Purpose of this Policy
This privacy policy (“Privacy Policy”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information or share it. This Privacy Policy also sets out your rights in respect of our processing of your personal information. This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer it and/or provide you with access to it.
This Privacy Policy is intended to assist you in making informed decisions when using the Sites and our Services. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Terms and Conditions.
This Privacy Policy only applies to the use of your personal information obtained by us. It does not apply to your personal information collected during your communications with third parties.
Who are we and what do we do?
The Sites and our Services are operated by 316 Startups Ltd, (“316”, ‘’316 Startups’’ “we”, “us” or “our”) who is the data controller. 316 Startups Ltd is an English company with registered company number: 12684989 and whose registered office is at Office 9, Dalton House, 60 Windsor Avenue, London, United Kingdom, SW19 2RR.
We provide various services related to Retail and banking which are explained more fully in the Sites and in our Terms and Conditions.
How to contact us?
If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by:
- sending an e-mail to [email protected]; or
- write to us at: Office 9, Dalton House, London, SW19 2RR.
What personal information do we collect and how do we use it?
Our primary goal in collecting personal information from you is to:
- Verify your identity;
- Help us improve our services and develop new and services;
- Carry out requests made by you on the Sites;
- Investigate or settle inquiries or disputes;
- Comply with applicable laws, court orders, other judicial process and the requirements of regulators;
- Enforce our agreements with you;
- Protect the rights, property and safety of us and third parties, including our other customers and users of the Site;
- Provide support for the provision of our Services;
- Use as otherwise required or permitted by law. In particular, we use your personal information for the following purposes:
Customer registration and account opening.
When you sign up to use our Site and service contact information will be requested in each case, together with details of other personal information that is required for registration or as may be required to verify your identity. This information is used in order to enable us to handle your registration application and determine your eligibility for an account.
Who do we share your personal information with for this purpose?
We may share your information with third parties such as credit reference agencies in order to verify your identity and details that you have provided and to conduct account opening checks (such as “Know Your Customer” checks). We may share your information with fraud prevention organisations which will use it for identity verification and prevention of fraud and money-laundering. Suspicious activity may be reported to law enforcement. If fraud is detected, the relevant individual or entity could be refused finance, employment, contract, tenancy or certain services.
What is our legal basis?
It is for the purposes of fulfilling our obligations under a contract to use your personal information in such a way to ensure that we verify your identity before approving you for an account and for our legitimate interest in complying with the law and preventing and detecting money laundering, fraud and other crime. We also have a legal obligation to report certain suspicious activity under anti-money laundering legislation.
Fulfilment of services
We collect and maintain personal information that you voluntarily submit to us during the registration process and your use of the Sites and/or our Services. We use the contact and payment details you have provided to us so that we can fulfil the supply of services via our Sites.
Who do we share your personal information with for this purpose?
We will share your personal information with the following categories of third parties:
- Credit card companies and other payment providers – to verify card payments and invoices, service card processing, agency banking services, faster payment services and to check accounts are correct and not subject to embargo or sanction (or as may be required by law);
- Payees authorised by you – to submit payments and invoices;
- Web hosting, optimisation and management companies – who assist us with the hosting, operation, optimisation and maintenance of our Sites, the administration of accounts and functionality of our Sites. Including Google Cloud Platform, please see their Privacy Policy at https://policies.google.com/privacy;
What is our legal basis?
It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you
Your feedback about our services
From time to we will contact you to invite you to provide feedback about our services in the form of online, postal or telephone surveys. We use this information to help us improve the quality of service provided and upgrade the Sites. We also use your feedback to monitor the quality of our services and to assist with future service or Site development.
Who do we share your personal information with for these purposes?
We may use a third-party service provider to assist us with customer surveys and feedback requests.
What is our legal basis?
It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.
Customer insight and analysis.
We analyse your contact details and other details you provide to us with other personal information that we observe about you from your interactions and use of our Sites, our email communications to you and/or with our services.
Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Sites, or from your mobile. This includes the following:
- technical information including: an IP address to monitor Sites traffic and volume, address used to connect your computer to the Internet login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information and type of mobile device (where applicable), a unique device identifier (e.g. IMEI number) and mobile network information;
- transaction information including date, time, amount, currencies used, exchange rate, beneficiary details, IP address of sender and receiver, sender`s and receiver`s name and registration information, messages sent or received with the payment, device information used to facilitate the payment and the payment instrument used;
- information stored on your device, including if you allow access to contact information from your address book, login information, photos, videos or other digital content, check ins (content information). The Site will periodically recollect this information in order to stay up-to-date;
- details of your use of our App or your visits to our Site including transaction details relating to your use of our services, including who you have sent money or electronic money to, foreign exchange transactions you have entered into, the time, date and location of the place the transaction was entered into;
- a session ID to track usage statistics on our Sites;
- information regarding your experiences with our services and your contact preferences; and
- to store bank account details.
Our web pages and e-mails contain “cookies” “web beacons” or “pixel tags” (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag. Where we have your consent to do so, we will also use your location data for customer insight purposes. By using this information, we are able to measure the effectiveness of our services and how visitors use our Sites. This allows us to learn what pages are most useful and how we can improve the service. We may also use this information for marketing purposes (see the marketing section below for further details).
