Dated: 10 June 2020
TrueLayer Limited (“TrueLayer”) (with company number 10278251) is based at 1 Hardwick Street, London, EC1R 4RB. For the purposes of data protection laws, TrueLayer is registered as a data controller with the Information Commissioner's Office (“ICO”) under number ZA207054.
|The personal data we collect about you and how we use it||What type of personal data are we using?||Purpose of Processing||What lawful basis do we rely on to use your personal data?|
|If you are a TrueLayer Customer||Your name, date of birth, address, email, number, username, client ID and login data if you register as a user.||To deliver our Services to you||To deliver a contractual service to you as our Customer|
|Your name, date of birth, address, email, number and photo identification. Such personal data may include any criminal background information.||To conduct any due diligence that we are required to do in order for you to receive our Services||To comply with our legal obligations (including regulatory requirements that we are under)|
|Your name, email address, username and login data you supply to us if you register as a user.||To provide you with updates on our activities, services and products; to record your marketing preferences and any feedback or responses for the purposes of improving our Services||With your consent|
|If you are an End-User of our AIS Tool||Any Personal Data that is contained in the account information that you have given us your explicit consent to access in accordance with the End-User Terms of Service.||To deliver our Services to you and/or your Provider and to improve our Services and AIS Tool||It is necessary for our legitimate interest in ensuring that we can provide you and your Provider with the Services and to continuously improve our Services|
|If you are an End-User of our PIS Tool||Any Personal Data that you give to us, for example your name, email address, username, login data and any payment reference that you supply.||To deliver our Services to you and/or your Provider and to improve our Services and PIS Tool||It is necessary for our legitimate interest in ensuring that we can provide you and your Provider with the Services and to allow us to continuously improve our Services|
|If you are an End-User of any of our products||Your name, address and any photo identification. Such personal data may include any criminal background information.||To conduct any due diligence that we are required to do in order for you to receive our Services||To comply with our legal obligations (including regulatory requirements that we are under)|
|Your name, email address, username and login data you supply to us if you register as a user via any TrueLayer portal or console.||To deliver our Services to you and to give you access to information we hold about you||With your consent|
|Your username, email and account information, supplied to us by your Provider||To debug any issues you have when you access our Services and to improve our automated processes for retrieving data.||It is necessary for our legitimate interest in ensuring that we can provide you and your Provider with the Services and to allow us to continuously improve our Services|
|Any Personal Data that is contained in the account information that you have given us your explicit consent to access in accordance with the End-User Terms of Service.||To anonymise or pseudonymise the Personal Data in order for it to be used to improve our Services, to be part of a market study or analytics by us or a third party.||It is necessary for our legitimate interest in ensuring that we are able to continuously improve and develop our Services and enhance the experience of you and your Provider|
|If you are a visitor to our Site||Your name, email address and any other Personal Data you supply to us (such as any feedback)||To provide you with updates on our activities, services and products; to record your marketing preferences and any feedback or responses for the purposes of improving our Services.||With your consent|
|Any Personal Data we collect as part of your cookies setting, namely online identifiers (such as your cookie identifier, IP address, browser type and version, time zone settings and location)||To allow us to run the operation of our website and ensure that our provision of Services through our website runs as smoothly as possible||With your consent|
How we collect your Personal Data
These are the ways in which we may collect your personal data:
If you are an End-User
If you are an End-User, the provider of the application through which you access our Services (your “Provider”) will direct you to use our Services which will include the following:
- If you are an End-User using our AIS product, through a software tool (the “AIS Tool”) which you can use to transmit information (including Personal Data) relating to payment accounts (“Account Information”) that you hold with Account Servicing Payment Service Providers (i.e. any payment service provider, such as a bank or a credit card issuer that maintains an online payment account on your behalf) (“ASPSPs”) to you and your Provider, in accordance with the End-User Terms of Service. When you use the AIS Tool, we will collect and process the Personal Data contained in the Account Information retrieved from your ASPSP. We may also collect and process Personal Data provided to us by your Provider.
- If you are an End-User using our payment initiation services (“PIS”) product, through a software tool (the “PIS Tool”) which you can use to consent to and authorise a payment as specified by your Provider; this may require that your ASPSP sends us your bank account details. When you use the PIS Tool, we will collect and process the Personal Data that you provide to us (e.g. any Personal Data you include in the payment reference) in order for us to provide the PIS Tool. We may also collect and process Personal Data contained in your bank or payment account details shared with us by your ASPSP. Our Tool may merge or aggregate Account Information retrieved from a particular ASPSP with Account Information retrieved from other ASPSPs where you have consented to us accessing and transmitting such information. Our Tool may use your Account Information for profiling purposes or store your Account Information if this forms part of the Services we are delivering to your Provider, for example, if it is necessary for the functioning of your Provider’s app.
- If you have registered to use the TrueLayer End-User Portal or console we will collect and process your name, email, username that you provide to us in order to access the End-User Portal and the information about your use of the AIS Tool.
- Through email when you communicate with us.
