TrueLayer is partnering with fino run GmbH (“fino”) to ensure that account information services or payment initiation services will continue to be provided once the Brexit transition period ends - please see here for more details.
These services will also be subject to fino’s terms and conditions, which you can find here.
fino run GmbH (Universitätsplatz 12, 34127 Kassel, Germany) is responsible for the provision of account information services (“AIS”) and payment initiation services (“PIS”). fino outsources certain parts of the provision of these services to TrueLayer Limited (“TrueLayer”), with company number 10278251, based at 1 Hardwick Street, London, EC1R 4RB. TrueLayer will be processing your data in connection with fino’s AIS and PIS services – further details of this are set out below.
You should read this notice, so that you know what we are doing with your personal data. Please also read our service terms and conditions if you are an End-User (the “End-User Terms and Conditions”, a copy of which can be found here, in addition to any other privacy notices and documentation that we give you that might apply to our use of your personal data in specific circumstances in the future.
|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 an End-User of our AIS Service||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 and Conditions.||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 Service||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 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 and Conditions.||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|
How we 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 Service, through a software tool provided by TrueLayer (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 and Conditions. 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 PIS Service, through a software tool provided by TrueLayer (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.
The Tools 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. The Tools 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.
Through email when you communicate with us.
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 End- User Terms and Conditions);
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 TrueLayer who will be acting on our behalf as a data processor in relation to that Personal Data, using your Personal Data for specified purposes in connection with our Services and in accordance with our instructions.
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 End-User Terms and Conditions and other agreements;
to protect the rights, property, or safety of fino, our customers, or others;
if we have to do so to fulfil our legal obligations;
in addition to TrueLayer, with other partners or suppliers who process Personal Data on our behalf (such as our professional advisers, payment schemes, 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 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, 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
we have entered into a standard contractual clause approved by the European Commission, which give Personal Data the same protection it has in the EEA, 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.
We guarantee your right to informational self-determination and the protection of your personal rights when using our services. You can at any time and free of charge claim the following rights against us upon request: Information about your stored data, correction or deletion of your stored data, restriction of the processing of your stored data, objection to the processing of your stored data, right of revocation of a once given consent to the collection, processing and use of your personal data with effect for the future as well as your right to data transferability. For this purpose, please use the contact details set out below. You have the right to appeal to a supervisory authority at any time if you are of the opinion that the processing of your personal data has taken place unlawfully.
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
fino run GmbH
Annex Account Information
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:
a. Account type (e.g. current, saving, investment, credit card);
b. Account name;
c. IBAN/Account number/Sort code/SWIFT;
Account balance information:
e. Current balance;
f. Available balance (credit cards);
j. Meta-data (arbitrary data that banks associate with a transaction e.g. category); and/or
Additional data which fino may collect in the future (as confirmed in writing from time to time):
k. Loans data when available;
l. Insurance data when available; and/or
m. Investments data when available;
n. Payment due date (credit cards) when available; and/or
o. Minimum payment due (credit cards) when available.