Introduction
Welcome to Currensea Limited's privacy notice.
Currensea respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website or app and tell you about your privacy rights and how the law protects you.
Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Currensea collects and processes your personal data through your use of our website or mobile app, including any data you may provide when you sign up.
Our website and mobile app are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data.
Controller
Currensea is the controller and responsible for your personal data (collectively referred to as “Currensea”, “we”, “us” or “our” in this privacy notice).
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our website and mobile app may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and applications and are not responsible for their privacy statements. When you leave our website or mobile app, we encourage you to read the privacy notice of every website or application you visit.
The 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 name or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes address, email address, telephone numbers and place and type of business.
We also collect certain Special Categories of Personal Data about you, including things like:
- Biometric Data
- Financial Data including:
- Details about your transactions and the accounts you use;
- Details of balances and direct debits in your linked bank accounts;
- Information on how you use your phone (e.g. mobile network you use, your IP address, IMEI number, operating system, IMSI number and some settings on your phone;
- Information from social networks or online accounts that you share with us.
We do not collect other Special Categories of Personal Data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic data. Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, 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 perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
How your personal data is collected
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
- Automated technologies or interactions. As you interact with our service, we may automatically collect Technical Data about your equipment, usage actions and patterns. We collect this personal data by using cookies and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties such as Google Analytics.
- Open Banking. When you choose to connect an account via open banking, we collect personal data including your Financial Data from your account provider (e.g. if you connect your bank account, we will collect personal data including Financial Data from your bank)
How we use your personal data
To meet our legal obligations. We will only use your personal data when the law allows us to and to provide our services. We use it to:
- Help us maintain the account.
- Track, analyse and improve the services we give you and other customers.
- Search your record at immigration and fraud prevention agencies.
- Prevent illegal activities like money laundering, tax evasion and fraud.
- Manage our credit risk.
To exercise our legitimate interests. This is when we use data for a reason which is in your and/or our interest, and which doesn't involve overriding your privacy rights. We use it to:
- Market products and services.
- Search your record at credit reference agencies when you sign up (this is a 'soft search' and shouldn't impact your credit score).
- Process to remove all identifiable references to you as an individual or data subject (called ‘anonymised data’) for service analytics purposes.
- Market and communicate our products and services and those of affiliated partners where we think these will be of interest to you by email (with your permission only). If you are a resident of California click here for more information.
- You can unsubscribe from receiving marketing emails by getting in touch at help@currensea.com.
Who we share it with
We may share your personal information with:
- Anyone who works for us when they need it to do their job.
- Any organisation which supports any of our services you use, when they need it to offer those services, including card producers and networks, analytical, Know Your Customer (KYC) and cyber security service providers.
- Companies that do advertising for us (but we won’t share identifiable personal data with third parties for their own direct marketing unless you give us permission, and you can opt out any time).
- Third party companies we employ to collect outstanding payments on our behalf.
- Certain authorities that detect and prevent terrorism.
- TotallyMoney Limited, where you have a TotallyMoney debit card.
- Anyone who you give us express permission to share it with.
We’ll also share it to comply with the law; to enforce our Terms and Conditons or other agreements; or to protect the rights, property or safety of us, our customers or others.
Credit reference agencies – CRA’s
In order to process your application, we will perform credit and identity checks on you with one or more Credit Reference Agencies (CRAs). These are soft searches and will not leave a footprint on your credit file. We may also carry out further periodic searches at CRA’s to allow us to manage your account with us.
To do this, we will supply your personal information to CRAs. This will include your name, date of birth and residential address. It may also include additional information such as previous residential addresses and other information you provide as part of your application.
The CRAs will match this information to the records they hold about you, and provide in return, both public information (including the electoral register) and shared credit information in relation to your financial situation and financial history.
We will use this information to:
- Assess whether the debit card you are applying for is suitable for you
- Verify the accuracy of the data you have provided to us;
- Prevent criminal activity, e.g fraud and money laundering;
- Manage your account(s);
- Trace and recover any debts
If you use your Currensea card and we are unable to collect your direct debit in full or on time, we may record the outstanding debt with the CRA’s. This information may be supplied to other organisations by CRA’s.
If you have signed up to the BuildMyCreditScore A (formerly TotallyMoney Debit Card) service you agree that we will share your Identity Data, Contact Data and Financial Data (see above) with the CRAs on an ongoing basis in order to help build your credit score.
The identities of the CRA’s, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRA’s are explained in more detail at:
How long we keep it
We keep your data as long as you’re using Currensea, and for 5 years after that to comply with the law. In some circumstances, like cases of anti-money laundering or fraud, we may keep data longer if we need to and/or the law says we have to.
International transfers
We might transfer and store the data we collect from you somewhere outside the UK or the European Economic Area (EEA). People who work for us or our suppliers outside the UK or the EEA might also process your data. We will only share data with organisations and countries that:
- Have adequate data protection; or
- We’ve agreed standard data protection clauses with.
Data 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.
Your legal rights
Under certain circumstances, you have rights under the data protection laws in relation to your personal data. You may have the following rights:
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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Exercising your rights:
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 may 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 may 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.
Cookies
Our website and mobile app uses cookies to distinguish you from other users of our services. This helps us to provide you with a good experience when you use our service and also allows us to improve it.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or smartphone. Cookies contain information that is transferred to your computer or smartphone.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website and app.
- Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website and app when they are using it. This helps us to improve the way our website and app works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website or app. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website and app, the pages you have visited and the links you have followed. We may also share this information with third parties for this purpose.
Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. We use third party cookies which are likely to be analytical cookies or performance cookies or targeting cookies provided by Google.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.