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?
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:
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).
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).
|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.
|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.
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).
|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
- 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?
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.
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: firstname.lastname@example.org.
Postal Address: 80 Clerkenwell Road, London, EC1M 5RJ.