Sync.Money UK Ltd
ABOUT THIS POLICY
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation, (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA).
Sync.Money is the data ‘controller’ of that personal data for the purposes of those laws. Our full details are set out at the end of this policy.
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. Key terms
It would be helpful to start by explaining some key terms used in this policy:
|We, us, our||Sync.Money UK Ltd trading as sync.money|
|Personal data||Any information relating to an identified or identifiable individual.|
|Special category personal data||Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data (when processed to uniquely identify an individual)Data concerning health, sex life or sexual orientation|
|Data subject||The individual who the personal data relates to|
2. Personal data we collect about you
We may collect, use and transfer the following personal data about you:
- Identity and Contact Data such as your name and contact information, including email address, date of birth, telephone number and company details (if applicable) and your gender
- Financial Data such as your billing information, information about your transactions (such as direct debits and standing orders), your bank account (or any other bank account connected via our services) and IBAN details and your payment card information
- Special Categories of Data including biometric data such as touch identification, fingerprints and/or facial recognition.
- Technical Data including information about how you use our website, IT, communication and other systems, internet protocol (IP) address, your location data, login data, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. This will include information about how you use our website and our products and/or services.
- Marketing and Communications Data which includes your preferences in receiving marketing from us and your communication preferences, and your responses to surveys, competitions and promotions.
- Career Data including your CV, career history information and references.
- Profile Data including username and password details and profile photographs.
We collect and use this personal data to provide products and/or services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing products and/or services to you.
3. How your personal data is collected
We collect most of this personal data directly from you by email, over the phone, text and/or via our website and applications you download. For example, you might provide certain identity information by completing one of our online forms such as our “Get Early Access” page in order to pre-order your ‘Founders’ card or if you make an enquiry with us, or if you request marketing information from us or provide us with feedback. However, we may also collect information:
- from publicly accessible sources, eg Companies House or HM Land Registry;
- directly from a third party, eg:
- sanctions screening providers;
- credit reference agencies; and
- customer due diligence providers.
- from a third party with your consent, eg your bank or building society
4. How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interest against your own.
The table below explains what we use your personal data for and why:
|What we use your personal data for||Types of personal data used||Our reasons|
|To provide products and/or services to you, including for example, to contact you or deal with our internal record keeping. To manage the relationship which we have with you, such as dealing with enquiries or complaints.||Identity and Contact Data
|To perform our contract with you or to take steps at your request before entering into a contract.This is also in our legitimate interests in ensuring that our services we provide are properly managed, and to comply with our regulatory obligations to handle complaints.|
|Preventing and detecting fraud against you or us||Identity and Contact Data
|For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for you and/ or us|
|Conducting checks to identify our customers and verify their identityScreening for financial and other sanctions or embargoesOther activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under anti-money laundering legislation or rules issued by the Financial Conduct AuthorityTo gather information on your use of our services and to provide you with custom information relating to your use of finances and/or our services||Identity and Contact Data
|To comply with our legal and regulatory obligationsThis will be necessary for our legitimate interests in the operation of our business|
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies||Identity and Contact Data
|To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||Technical Data
|For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control.To administer our website, including troubleshooting, data analysis, testing, system and maintenance support.||Identity and Contact Data
Marketing and Communications Data
|For our legitimate interests or those of a third party, ie to be as efficient as we can by improving our website and our customer service to you, improving the services and/or products we offer so we can deliver the best service to you at the best price, and in ensuring that our website works properly and for network security.|
|Ensuring the confidentiality of commercially sensitive information||Technical Data||For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable informationTo comply with our legal and regulatory obligations|
|Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures||Identity and Contact Data
Marketing and Communications Data
|For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price|
|Preventing unauthorised access and modifications to systems||Identity and Contact Data
Special Categories of Data
|For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for you and/or usTo comply with our legal and regulatory obligations|
|Updating and enhancing customer records||Identity and Contact Data
Marketing and Communications Data
|To perform of our contract with you or to take steps at your request before entering into a contractTo comply with our legal and regulatory obligationsFor our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products|
|Statutory returns||Identity and Contact Data
|To comply with our legal and regulatory obligations|
|Ensuring safe working practices, staff administration and assessments||Career Data||To comply with our legal and regulatory obligationsFor our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you|
|Marketing our services and those of selected third parties to:
||Identity and Contact Data
Marketing and Communications Data
|For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you, by developing, marketing and promoting our services and products.|
|To ensure our third-party providers can perform their obligations to us, such as to complete credit reference checks via external credit reference agencies||Identity and Contact Data
|For our legitimate interests in ensuring our third-party providers perform their services to us.From time to time we may also use IT providers and marketing consultants for the proper function of the website and to help us promote our services and products.|
|External audits and quality checks, eg for ISO or Investors in People accreditation and the audit of our accounts||Identity and Contact Data
|For our legitimate interests or those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standardsTo comply with our legal and regulatory obligations|
|To deal with new enquiries and contacts||Identity and Contact Data
|This will be necessary for our legitimate interests in the operation of our business in order to be able to respond to and deal with new enquiries, and to assess your application if you have applied for a job vacancy.|
|To gather your feedback on our services.||Identity and Contact Data
Marketing and Communications Data
|This will be necessary for our legitimate interests in seeking to improve the quality of our services.|
|To authenticate your access to your account, for example by using your biometric data, or by sending a temporary pass code to your phone.||Identity and Contact Data
Special Categories of Data
|This will also be necessary for complying with our legal obligations under payment services legislation, and for our legitimate interests in providing our services to you, and so that our applications are easy for you to use and are as secure as possible.In addition, we will only process Special Categories of Data, such as biometric data, on the basis that you have given your express consent for us to process it for this purpose.|
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, eg:
- we have your explicit consent;
- the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
- the processing is necessary to establish, exercise or defend legal claims.
