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Privacy Policy

Date of issue: 08/05/2018

Personal information

We carefully safeguard the information we hold about you, including your personal data (the “Personal Information") and, in particular, we are responsible for the security of sensitive cardholder data we process and transmit on your behalf, such as PAN, expiration date, and CVV. DiPocket UK is the data controller of your Personal Information that you provide to us. If you wish to contact your data controller in all matters related to the processing of your Personal Information, please contact our Data Protection Officer at [email protected]

Your Personal Information will be processed for the purposes described in this Agreement (including to provide you with the services offered by DiPocket) and for the purposes determined by law (including tax and accounting purposes). You have right of access to your Personal Information and you can correct (rectify) that Personal Information at any time.

We mainly process the Personal Information which you provided to us during the registration process. The provision of this Personal Information is both a statutory requirement and necessary for us to enter into the Agreement. Providing your Personal Information to DiPocket is voluntary. If you do not provide us with the necessary information and documents, we will not be allowed to perform the services specified in the Agreement.

You have a right to ask us or anyone who processes your Personal Information on our behalf to restrict processing or to erase your Personal Information, and we will consider your request in the light of our legitimate interests. Where a request to erase Personal Information is received on behalf of a minor, we will take extra care to consider the impact on them of any decision we make.

You also have a right to object to the processing of your Personal Information, provided it is processed based on public interest or our legitimate interests. Furthermore, you may also ask us to provide your Personal Information in machine-readable form back to you, for onward sharing with another data controller or to provide this data to a third party for their use, at your direction.

Where you have given us your explicit consent for the processing of Personal Information, you also have the right to withdraw this consent at any time. However, such withdrawal will not affect the lawfulness of the processing carried out before the withdrawal was submitted.

If you feel your rights and freedoms in relation to processing your Personal Information have been infringed in any way, please let us know so that we can attempt to resolve the issue. The Personal Information also comes from your usage of the App, including information about payments you make or receive, and from your other interactions with us, for example through social media, and, if it is compliant with the applicable law, from third parties such as shared account holders, credit reference agencies (who may check the Personal Information against other databases – public or private – to which they have access) or fraud prevention agencies.

Subject to your consent, we may also monitor or record telephone calls between you and us or capture images or video recordings during our interactions. We will use these recordings for risk management and fraud prevention purposes, to check your instructions to us, and for training and quality purposes.

If you give us Personal Information about other people which we use to provide services, then you confirm that (i) you know they agree to our holding and use of that data or that you are otherwise allowed to give us this Information and consent on their behalf to our holding and use of it, as well as (ii) you provided such other people with all the Information regarding the processing of personal data as required under the applicable law.

Use of Cookies and other information collection

The App does not use cookies or similar technologies. DiPocket customer website uses cookies (the “Cookies"), and you will be asked to familiarize yourself with DiPocket Cookies Policy and to accept it when you visit the site.

Certain functionality (such as making transfers to people on your contact list) will need to access information on your device. Other functionality will need to operate components of your device (such as the camera to take a selfie or scan your documents). By using such functionality, you consent to The App accessing your device and information. We will inform you before The App accesses your device or information. As such functionality is part of our service and is required for The App to work, we do not provide an option to restrict it and, should you decide to do so through the privacy settings on your mobile device, The App functionality will be severely affected and you may not be able to perform certain transactions or to use The App altogether.

Use of location data

Certain services will make use of location data sent from your mobile device, including but not limited to transaction detail reporting (which allows you to see where you were when you made a particular transaction) and fraud prevention services. If you accept to use these services when installing The App or at any point in time by changing the relevant settings in your mobile device, you consent to us and our partners' and licensees' transmission, collection, maintenance, processing, queries and use of your location data to provide and improve location-based services. You may withdraw this consent at any time by turning off the location services settings on your mobile device. Should you choose to disable location services, certain functionality of The App may be limited or disabled.

How we use the Information

We use the Information for security, identity verification, to communicate with you and to comply with the law.

Specifically, we and other DiPocket Group companies may use the Information to:

  • carry out regulatory checks and meet our obligations to our regulators,
  • prevent and detect fraud, money laundering and other crime (such as identity theft),
  • check if you are in the country and location where your payments are being made in instances where we deem it important to prevent fraud on your account. We do this by using your mobile phone location services,
  • manage your account with us or with other DiPocket Group companies,
  • tell you about products and services (including those of others) which may be of interest to you,
  • develop and improve our services through assessment and analysis of the Information including credit and/or behavioural scoring, market and product analysis, and market research.