Who do we share your personal information with for these purposes?
We share your personal information with various third party service providers to assist us with customer insight analytics. These providers include Google Analytics; Google AdWords/Adjust and Google Cloud.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to process it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. We process some of your personal data for our legitimate business interest in understanding our customers and developing our services.
Marketing communications
We carry out the following marketing activities using your personal information:
Email or text message marketing
We use information that we observe about you from your interactions with our Sites and/or with our services, our email/text communications to you and/or your email address or telephone number, to send you marketing communications by email and/or text message, where you have consented to receive such marketing communications or where we may rely on another lawful basis to do so.
Who do we share your personal information with for these purposes?
We may share your personal information with a variety of third party email or text message marketing providers (including Mailchimp) who assist us in delivering our email marketing campaigns, newsletters and other mass emails or text messages (for example, account updates) to you.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes. We will only send you marketing communications via email or text message where you have consented to receive such marketing communications or where we may rely on another lawful right to do so.
Telephone marketing
We use information that we observe about you from your interactions with our Sites and/or with our services to contact you by telephone for marketing purposes, where you have consented to receive such marketing communications or where we may rely on another lawful basis to do so.
Who do we share your personal information with for these purposes?
We may share your personal information with a third-party telephone marketing providers who assist us in delivering our telephone marketing campaigns (for example, where an account opening procedure has not been completed) to you. Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes. We will only contact you via telephone for the purposes of marketing communication where you have consented to receive such communications or where we may rely on another lawful right to do so
Social Media Marketing
Where you have consented to receive such marketing communications in the tick box on sign-up, we use information that we observe about you from your interactions with our Sites and/or with our services, our email/text communications to you and/or your email address or telephone number, to share with third-party social media platforms to send you targeted marketing communications.
Who do we share your personal information with for these purposes?
We may share your personal information with a variety of third-party social media platforms (including, but not limited to, Facebook, Instagram and WhatsApp) who deliver targeted marketing campaigns.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, we will only share your personal data with such third party social media platforms where you have consented to us sharing of your data or where we may rely on another lawful right to do so.
Business administration and legal compliance.
We use your personal information for the following business administration and legal compliance purposes:
- to comply with our legal and regulatory obligations;
- to enforce our legal rights;
- to protect rights of third parties; and
- in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
Who do we share your personal information with for these purposes?
We may share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.
What is our legal basis?
Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.
Job applicants
We will use your contact details, copies of your job application, curriculum vitae and covering letter, as well as any references provided, for the purposes of processing your application and for general recruitment and selection purposes.
Who do we share your personal information with for these purposes?
We will not share the data of job applicants with any third parties and will only use the details provided for our internal business purposes. If you are a successful applicant, we will share your details with HMRC, and other authorities for the purposes of your employment.
What is our legal basis?
It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above. Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.
How do we obtain your consent?
Where our use of your personal information requires your consent, you can provide such consent:
- At the time we collect your personal information following the instructions provided or
- By informing us by e-mail or post using the contact details set out in this Privacy Policy.
Our use of cookies and similar technologies
Our Sites use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.
Storage and Sharing of Personal Information and International Data Exports
We store some personal data in data centres in the United Kingdom. In order to provide you with some of the services via the Sites, we may need to share your personal data with third party service providers. This will involve transferring your data outside the European Economic Area (“EEA”). Whenever we transfer your personal data outside the EEA, we ensure that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Where we use service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (including “model clauses”).
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield framework which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your data out of the EEA.
Third Party Links and Services
Our Sites may contain links to third party websites and services. When you use a link to go from our Sites to another website or you request a service from a third party, this Privacy Policy no longer applies.
Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.
We do not monitor, control, or endorse the privacy practices of any third parties.
This Privacy Policy applies solely to personal information collected by us through our Service and does not apply to these third party websites and third party service providers.
How long do we keep your personal information for?
We keep your personal information for a period of 6 years from the date of our last interaction with you or such longer period as is required by law or regulation.
If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it shortly afterwards.
Confidentiality and security of your personal information
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
- Unauthorised access;
- Improper use or disclosure
- Unauthorised modification and
- Unlawful destruction or accidental loss.
All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Sites.
How to access your information and your other rights?
You have the following rights in relation to the personal information we hold about you:
Your right of access
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information. If you require additional copies, we may need to charge a reasonable fee.
Your right to rectification.
If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal information with others, we’ll let them know about the rectification where possible. Where it is possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to erasure.
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure (where possible). Where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to restrict processing.
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. Where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to data portability.
You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
Your right to object.
You can ask us to stop processing your personal information, and we will do so, if we are:
- Relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
- Processing your personal information for direct marketing.
- Your rights in relation to automated decision-making and profiling.
relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or processing your personal information for direct marketing. Your rights in relation to automated decision-making and profiling. You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
Your right to withdraw consent If we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
Changes to this Privacy Policy
We may make changes to this Privacy Policy from time to time.
To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to understand how we use your personal information.