In addition, we may disclose information about you to the extent that we are required to do so by law, regarding any legal proceedings or prospective legal proceedings, in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk) and / or where we may otherwise do so in accordance with applicable data protection legislation.
We may use your personal data to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with the utmost respect and never sell it to other organisations for marketing purposes.
Email, text message and any other marketing messages we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of subscriber data relating to engagement, geographic, demographics and already stored subscriber data. You have the right to opt out of receiving marketing communications at any time by:
- contacting us at email@example.com
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
- updating your marketing preferences by contacting us at firstname.lastname@example.org
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
6. Who we share your personal data with
We routinely share personal data with:
- companies within the Sync.Money UK Ltd group
- other third parties we use to help us run our business, eg marketing agencies or website hosts;
- third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
- credit reference agencies;
- our insurers and brokers;
- our bank;
- money exchange companies.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We may also need to:
- share personal data with external auditors, eg in relation to ISO or Investors in People accreditation and the audit of our accounts;disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations; or
- share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible, however, the the recipient of the information will be bound by confidentiality obligations.
7. Third-party links
This website may include links to third-party websites, such as our Facebook, Twitter, Instagram and LinkedIn social media pages. Clicking on those links 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 policies. You should read any policies and other statements on such websites carefully.
8. Where your personal data is held
Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK/ EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. How long your personal data will be kept
We will keep your personal data while you have an account with us or we are providing products and/or services to you. Thereafter, we will keep your personal data for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
To determine how long we should keep the different types of personal data we hold about you, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We will not keep your personal data for longer than necessary.
In some circumstances, we may anonymise 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 policy to you.
10. Transferring your personal data out of the UK and EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK/EEA, eg:
- with our offices or other companies within our group located outside the UK/EEA;
- with your and our service providers located outside the UK/EEA;
- if you are based outside the UK/EEA;
- where there is a European and/or international dimension to the services we are providing to you.
Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/EEA where:
- the UK government or, where the EU GDPR applies, the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
- a specific exception applies under data protection law
These are explained below.
We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:
- all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);
- Gibraltar; and
- Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.
The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.
Other countries or international organisations we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.
Transfers with appropriate safeguards
Where there is no adequacy decision, we may transfer your personal data to another country or international organisation if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.
The safeguards will usually include using legally-approved standard data protection contract clauses.
To obtain a copy of the standard data protection contract clauses and further information about relevant safeguards, please contact us (see ‘How to contact us’ below).
Transfers under an exception
In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, eg:
- you have explicitly consented to the proposed transfer after having been informed of the possible risks;
- the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
- the transfer is necessary for a contract in your interests, between us and another person; or
- the transfer is necessary to establish, exercise or defend legal claims
We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.
11. Further information
If you would like further information about data transferred outside the UK/EEA, please contact us (see ‘How to contact us’ below).
12. Your rights
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal data|
|Rectification||The right to require us to correct any mistakes in your personal data|
|Erasure (also known as the right to be forgotten)||The right to require us to delete your personal data—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data|
|Data portability||The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|To object||The right to object:—at any time to your personal data being processed for direct marketing (including profiling);—in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests.|
|Not to be subject to automated individual decision-making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
You will not have to pay a fee to access your personal data (or to exercise any 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.
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 personal data is not disclosed to a person who has no right to receive it. We may also contact you to ask you to clarify your request to speed up our response.
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 several requests in which case we will keep you updated.
If you would like to exercise any of those rights, please:
- email, call or write to us - see below: ‘How to contact us’; and
- let us have enough information to identify you (eg your full name, address and customer or matter reference number);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
13. Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses
and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
14. How to complain
Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner [or any relevant European data protection supervisory authority]. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
This privacy notice was last updated on 1 January 2021.
We may change this privacy notice from time to time - when we do we will inform you via our website or other means of contact such as email.
16. How to contact us
Address: Sync.Money UK Ltd, Level 39, One Canada Square, London, United Kingdom E14 5AB
This policy explains when and why we collect personal data about you, how we use it, the conditions under which we may disclose it to others and how we keep it secure.
TPL is committed to safeguarding the privacy of your information. By “your data”, "your personal data”, and “your information” we mean any personal data about you which you or third parties provide to us.
We may change this Policy from time to time so please check this page regularly to ensure that you’re happy with any changes.
Who are we?
