in your 2Pay app. You can create a linked account by activating Open Banking in the app.
Information from social media
Occasionally, we will 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).
If you are a 2Pay Business customer, we may collect information about you if you make it publicly available on social media websites or apps. We only do this as part of our 2Pay Business KYC checks. For example, if you have not yet set up a website for your business, we may need to look at information available on social media websites or apps to make sure your business is legitimate.
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 for 2Pay Business customers.
2Pay BUSINESS CUSTOMERS
If you are a 2Pay Business customer, we will need to confirm your identity as part of our KYC process. We will ask you to provide documents, and will also collect information from third parties, such as commercial registers, for this purpose.
- 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, or share it with other organisations, because we have a legitimate reason to use it and this is reasonable when balanced against your right to privacy.
- Consent
Where you’ve agreed to us collecting your personal data, for example when you have ticked a box to indicate you are happy for us to use your personal data in a certain way.
We have explained more about how we use your personal data in the How do you use my information? section below.
- Substantial public interest
Where we process 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.
- How do you use my personal data?
We use your personal data so we can provide the best service, tell you about products and services you may be interested in, and meet our legal obligations.
HERE’S AN EXAMPLE OF HOW WE USE YOUR PERSONAL DATA TO PROVIDE OUR SERVICES
If you apply for a credit product, we or our lending partner (the provider of the credit product) will carry out a credit check to better understand your financial circumstances and repayment history.
Our legal basis is one or more of the following:
- 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); or
- 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 are eligible to use our services. We also use it to help us better understand your financial circumstances and manage fraud risks related to your 2Pay account.
MARKETING AND PROVIDING NEW PRODUCTS AND SERVICES THAT MIGHT INTEREST YOU
We use your personal data to do the following:
o provide you with information about other products and services we offer that are similar to those you have already used (or asked about, where allowed by law).
o provide you with information about our products or services which we think you might be interested in. To help us do this, we may use information about you to help us better understand your interests. You can opt out of this by using the privacy settings in the 2Pay app or by emailing our Data Protection Officer at info@2pays.co.uk
o if you agree, provide you with information about our partners’ promotions or offers which we think you might be interested in.
o if you agree, allow our partners and other organisations to provide you with information about their products or services.
o measure or understand the effectiveness of our marketing and advertising, and provide relevant advertising to you.
o ask your opinion about our products or services.
process applications for products and services available through us, and make decisions about whether to approve applications.
Remember, you can ask us to stop sending you marketing information by adjusting your marketing choices (the Do you use my information for marketing? section below explains how to do this).
HERE’S AN EXAMPLE OF HOW WE USE YOUR PERSONAL DATA FOR MARKETING
If you are a 2Pay customer, we may contact you about optional extras or promotional offers. We may use personal data we gather about you through your use of our services to tailor these offers to you.
Our legal basis is one or more of the following:
- legitimate interests (to develop our products and services, define types of customers for new products or services, and to be efficient about how we meet our legal and contractual duties); or
- consent (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 2Pay app, (including troubleshooting, data analysis, testing, research, statistical and survey purposes), and to make sure that content from our website is presented in the most effective way for you and your device. For more information, please see our Cookies Policy.
We also use your personal data to allow you to take part in interactive features of our services, to tell you about changes to our services, and to help keep our website and the 2Pay app safe and secure.
HERE’S AN EXAMPLE OF HOW WE USE YOUR PERSONAL DATA TO RUN OUR SERVICES
If any changes we make to our services affect you, we’ll normally contact you using the email address you gave us when you signed up, or through the 2Pay app, to tell you about the changes.
Our legal basis is one or more of the following:
- 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); or
- consent (where required by law).
HELPING WITH SOCIAL INTERACTIONS
We use your personal data to help social interactions through our services or to add extra functions in order to provide a better experience.
HERE’S AN EXAMPLE OF HOW WE USE YOUR PERSONAL DATA FOR SOCIAL INTERACTIONS
We’ll let you know if any 2Pay customers are in the same area as you (if you and they have location services switched on).
If you give us permission, we’ll use the contacts list on your phone, so you can easily make payments to your contacts using the 2Pay app or upload photos to your savings vaults in the 2Pay app.
Our legal basis is one or more of the following:
- legitimate interests (to develop our products and services and to be efficient in meeting our obligations); or
- 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
We use your personal data to provide relevant advertising to you (for example, information on nearby merchants), to protect against fraud, and to let you know when any of your contacts who are 2Pay customers are in the same area as you (if they have location services switched on).
HERE’S AN EXAMPLE OF HOW WE USE YOUR LOCATION INFORMATION
If you go abroad, the 2Pay app may automatically tell you the exchange rate in that country.
Our legal basis is one or more of the following:
- keeping to contracts and agreements between you and us;
- legitimate interests (to develop and market our obligations and keep to regulations that apply to us); or
- consent (to track you when you have location services switched on).
PREPARING ANONYMISED STATISTICAL DATASETS
We prepare anonymised statistical datasets about our customers’ spending patterns for forecasting purposes or to help governments in policy-making. These datasets may be shared internally or externally with others, including non-2Pay 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. Anonymised statistical data cannot be linked back to you as an individual.