- When you visit our Site.
- When you provide us with your marketing preferences.
If you are a Customer
If you are a Customer, we may collect your personal data from the following sources:
- through our Site when you register as a Customer or use our Services;
- through email when you communicate with us;
- through information that you provide to us, and from third party sources such as Companies House and LexisNexis for due diligence and onboarding purposes;
- when you visit our Site; and/or
- when you provide us with your marketing preferences.
If you are a visitor to our Site
If you are a visitor to our Site, we may collect your personal data from the following sources:
- through cookies that we have set on our Site; and/or
- when you provide us with your marketing preferences through the Site.
How long we keep your Personal Data
We will not keep your Personal Data for any longer than we think is necessary.
When deciding how long to keep your Personal Data, we consider factors including:
- our contractual obligations and rights in relation to the Personal Data involved (including the Terms of Service);
- legal obligation(s) under applicable law to retain data for a certain period of time;
- whether we relied on your consent to use the Personal Data, but you have since withdrawn your consent;
- statute of limitations under applicable law(s);
- our legitimate interests where we have carried out balancing tests;
- fraud and risk management;
- (potential) disputes; and
- guidelines issued by relevant data protection authorities.
Sharing of your Personal Data
By using our Services as an End-User, we share your Personal Data with your Provider who will become responsible for it as a data controller.
If you are an End-User or a Customer, we may also have to share your Personal Data:
- if we reasonably consider that we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation;
- we need to enforce or apply our Terms of Service and other agreements;
- to protect the rights, property, or safety of TrueLayer, our customers, or others;
- if we have to do so to fulfil our legal obligations;
- with partners or suppliers who process Personal Data on our behalf (such as our professional advisers, auditors or IT suppliers) - we take the security and protection of your Personal Data seriously and only allow such suppliers to use your Personal Data for specified purposes and in accordance with our instructions;
- to another company in our group, if this is necessary to ensure continuity in the provision of Services to you (including in relation to the UK’s withdrawal from the European Union), or to reflect any business reorganisation or expansion that we may engage in from time to time.
International transfers of your Personal Data
However, whenever we do transfer your Personal Data out of the EEA or the UK, we will only do so if:
- it is to a country that has been deemed to provide an adequate level of protection for Personal Data by the European Commission (or the UK once the Brexit transition period is over); or
- we have entered into a standard contractual clause approved by the European Commission or the UK once the Brexit transition period is over, which give Personal Data the same protection it has in the EEA or the UK, with the recipient of the data.
Please contact us if you want further information on how we ensure adequate protection for any Personal Data transferred out of the EEA or the UK.
Right of access
You have the right to ask us to provide any personal data we have collected about you, to you. Should you wish to do so, please email us at email@example.com to make a subject access request detailing:
- your name,
- your address,
- the details of your Provider, and
- the period of data you would like access to.
Object to processing, including Direct Marketing
You may have the right in certain circumstances to ask us to stop processing your Personal Data. You always have the right to ask us to stop processing your Personal Data for direct marketing purposes, at any time.
Request to restrict processing
You may, in certain circumstances, have the right to ask us to restrict the processing of your data or to suppress your data.
Request correction or erasure
If we hold any of your Personal Data, you have the right to ask us to correct any inaccurate data we hold about you or delete the data where there is no legitimate reason for us to continue to process it. We may not always be able to delete or correct on request if it is not within our control (such as with Account Information, in which case we will forward your request to the ASPSP) or if we are subject to legal requirements to keep the data.
If any of our Services require your consent to process your Personal Data and after you provided your consent, you change your mind, you may withdraw your consent by contacting us as set out in the contact information below.
Request to transfer
Where we collect and store your Personal Data to perform a contract that we have with a Provider, you may request the transfer of your personal data to a third party, which we will provide to you in a structured, commonly used and machine-readable format.
Questions and Contact Information
If you would like to access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information about how we process your Personal Data, you can contact us at firstname.lastname@example.org or by mail at:
- Data Protection Officer,
- 1 Hardwick Street,
- London EC1R 4RB.
Making a complaint to a supervisory authority
Should you be dissatisfied with the service we provide, you have the right to file a formal complaint to the Information Commissioner's Office at www.ico.org.uk, or to the relevant data protection supervisory authority in your country of residence.
Subject to such Account Information being returned by the relevant ASPSP, Account Information shall include, but not be limited to, the following financial information and Personal Data:
- Personal details: name, date of birth, full address(es), email address, phone number, gender;
- Bank account information:
- Account type (e.g. current, saving, investment, credit card);
- Account name;
- IBAN/Account number/Sort code/SWIFT;
- Account balance information:
- Current balance;
- Available balance (credit cards);
- Meta-data (arbitrary data that banks associate with a transaction e.g. category); and/or
- Additional data which TrueLayer may collect in the future (as confirmed in writing from time to time):
- Loans data when available;
- Insurance data when available; and/or
- Investments data when available;
- Payment due date (credit cards) when available; and/or
- Minimum payment due (credit cards) when available.