This is how Pockit uses your personal information.

Updated March 2022.

1.    About us

Pockit Limited is registered as a data controller with the Information Commissioner under reference: Z265459X.

If you have any questions, or want more details about how we use your personal information, just email Pockit’s data protection officer at [email protected].

2.    Information we use

Personal information that we use:

·         Your contact details: data that allows us to contact you, including name, email address, phone number, residential address

·         Your date of birth

·         Your Nationality 

·         Your Residential and Employment Status 

·         Banking transactional information: information about how you have used and currently use the Pockit product, including transactional history, statements, and product holdings

·         How you interact with the Pockit product: information about the devices and channels you use to interact with the Pockit website / app

·         Location: information identifying computers/devices used to connect to the internet, including your Internet Protocol (IP) address

·         Marketing: information which records your response to marketing campaigns, including opt-in / opt-out election

·         Customer care: records of any exchanges with our Customer Care team via phone, email and social media (Twitter and Facebook), including customer complaints

·         Your privacy: information which records any exercise of your rights under privacy regulations

3.    Protection of your data by law

 Your privacy is protected by law. This section provides further detail about this.

 

According to Data Protection laws, we are allowed to use personal information only if we have an acceptable reason to do so.

The law says we must have at least one or more of the following reasons:

·         To fulfil a contract we have with you, or

·         When it is our legal duty, or

·         When it is in our legitimate interest, or

·         When we have your consent to.

·         When we have a business or commercial reason to use your information, this is classed as a legitimate interest, even then, it must right and best for you and must not be unfairly used.

We are committed to keeping your data confidential and secure. We will not sell any of your personal data.

4.    Why we collect your personal information

Collect your personal information because of our contract

Personal data used	Why?
·         Contact details ·         Date of birth ·         Banking transactional information	To deliver our product and services, including exchanging your data with third parties

 

Collect your personal information because of a legal obligation

Personal data used	Why?
·         All the personal information listed in section 2	To investigate suspicious activity on your account, including fraud, money laundering and other financial crime
·         All the personal information listed in section 2	To respond to complaints and/or legal claims

 

Collect your personal information because of legitimate interest

Personal data used	Why?
·         All the personal information listed in section 2	To develop new products and services
·         All the personal information listed in section 2	To market new and existing products that may be of interest to you if you have opted into receiving marketing emails from Pockit

Collect your personal information because you have opted in

Personal data used	Why?
·         All the personal information listed in section 2	To market new and existing products that may be of interest to you

 

We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

5.    Where we collect your personal information

We may collect personal information about you from these sources:

Data you give to us:

·         When you apply for our products and services:

·         When you talk to us on the phone

·         When you use our website or app

·         When you enter a competition or promotion sponsored by us or third parties

·         When you report any problem with our website

·         In emails and letters

·         In customer surveys

Data we collect for use of our services including the amount, frequency, type, location, origin and recipients:

·         Payment and transaction data

·         Profile data

·         Usage data

This includes when you connect to internet banking. We gather this data from devices you use to connect to those services, such as computers and mobile phones, using cookies.

 

Data from third parties we work with:

·         Card schemes

·         Credit reference agencies

·         Fraud prevention agencies

·         Government and law enforcement agencies

6.    Who we may share your personal information with

 We may be legally obligated to share your information with other organisations or government agencies, these include Agents and Advisers who we use to help run your accounts and services, collect what you owe, and explore new ways of doing business:

Who	Examples
Government bodies	HM Revenue & Customs, regulators, including the FCA, and other authorities
Fraud prevention agencies	ComplyAdvantage – to check financial risk Onfido – to verify your identity Au10tix – to verify your identify
Credit reference agencies	Companies like Experian, Equifax, Callcredit to help feed into your credit reference
Companies that support our IT infrastructure	Zendesk – to assist with Customer Care Braze – to send you emails Sengrid – to send you emails
Advertising partners	Search engines e.g., Google, Bing Social media e.g., Facebook, Twitter
Third parties helping us provide your product or service	FCA-regulated companies that help us provide the product / services, our issuer and various third-parties to support our additional lending / credit products E.g Payrnet Ltd, Our payments processor  Non-regulated third party companies that help us to provide additional products e.g Switchcraft
Police and law enforcement	Police, Information Commissioner's Office

 

7.    Transferring your personal data internationally

The data we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

When we do transfer data outside of the EEA, we make sure that your data is protected and the country where the data is transferred has equivalent data protection regulation and requirements in place based on guidance provided by the European Commission. 