Our legal basis is:
- legitimate interests (to conduct research and analysis, including to produce statistical research and reports); or
- legal obligations.
HERE’S AN EXAMPLE OF WHY WE MAY ANONYMISE YOUR PERSONAL DATA
Some countries ask us to report spending statistics and how money enters or leaves each country. We may provide anonymised statistical information that explains the broad categories of merchants that 2Pay customers in that country spend their money with. We may also provide information about how 2Pay customers top up their accounts and transfer money in that particular country. However, we will not provide any customer-level information. It will not be possible to identify any individual 2Pay customer.
MEETING OUR LEGAL OBLIGATIONS, ENFORCING OUR RIGHTS AND OTHER LEGAL USES
We may need to share personal data about you:
- with other organisations (for example, fraud-prevention agencies);
- if this is necessary to meet our legal obligations or in connection with legal claims; or
- to help detect or prevent crime.
You can find out more in the Do you share my personal data with anyone else? section below.
Our legal basis is one or more of the following:
- legitimate interests (to keep to laws and regulations that apply to us);
- substantial public interest (if we process your sensitive personal data to keep to legal requirements that apply to us); or
- legal obligations.
- Do you make automated decisions about me?
Depending on the 2Pay 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. 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; or
- setting credit limits.
Opening accounts
- anti-money laundering and sanctions checks; and
- 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; or
- legal obligations.
- Do you carry out credit checks about me?
We and our lending partners will use credit-reference agencies (or other providers of credit information in relevant countries) to carry out credit checks on you if you apply (or tell us you want to apply) for a credit product through 2Pay.
We will 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; or
- 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).
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 2Pay credit product will vary depending on the country you live in. We will provide full details when you apply for a 2Pay credit product.
For UK users only
If you are located in the United Kingdom, we may also check your credit history to help us develop and, in the future, offer credit products that meet the needs of our customers. This will enable us to pre-filter the credit products that you may be eligible for and, in some cases, let you know before you apply if you will be accepted for a 2Pay credit product.
However, if you would prefer that we do not use your data in this way you can use the privacy settings in the 2Pay app to opt out.
Credit-reference agencies will not store any of your information that we send them when we use their services for this purpose and these checks do not leave any ‘footprint’ (trace) whatsoever on your credit record held by the credit-reference agency.
The three main credit-reference agencies 2Pay uses are:
- TransUnion (www.transunion.com);
- Equifax (www.equifax.com); and
- Experian (www.experian.com).
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); or
- legitimate interests (to develop and, in the future, offer credit products to our customers).
- How do you use my information for marketing?
If you sign up to our services, and where allowed by law, we will assume you want us to contact you by post, email and SMS text message with information about 2Pay products, services, offers and promotions. We may use the personal data we have collected about you in order to tailor our offers to you.
You can adjust your preferences, or tell us you don’t want to hear from us, at any time. Just use the privacy settings in the 2Pay app or click on the unsubscribe links on any marketing message we send you.
We won’t pass your details on to any organisations outside the 2Pay group of companies for their marketing purposes without your permission.
Your rights
- What are my rights?
The information below explains what rights you have and what those rights mean.
You have the right to be told about how we use your personal data
We provide this privacy policy to explain how we use your personal data.
If you ask, we will 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
You can ask us to delete your personal data if:
- there’s no good reason for us to continue using it;
- you gave us consent (permission) to use your personal data and you have now withdrawn that consent;
- you have objected to us using your personal data;
- we have used your personal data unlawfully; or
- the law requires us to delete your personal data.
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 where you ask us to delete it (we’ve explained this in more detail below). If you’ve closed your 2Pay account, we may not be able to delete your entire file because these regulatory responsibilities take priority. We will always let you know if we can’t delete your information.
You can object to us processing your personal data for marketing purposes
You can tell us to stop using your personal data for marketing.
You can object to us processing other personal data (if we are 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 want us to investigate whether it is accurate;
- our use of your personal data is unlawful but you do not want us to delete it;
- we no longer need the information, but you want us to continue holding it for you in connection with a legal claim; or
- you have objected to us using your personal data (see above), but we need to check whether we have an overriding reason to use it.
You can ask us to transfer personal data to you
If we can, and are allowed to do so under regulatory requirements, we will provide your personal data in a structured, commonly used, machine-readable format.
You can withdraw your permission
If you have given us any consent we need to use your personal data, you can withdraw your consent at any time by changing your privacy settings in the 2Pay app or sending an email to info@2pays.co.uk
(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 will not 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 2Pay app or send us an email at info@2Pay.com.
For security reasons, we can’t deal with your request if we are not sure of your identity, so we may ask you for proof of your ID.
2Pay will usually not charge you a fee when you exercise your rights. However, we are allowed by law to charge a reasonable fee or refuse to act on your request if it is manifestly unfounded or excessive.
If you are unhappy with how we have handled your personal data you can complain to your local data protection authority. In the United Kingdom, this is the ICO (website). In the EU, there are national and regional data protection authorities (a list is available on this website).
- Do you share my personal data with anyone else?
2Pay GROUP COMPANIES
We share your personal data within the 2Pay group of companies in order to provide you with the best service.
