Privacy policy

This policy (together with any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting or using the Countingup mobile application, the website countingup.com or our blog countinguphq.com (“our site”) you are accepting and consenting to the practices described in this policy.

For the purpose of the Data Protection Act 1998 (the “Act”), we are the data controller. Please note that our financial services partner, PPS, is a separate Data Controller.

Information we may collect from you

We may collect and process the following data about you:

Information you give us. You may give us information about you by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, post material on our site, carry out transactions or make payments through our site, report problems with our site or carry out any other activities on our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information and other personal information.

Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:

  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website 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. 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, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You 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 site.

Uses made of the information

We use information held about you in the following ways:

Information you give to us. We will use this information:

  • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
  • to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
  • to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data;
  • to notify you about changes to our service; and
  • to ensure that content from our site is presented in the most effective manner for you and for your computer.

Information we collect about you. We will use this information:

  • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
  • to allow you to participate in interactive features of our service, when you choose to do so;
  • as part of our efforts to keep our site safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
  • to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Disclosure of your information

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006

We may share your information with selected third parties including:

  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
  • Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
  • Analytics and search engine providers that assist us in the improvement and optimisation of our site; and
  • Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

We may disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any agreements between you; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store your personal data

The data that 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 for one of our suppliers. 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.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Email

If you no longer wish to receive our emails there is an unsubscribe link located in the footer of all emails that we send.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at hello@countingup.co.uk.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Access to information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to hello@countingup.co.uk.

Account holders

This section is applicable if you apply for or have been issued a Card and/or Account which is regulated as E-Money or Payment Services.

Prepay Technologies Ltd, trading as PrePay Solutions (“PPS”, “Our” and “We”) is a company registered in England and Wales with number 04008083 and a registered office at 6th Floor, 3 Sheldon Square, Paddington, London, W2 6HY, United Kingdom. You can email PPS at contact@prepaysolutions.com or you can call PPS on 0845 303 5303 (+44 845 303 5303 from
outside the UK).

The Card and/or Account (Card) is issued by PPS (see details below). PPS is the Data Controller in relation to your Card and all necessary activities relating to the operation of the Card: allowing you to receive, activate and use your Card (activating, managing and using your online account where
applicable, making and receiving payment transactions, meeting legal requirements, answering requests, providing information to you).
You may be the Customer or you may be a person that has been provided with a Card by the Customer.

Contact details for the PPS Data Protection Officer

Our Data Protection Officer can be contacted at PO Box 3883, Swindon SN3 9EA or at DPO@prepaysolutions.com.

Processing is necessary for the performance your contract with PPS and for the issue and operation of Cards and is necessary for compliance with legal obligations applicable to PPS. PPS does not use your personal information for marketing purposes and will not share your information with third parties for marketing purposes.

Categories of personal information and collection

Personal Details Full name and date of birth

Contact Details Where you live and how to contact you including phone numbers and e-mail addresses

Transactional Data Details about use of your Countingup Card and payments to and from your accounts with us

Contractual information Details about the products or services we provide to you

Locational Data Data we get about where you are, such as may come from your mobile phone, the address where you connect a computer to the internet, or a shop where you buy something with your Countingup Card

Behavioural Data Details about how you use our products and services

Technical Data Details on the devices and technology you use
Communications What we learn about you from letters, emails and conversations between us

Documentary Data Details about you that are stored in documents in various formats, or copies of them. This could include things like your passport, drivers licence or birth certificate collected to fulfil customer due diligence
requirements

Personal information will only be collected directly and voluntarily from you as part of the application process or as a result of transactions relating to your Countingup Cards. Some personal information may be verified by PPS with use of publicly accessible sources to fulfil customer due diligence.

Sending personal information outside of the EEA

PPS will only send your personal information outside of the European Economic Area (EEA) to:
 Follow your instructions
 Comply with a legal duty
In relation to personal information processed by Mastercard certain processors are located outside of Europe. Personal information processed by Mastercard is subject to Mastercard Binding Corporate Rules which you have enforcement rights under as a third-party beneficiary.

Recipients (or categories of recipients) of personal information

PPS is committed to ensuring that your information is secure with us and with third parties who act on our behalf. These third parties include MasterCard, card manufacturers, suppliers of identity validation services, IVR and call recording (telephone) suppliers and Countingup. We use many tools to make sure that your information remains confidential and accurate and we may monitor or record calls, emails, text messages or other communications in order to protect you and us.

Retention of personal information

We don’t keep your information for longer than we need to, which is usually up to 7 years after the end of the relationship or upon termination of the contract, unless we are required to keep it longer (for example due to a court order or investigation by law enforcement agencies or regulators).

Your Rights

You have certain legal rights to control what we do with your information. These include:

Access You have a right to access the personal information we hold about you

Rectification You have a right to rectification of inaccurate personal information and to update incomplete personal information

Erasure You have a right to request that we delete your personal information

Restriction on processing You have a right to request us to restrict a processing of your personal information

Objection to processing You have a right to object to the processing of your personal information

Portability You have a right to personal information portability

Marketing You have a right to object to direct marketing

To exercise any of your legal rights, you can email PPS at dpo@prepaysolutions.com or you can write to PPS DPO at PO Box 3883, Swindon SN3 9EA.

Your right to lodge a complaint with the Information Commissioner’s Office

If you wish to raise a complaint on how we have handled your personal information, you can contact our Data Protection Officer. We hope that we can address any concerns you may have, but if we fail to address your complaint you can contact the Information Commissioner’s Office (https://ico.org.uk/).

Financial crime prevention

PPS will use your personal information to help decide if your accounts may be being used for fraud or money-laundering. We may detect that an account is being used in ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual. If we think there is a risk of fraud, we may stop activity on the accounts or refuse access to them. We might also check and share your information with fraud prevention agencies. If fraud is identified or suspected, these agencies may keep a record of that information and we may refuse to provide any services. Law enforcement agencies may access and use this information.

If you choose not to give personal information

If you choose not to give us your personal information, it may mean that we cannot perform services needed to run your Card. It could mean that we cancel your Card or services you have with us.