We also make sure that contracts with organisations Pockit chooses to partner with, include standard working approved by the European Commission to provide equivalent protection to your data.

8.    Direct Marketing: Email, SMS & Push Notifications

When you sign up for your Pockit account we'll ask if you'd like to be contacted about new Pockit features, offers and tips about your money. If you tell us you're happy to be contacted, we'll send you information about things you might be interested in via email, SMS or push notifications.

You'll only get push notifications if you have the Pockit app and have enabled notifications in your phone settings. If you wish to stop receiving push notifications just turn this off in your phone settings.

How to withdraw your consent

You can unsubscribe from our marketing by clicking the unsubscribe link in any marketing emails we send to you. You can also change your preferences within your online account, or you can let us know that you'd like to unsubscribe by emailing us at [email protected].

 

9.    Advertising on other websites and apps

When you visit our website, we may collect information about your computer, including your IP address, operating system and browser type, for system administration and to report aggregate information to inform our advertising. This is statistical data about or your browsing actions and patterns and does not identify you individually.

For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our website and to deliver a better and more personalised service. They enable us:

·         To store information about your preferences, and so allow us to customise our Site according to your individual interests.

·         To make it easier for you to log on and use the Site during future visits.

You may refuse to accept cookies by activating the setting on your internet browser which allows you to refuse the setting of cookies. Please refer to your internet browser's help section for specific instructions. However, if you select this setting you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our Site.

For more information about cookies (including how to set your browser to reject cookies) please visit the website set up by the Interactive Advertising Bureau (Europe) at www.allaboutcookies.org

10.  How long we keep your personal data for

We will keep your personal data for 6 years after you stop being a Pockit customer in line with regulatory requirements. We are obligated under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692) to retain personal data about you and your transactions with us for up to 5 years. As an appointed agency of an FCA regulated e-money institution, you can redeem your e-money up to 6 years after the termination of your account.

11.  Your rights to your personal data

Your rights to object to restrict our use of your personal data

You have the right to ask for your personal data to be restricted if you think:

·         It is not correct.

·         It you think it has been used unlawfully, but you do not it deleted.

·         It is no longer relevant, but you want us to keep it for a legal claim.

·         You are waiting for us to confirm if we are allowed to keep on using it but you have already asked us to stop using your data.

Your rights to object to use processing your personal data

Data collection is optional, however, if you decide not to share required personal data with us, it may delay or stop us from meeting our obligations. This can also mean that we cannot perform services needed to run your accounts. We are required to collect certain personal information by law, and/or under the terms of a contract we have with you. By not sharing the required data with us may mean that we may cancel a product or service you have with us.

If you want us to stop using your personal data for any of the above cases, please contact us at [email protected].

Your rights to obtain a copy of your personal data

You can access the personal information we hold by emailing [email protected].

12.  Use of Cookies

You can read more about how we use cookies and how you can change your cookie settings on our Cookies Page.

 

13.  Contacting us

If you're unhappy with why or how we've used your personal data, you can contact us through email at [email protected].

You also have the right to complain to the Information Commissioner’s Office. If you are unhappy with our response, you can contact the office or the Information Commissioner at:

Email: [email protected]

Tel: 0303 123 1113

Website: https://ico.org.uk/global/contact-us/

 

14. Consequences of collecting and sharing your data with fraud prevention agencies

The personal data we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further information can be found at CIFAS website: https://www.cifas.org.uk/fpn .