BACKGROUND:
Ecospend understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who uses our services and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested. In this Privacy Policy, Ecospend will be referred to as “we”, “us”, or “our”. Additionally, there are references to “You” and “Your”. In these instances, “You” may be a visitor to our Site, a customer that is an individual, or an employee of a corporate customer (in each case, a “Customer”), or a user of our or our Customer’s products or services (“End User”).
1. Information About Us
Ecospend Technologies Limited, a limited company registered in England under company number 11114967. Registered address: 80 Clerkenwell Road, London, UK, EC1M 5RJ. We are certified by the Financial Conduct Authority, registration number 829713
2. What Does This Policy Cover?
This Privacy Policy applies only to your use of Ecospend products, services and websites and does not apply to your use of other apps or websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
3. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, the Data Protection Legislation) as any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
4. What Are Your Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 13.
b) The right to access the personal data we hold about you. Part 11 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 13 to find out more.
d) The right to be forgotten, i.e., the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 13 to find out more.
e) The right to restrict (i.e., prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 13. It is important that your personal data is kept accurate and up-to date. If any of the personal data we hold about you changes, please keep us informed if we have that data. Further information about your rights can also be obtained from the Information Commissioners Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioners Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 13.
5. What Data Do We Collect and How?
Depending upon your use of Ecospend, we may collect and hold some or all the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any special category or sensitive personal data and/or personal data relating to children and/or data relating to criminal convictions and/or offences.
| Type of Data | Purpose of Data | How Data is Collected | Legal Basis |
|---|---|---|---|
| Bank Account Transactions and Account summary information. |
Provide analysis and feedback for fraud detection, potential overspend, and appropriate financial product offers for End Users. |
Using Account Information Service Connections to your Bank (This service requires your explicit consent). |
Consent |
|
Sort Code and Account Number |
Gathered and stored for Refunds relating to payments made through our systems, account ownership verification, or as part of other financial products for End Users. |
Using Account Information Connections to your Bank (This service requires your explicit consent). |
Consent |
| Credit Card Statements | Provide analysis and feedback for fraud detection, potential overspend, and appropriate financial product offers for End Users. | Using Account Information Connections to your Bank (This service requires your explicit consent). | Consent |
|
Identification of End Users of our systems and communication with Customers. |
Via direct email contact with Ecospend for Customers or when registering End Users on our system. |
Contractual obligation | |
| Mobile Phone Numbers |
As part of multifactor authentication when accessing our systems for End Users & communication with Customers |
End User enters their number in our system for multifactor authentication or Customers share their number for communication. |
Contractual obligation |
| Names |
Identification of Customers and personalisation of our systems for End Users. |
Via direct email contact with Ecospend or Using Account Information Connections to your Bank (This service requires your explicit consent). |
Consent |
| IP Address and device information |
To provide analysis and feedback on devices accessing our systems for information security and general location information. |
Stored when a device interacts with our system through our APIs or website. | Contractual obligation |
6. How Do We Use Your Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data.
Our Lawful Basis:
We use banking information to provide you with the products and services we are offering. We also want to make you aware of the outcome of the actions you make on Ecospend, company updates and new products with your permission and/or where permitted by law. We may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
7. How Long Will We Keep Your Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- Type of Data: Identity Information including Name and Email address
- How Long We Keep It: Until you opt-out unless otherwise indicated as part of a contract or Terms of Use agreement.
- Type of Data: Technical information including IP address, operating system and browser type
- How Long We Keep It: Until you opt-out.
- Type of Data: Bank Account information, including account transactions.
- How Long We Keep It: Until you opt-out. (Note that the collection of new data automatically expires after, at most, 90 days unless you consent to extend that collection).
- Type of Data: Payment Transaction data.
- How Long We Keep It: For 5 years plus up to one week. We are required to keep this data by law for at least 5 years.
8. How and Where Do We Store or Transfer Your Personal Data?
We will only store or transfer your personal data within the UK. This means that it will be fully protected under GDPR Legislation.
9. Do We Share Your Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions: If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
Regardless of who you are, your personal data may be shared with companies that form part of our company group. This sharing of data is carried out on the basis that we have a legitimate interest in sharing data within our group for commercial, compliance and organisational reasons.
10. Can You Withhold Information?
You may access certain areas of Ecospend without providing any personal data at all. However, to use all features and functions available on Ecospend you may be required to submit or allow for the collection of certain data.
11. How Can You Access Your Personal Data?
If you want to know what personal data, we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a subject access request or SAR. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 13. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible. There is not normally any charge for a subject access request. If your request is manifestly unfounded or excessive (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within three weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
12. Cookie Policy
Ecospend does not use cookies for any of its Payment Initiation or Account Information services. However, we do use cookies on our website (www.ecospend.com). We use performance cookies, in particular Google Analytics cookies to collect information about how users use our website. We collect information such as the part of the webpage clicked, number of webpages visited, length of time of each session, and error messages (if any) with the purpose of improving our website and providing users with a better experience. For more information on Google Analytics, please click here. If you would like more information about the privacy policy of the Google Analytics’ service, please click here.
13. How Do You Contact Us?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [for the attention of the Data Protection Officer, Ecospend Technologies Limited:
Email address: hello@ecospend.com.
Postal Address: 80 Clerkenwell Road, London, EC1M 5RJ.
14. Changes to this Privacy Policy
We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be immediately posted on Ecospend, and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Ecospend following the alterations. We recommend that you check this page regularly to keep up to date.
This Privacy Policy was last updated on March 13, 2023.