Transact Payments Limited (“TPL”, “we”, “our” or “us”) is the issuer of your card and is the Data Controller for the personal data which you provide to us in relation to the card only. TPL is an e-money institution, authorised and regulated by the Gibraltar Financial Services Commission. Our registered office address is 6.20 World Trade Center, 6 Bayside Road, Gibraltar, GX11 1AA and our registered company number is 108217.
Sync.Money UK Ltd Limited (“Sync”) is the Program Manager for your card program and is the Data Controller for any personal data which you provide which is not related to the card. Sync is incorporated in the United Kingdom with registration number 11801268 and registered office at Level 39, One Canada Square, London E14 5AB.
How do we collect your personal data?
We collect information from you when you apply online or via a mobile application for a payments card which is issued by us. We also collect information when you use your card to make transactions. We also obtain information from third parties (such as fraud prevention agencies) who may check your personal data against any information listed on an Electoral Register and/or other databases.
On what legal basis do we process your personal data?
Your provision of your personal data and our processing of that data is necessary for each of us to carry out our obligations under the contract (known as the Cardholder Agreement or Cardholder Terms & Conditions or similar) which we enter into when you sign up for our payment services. At times, the processing may be necessary so that we can take certain steps, at your request, prior to entering into that contract, such as verifying your details or eligibility for the payment services. If you fail to provide the personal data which we request, we cannot enter into a contract to provide payment services to you or will take steps to terminate any contract which we have entered into with you.
We may also process your personal data to comply with our legal or regulatory obligations.
On occasion we may have a legitimate interest or those of a third party to process your personal data.
What type of personal data is collected from you?
When you apply for a card, we, or our partners on our behalf, collect the following information from you: full name, physical address, email address, mobile phone number, phone number, date of birth, gender, login details, IP address, identity and address verification documents.
When you use your card to make transactions, we store that transactional and financial information. This includes the date, amount, currency, card number, card name, account balances and name of the merchant, creditor or supplier (for example a supermarket or retailer). We also collect information relating to the payments which are made to/from your account.
How is your personal data used?
We use your personal data to:
- set up your account, including processing your application for a card, creating your account, verifying your identity and printing your card.
- maintain and administer your account, including processing your financial payments, processing the correspondence between us, monitoring your account for fraud and providing a secure internet environment for the transmission of our services.
- comply with our regulatory requirements, including anti-money laundering obligations.
Who do we share your information with?
When we use third party service providers, we have a contract in place that requires them to keep your information secure and confidential.
We pass your information to the following categories of entity:
- identity verification agencies to undertake required verification, regulatory and fraud prevention checks;
- information security services organisations, web application hosting providers, mail support providers, network backup service providers and software/platform developers;
- document destruction providers;
- anyone to whom we lawfully transfer or may transfer our rights and duties under this agreement;
- any third party as a result of any restructure, sale or acquisition of TPL or any associated entity, provided that any recipient uses your information for the same purposes as it was originally supplied to us and/or used by us.
- regulatory and law enforcement authorities, whether they are outside or inside of the EEA, where the law requires us to do so.
Sending personal data overseas
To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), e.g.:
- with service providers located outside the EEA;
- if you are based outside the EEA;
- where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and Gibraltar data protection law.
These non-EEA countries do not have the same data protection laws as Gibraltar and EEA. We will, however, ensure the transfer complies with data protection law and all personal data will be secure. We will send your data to countries where the European Commission has made an adequacy decision, meaning that it has ruled that the legislative framework in the country provides an adequate level of data protection for your personal data. You can find out more about this here.
Where we send your data to a country where the European Commission has not made an adequacy decision, our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses, please go to the European Commission’s website.
We send your data to the United States of America. In relation to data transfers to the USA, please go to the Privacy Shield website in order to find out more about the EU Commission-approved safeguards in place.
If you would like further information, please contact our Data Protection Officer on the details below.
How long do we store your personal data?
We will store your information for a period of five years after our business relationship ends in order that we can comply with our obligations under applicable legislation such as anti-money laundering and anti-fraud regulations. If any changes to applicable legislation require us to retain your data for a longer period of time, we shall retain it for that period. We will not retain your data for longer than is necessary.
Your rights regarding your personal data?
You have certain rights regarding the personal data which we process:
- You may request a copy of some or all of it.
- You may ask us to rectify any data which we hold which you believe to be inaccurate.
- You may ask us to erase your personal data.
- You may ask us to restrict the processing of your personal data.
- You may object to the processing of your personal data.
- You may ask for the right to data portability.
- If you would like us to carry out any of the above, please email the Data Protection Officer at DPO@transactpaymentsltd.com.
How is your information protected?
We implement security policies and technical measures in order to secure your personal data and take steps to protect it from unauthorised access, use or disclosure.
While we strive to protect your personal data, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your personal data.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Gibraltar is the Gibraltar Regulatory Authority. Their contact details are as follows:
Gibraltar Regulatory Authority,
2nd floor, Eurotowers 4, 1 Europort Road, Gibraltar.
(+350) 20074636/(+350) 20072166 email@example.com
How to contact us