1Purpose of this privacy policy
This privacy policy aims to inform you on how we collect and process your personal data through your use of our service and website.
This policy indicates how we comply with our obligations under the UK General Data Protection Regulations and all related UK national laws, regulations and secondary legislation, including the Data Protection Act 2018. Capitalised terms in this policy shall bear the meaning given to them in the legislation.
2Important information and who we are
Obrenza Ltd is our parent company. We are the controller of your personal data and Obrenza Ltd is the processor of your personal data. If you are using our services via our appointed agent, the agent is also a controller of your data and you should refer to their privacy policy in addition to this privacy policy.
We are regulated by the Financial Conduct Authority under registration numbers 962292 and 934392. Our authorisations and the identity of our agents can be checked on the Financial Services Register at www.fca.org.uk (opens in a new tab). We are registered with the Information Commissioner’s Office, in compliance with the Data Protection Act 2018, under registration ZA789844.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
In this policy the following words have the meanings given below:
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Legitimate Interest means conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of our contract with you or to take steps at your request before entering into such a contract.
If you have any questions about this privacy policy or our privacy practices, please contact our DPO by email to support@hopemacy.com in the first instance, or write to us at our registered office, details of which are on our website.
You have the right to make a complaint regarding our use of your data at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, which you can contact here: https://ico.org.uk/make-a-complaint/ (opens in a new tab). If you are not based in the United Kingdom you may also be able to raise a complaint with your local information commissioner or equivalent body.
We would, however, appreciate the chance to deal with your concerns first.
3Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. If we make any changes which are significant we will inform you if we are able to contact you.
It is important that the personal data we hold about you is accurate and current. We may repeat any checks we undertake in accordance with the requirements of our regulator.
Please keep us informed if your personal data changes during your relationship with us.
4Third-party links
Our website may include links to third-party websites. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
5The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username, and relationship to others.
- Contact Data includes billing address, residential address, email address and telephone number.
- Financial Data includes payment account details and details about your payments to us for the service.
- Marketing and Communications Data includes your preferences in receiving any marketing from us and your communication preferences.
- Transaction Data includes transaction and balance details for bank accounts which are accessed by our service.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, and the services used and information you have accessed.
6Failure to provide personal data
Where we need to collect personal data by law, or by a regulator, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to provide the service. In this case, we may have to cancel our service but we will notify you if this is the case at the time.
7Collection of personal data
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Financial and Transaction Data by registering with us or by corresponding with us by post, email or otherwise. This includes personal data you provide when you:
- register on our website;
- use our services; or
- give us feedback, make a complaint or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out in our service terms of use.
8Use of your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data to:
- comply with a legal obligation or requirements of a regulator;
- provide you with the service; or
- ensure the service is appropriate for you.
9Purposes for which we use your personal data
We will use your personal data in a variety of ways, and for a number of different purposes.
The purposes we use your data for will include enabling us to:
- check that the service is appropriate for you, register you as a new customer, and perform identity and other background checks as required by our regulator;
- process and deliver the service including managing payments, fees and charges;
- manage our relationship with you which will include:
- notifying you about changes to our terms or privacy policy; and
- asking you to leave a review or take a survey;
- administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
- deliver relevant website content to you;
- use data analytics to improve our website and services; and
- make suggestions and recommendations to you about any of our other services that may be of interest to you.
Our processing of your data for these purposes is necessary for:
- performance of a contract with you;
- compliance with our legal obligations and to satisfy the requirements of our regulators; and
- our legitimate interests, such as:
- running our business;
- recovering payment due to us;
- keeping our records updated;
- keeping our website updated and relevant;
- developing our business and informing our marketing strategy;
- studying how customers use our services;
- providing our administration and IT services and network security; and
- preventing fraud.
10Marketing
We may use your data to contact you with information regarding new services we provide that we think may be of interest to you. We do not provide your data to third parties for them to use for marketing.
We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which of our services and offers may be relevant for you. (We call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
11Cookies, Local Storage and Session Storage
We use cookies to preserve information as you navigate our website.
We use Google Analytics to collect data and use it to: study how people use our websites and our services so we can improve them; decide which of our products, services and offers may be relevant for you; and tailor the marketing you see on social media, apps and other websites.
12Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
13Disclosures of your personal data
We may share your personal data with third parties for the purposes of identity checking, credit checking, and anti-fraud purposes.
We may also share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
14Data transfers
When there is a legitimate interest, we may transfer your personal data within our group of companies. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. Your data is generally located in the United Kingdom, but we may transfer your personal information abroad. If your information is processed within the EEA it is protected by European data protection standards. If your information is transferred outside the EEA, we’ll make sure that suitable safeguards are in place before we transfer the information.
15Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
16Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data as stated in section 18.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
17Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below for examples of these rights. If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
18Examples of your legal rights
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.