We will never pass the Information to a third party for them to use in their own direct marketing without your consent.

Who we can share the Information with

We will keep the Information confidential but we may share it with other entities (who are also bound to keep it secure and confidential) if we have a duty to disclose it, if it is required for the provision of our services to you, or for legitimate business purposes provided your rights or freedoms are not infringed. Where we rely upon ‘legitimate purposes’ as a justification for our processing of the Personal Information, we will carry out an assessment, called a ‘Legitimate Interests Assessment’ and keep a record of it.

If this is compliant with the applicable law, we may share the Information with:

  • other DiPocket Group companies,
  • our partners with whom we may provide a joint offer, or whose offer may complement ours, subject to your explicit consent
  • our service providers and agents (including their sub-contractors),
  • payment-processing service providers and others that help us process your payments and/or provide our services to you. By using The App you agree that we may process the Information abroad, within or outside the European Union, provided we comply with the applicable laws and regulations and under the supervision of the FCA,
  • anyone to whom we transfer or may transfer our rights and duties in the Agreement,
  • UK and overseas regulators and authorities in connection with their duties (such as crime prevention) – for example, because of the way certain payments work means the regulator or authority may be able to access payment details (including information about others involved in the payment). In instructing us to make payments you agree to this for yourself and others involved in your payments,
  • fraud prevention agencies. In particular, we will always tell fraud prevention agencies if you give us false or fraudulent information. They will also allow other organisations (in the UK, Poland or other countries), including law enforcement agencies, to access this information to prevent and detect fraud, money laundering or other crimes. You can write to us at [email protected] for the details of the fraud prevention agencies with which we share the Information,
  • credit reference agencies. Credit reference agencies may use the Information to undertake statistical analysis, testing and development to enhance their existing and future products and services. Credit reference agencies will keep a record of our enquiries, which may also be used by other organisations to make decisions about you. In order not to affect your ability to obtain credit, we will only make unrecorded enquiries, unless you confirm to us explicitly that you would like to apply for a credit through or from us. An unrecorded enquiry is a search that was not made for lending purposes. It cannot affect your credit rating or score when you apply for credit. It is not seen by lenders other than the one that carried out the search. It is included on your credit report so you know the search was made but does not affect your credit rating, or score, when you apply for credit,
  • any third party after a restructure, sale or acquisition of any DiPocket Group company, provided that person uses the Information for the same purposes as it was originally given to us and/or used by us.

Transfer of Personal Information

We may process the Personal Information abroad, within or outside the European Union, provided we comply with the applicable laws and regulations and under the supervision of the FCA. Where we are sharing the Personal Information with organisations in another country (including outside of the EEA), we will ensure they agree to apply equivalent levels of protection as we do (for this purpose, we will take the necessary legal steps to ensure that such transfer is compliant with the law). If this is not possible – for example because we are required by law to disclose the Personal Information – we will ensure the sharing of the Personal Information is lawful.

If we have reasons to think that you are required to report your income or are subject to tax in another country, we may have to share information about your account with the relevant tax authorities, either directly or via the local tax authority who may share that information with the appropriate tax authorities abroad. If we need to request extra documents or information from you about this, you must supply these. If you don’t, you agree that we may close your account or, if the law or other regulations requires us to do so, you agree that we may withhold parts of certain payments received into your account, and pass withheld funds to the relevant tax authorities.

Requirement to update your personal data

To comply with the law and for your own security, it is essential that you keep us informed of changes to your contact, personal details or any other important changes that are relevant to us (for example residential address, mobile phone number, email address).

If you don’t keep these up to date, your eligibility for your account, the products and services we can offer you, or how they work, might be affected.

Once we’ve sent a message to you using the most recent contact information you supplied to us, we will assume that you have received it (even if that is no longer your current contact information). You have a responsibility to look out for things like emails, in-app notifications or texts from us.

Contacting you

We will send you messages by in-app notifications, text, email and other digital methods. These messages may be:

  • nonintrusive information to help you manage your account,
  • messages we are required to send to comply with our regulatory obligations, such as changes to the Agreement, or,
  • marketing information about products and services (including those of others) that may be of interest to you. You can ask us to stop or start sending you marketing messages at any time by changing the The App settings.

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