Welcome to Zoopay Limited's privacy notice.
Zoopay Limited respects your privacy and is committed to protecting your personal data. This privacy notice will let you know how we look after your personal data when you visit our website and when you use our services and tells you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
This privacy notice aims to give you information on how Zoopay Limited collects and processes personal data we collect from you or that you provide to us or that we obtain from third parties. This personal data may be obtained through the provision of our services in accordance with our terms and conditions, through our clients and potential client’s use of the website (https://www.zoopay.com) or through other direct communications between us and our clients or potential clients.
The website and our services 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 our terms and conditions (a copy of which can be obtained upon request) and 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. This privacy notice supplements the other notices and is not intended to override them.
Zoopay Limited is the controller and responsible for your personal data (collectively referred to as "Zoopay Limited", "we", "us" or "our" in this privacy notice).
We have appointed a data protection lead who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data protection lead using the details set out below.
Our full details are:
| Full name of legal entity: | Zoopay Limited |
| Name or title of data protection lead | Louise Backhouse |
| Email address: | privacy@zoopay.com |
| Postal address: | 35 Hobbs Court, 2 Jacob Street, London SE1 2BG |
| Telephone number: | +44(0) 20 7740 0001 |
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO) which is the United Kingdom’s 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 using the details set out in the table above in the first instance.
This version was last updated on 1 October 2019. Prior versions can be obtained by contacting us.
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.
This website 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 are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
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:
We do not collect any special categories of personal data about you (this 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 and biometric data). Nor do we collect any information about criminal convictions and offences.
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, execute a payment on your behalf). In this case, we may have to terminate the contract you have with us but we will notify you if this is the case at the time.
(c) Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Please see paragraph 3.2 (purposes for which we will use your personal data) to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the details set out in paragraph 1.3.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our Legitimate Interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the details set out in paragraph 1.3 if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of Legitimate Interest |
|---|---|---|
| To register you or your employer / company as a new client | (a) Identity Data (b) Contact Data |
Performance of a contract with your employer / company |
| To process and deliver the services including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity Data (b) Contact Data (c) Financial Data (d) Transaction Data |
(a) Performance of a contract with you (b) Necessary for our Legitimate Interests (to recover debts due to us) |
| To execute payments on your behalf (send money to beneficiaries) and sell currency to fulfil contracts entered into between us and a client | (a) Identity Data (b) Contact Data (c) Financial Data (d) Transaction Data |
(a) Performance of a contract with you. (b) Necessary for our Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (c) Necessary to comply with a legal obligation including Regulation (EU) 2015/847 on information accompanying transfers of funds (commonly referred to as the revised wire transfer regulation). |
| To manage our relationship with you which will include: (a) notifying you about changes to our terms and conditions or privacy policy (b) asking you to leave a review or take a survey |
(a) Identity Data (b) Contact Data (c) Usage Data (d) Marketing and Communications Data |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our Legitimate Interests (to keep our records updated and to study how clients use our services) |
| To enable you to partake in a prize draw, competition or complete a survey. | (a) Identity Data (b) Contact Data (c) Usage Data (d) Marketing and Communications Data |
(a) Performance of a contract with you (b) Necessary for our Legitimate Interests (to study how clients use our services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity Data (b) Contact Data (c) Usage Data |
(a) Necessary for our Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity Data (b) Contact Data (c) Usage Data (d) Marketing and Communications Data |
Necessary for our Legitimate Interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, client relationships and experiences | (a) Usage Data | Necessary for our Legitimate Interests (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity Data (b) Contact Data (c) Usage Data (d) Marketing & Communications Data |
Necessary for our Legitimate Interests (to develop our products/services and grow our business) |
| To send you a seasonal card or gift. | (a) Identity Data (b) Contact Data |
Necessary for our Legitimate Interests (to develop our products/services and grow our business) |
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can ask us to stop sending you marketing messages at any time.
We will get your express opt-in consent before we share your personal data with any company outside the Zoopay Limited company for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://www.zoopay.com/cookies-policy.
We will only use your personal data for the purposes for which we collected or received 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 using the details set out in paragraph 1.3.
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.
4.1 We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 3.2 (purposes for which we will use your personal data) above.
4.2 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.
5.1 Some of our External Third Parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
5.2 Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
5.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
6.1 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.
6.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and the Financial Conduct Authority of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
By law we have to keep basic information (including Identity Data, Contact Data, Financial Data and Transaction Data) about our clients, their directors, partners and ultimate beneficial owners and beneficiaries for five years after they cease being clients for the purpose of compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
In some circumstances you can ask us to delete your data: see paragraph 10(c) below for further information.
In some circumstances we may 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.
8.1 Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
Paragraph 10 provides more detail about these rights.
If you wish to exercise any of the rights set out above, please contact us using the details set out in paragraph 1.3.
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.
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.
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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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 a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External Third Parties means:
You have the right to: