Privacy Policy

This page is used to inform website visitors regarding our policies with the collection, use, and disclosure of Personal Information if anyone decided to use our Service.

If you choose to use our Service, then you agree to the collection and use of information in relation to this policy. The Personal Information that we collect is used for providing and improving the Service. We will not use or share your information with anyone except as described in this Privacy Policy.

The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which is accessible through the Whizzy Money app.

I

WE ARE COMMITTED TO PROTECTING AND RESPECTING YOUR PRIVACY.

We will:

  • always keep your personal data safe and private; and

  • never sell your personal data;

We will collect your personal data when you use:

When we say ‘personal data’, we mean information which can be used to personally identify you (for example, a combination of your name and postal address).

 

THIS POLICY CONTAINS IMPORTANT INFORMATION

This policy explains what information we collect, how we use it, and your rights if you want to change how we use your personal data.

  1. Your personal data

WE COLLECT DIFFERENT TYPES OF PERSONAL DATA FROM YOU AND OTHERS

The table below explains what personal data we collect and use.

Type of personal data

Details

Information you give us

We collect information you provide when you:

✓ fill in any forms;

✓ correspond with us;

✓ register to use the Whizzy Money app;

✓ open an account or use any of our services;

✓ contact us through any channel.

We will collect the following information:

✓ Your name, address, and date of birth;

✓ Your email address, phone number and details of the device you use (for example, your phone, computer or tablet);

✓ Your username, password and other registration information;

✓ Details of your bank account, including the account number, sort code and IBAN;

✓ Details of any debit cards and credit cards you registered with us,

✓ Identification documents (for example, your Emirates ID, passport or driving licence), copies of any documents you have provided for identification purposes, and any other information you provide to prove you are eligible to use our services;

✓ Information you provide upon request, including details about your income and source of funds;

✓ Records of our discussions, if you contact us or we contact you (including records of phone calls);

✓ Your image in photo or video form (where required as part of our Know-Your-Client (KYC) checks or where you upload a photo to your account).

If you give us personal data about other people (such as your spouse or family), or you ask us to share their personal data with third parties, you confirm that you have brought this policy to their attention beforehand.

Information from your device

Whenever you use our website or the Whizzy Money app, we collect the following information:

✓ Technical information, including the internet protocol (IP) address used to connect your device to the internet, your log-in information, the phone or browser type and version, the time-zone setting, the operating system and platform, the type of device you use, a unique device identifier (for example, your device's IMEI number, the MAC address of the device's wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use.

✓ Information about your visit, including the links you have clicked on, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling and clicks), and methods used to browse away from the page.

✓ Information on transactions (for example, payments into and out of your account), including the date, time, amount, currencies, exchange rate, beneficiary details, details of the merchant or ATMs associated with the transaction (including merchants’ and ATMs’ locations), IP address of sender and receiver, sender's and receiver's name and registration information, messages sent or received with the payment, details of device used to arrange the payment and the payment method used.

✓ Information stored on your device, including if you give us access to contact information from your contacts list. The Whizzy Money app will regularly collect this information in order to stay up to date (but only if you have given us permission).

Information about your location

If you have location services in the Whizzy Money app switched on, we track your location using GPS technology.

Information from others

We collect personal data from third parties, such as official registers and databases, as well as fraud-prevention agencies and partners who help us to provide our services.

This includes information to help us check your identity.

In the future, when you ask us to, we can also collect personal data from accounts you hold with third party banks (and some accounts with third party providers that aren't banks) so that you can initiate transfers to your Whizzy Account without leaving the Whizzy Money app and that you can see everything in one place in your Whizzy Money app.

Information from social media

Occasionally, we will use publicly available information about you from selected social media websites or apps to carry out enhanced due diligence checks. Publicly available information from social media websites or apps may also be provided to us when we conduct general searches on you (for example, to comply with our anti-money laundering or sanctions screening obligations).

Information from publicly available sources

We collect information and contact details from publicly available sources, such as media stories, online registers or directories, and websites for enhanced due diligence checks, security searches, and KYC purposes.

  1. Reasons for using your personal data

We must have a legal basis (a valid legal reason) for using your personal data. Our legal basis will be one of the following.

  • Keeping to our contracts and agreements with you

We need certain personal data to provide our services and cannot provide them without this personal data.

  • Legal obligations

In some cases, we have a legal responsibility to collect and store your personal data (for example, under anti-money laundering laws we must hold certain information about our customers).

  • Legitimate interests

We sometimes collect and use your personal data, or share it with other organisations, because we have a legitimate reason to use it and this is reasonable when balanced against your right to privacy.

  • Consent

Where you've agreed to us collecting your personal data, for example when you have ticked a box to indicate you are happy for us to use your personal data in a certain way.

  • Substantial public interest

Where we process your sensitive personal data (sometimes known as special category personal data) to adhere to government regulations or guidance, such as our obligation to support you if you are or become a vulnerable customer.

Ways we use your personal data

We use your personal data so we can provide the best service, tell you about products and services you may be interested in, and meet our legal obligations.

 

PROVIDING OUR SERVICES

Whenever you apply for a product or service, we will use your personal data to check your identity (as part of our KYC process) and decide whether or not to approve your application.

If you are already a Whizzy Money customer, we use your personal data to meet our obligations relating to any transactions you make with your  Whizzy account.

We use your personal data to give you details of our products and services and to help us develop new products and services.

We use your personal data to contact you by phone, messaging or e-mail and provide you with information about our products or services, as well as customer support services. We may monitor or record any communications between you and us, including phone calls, to maintain appropriate records, check your instructions, analyse, assess and improve our services, and for training and quality control purposes.

Our legal basis is one or more of the following:

  • keeping to contracts and agreements between you and us;

  • legitimate interests (we need to be efficient about how we meet our obligations and we want to provide you with good products and services); or

  • legal obligations.

 

PROTECTING AGAINST FRAUD

We use your personal data to check your identity to protect against fraud, keep to financial-crime laws and to confirm that you are eligible to use our services. We also use it to help us better understand your financial circumstances and manage fraud risks related to your Whizzy account.

 

MARKETING AND PROVIDING NEW PRODUCTS AND SERVICES THAT MIGHT INTEREST YOU

We use your personal data to do the following:

  • provide you with information about other products and services we offer that are similar to those you have already used (or asked about, where allowed by law).

  • provide you with information about our products or services which we think you might be interested in. To help us do this, we may use information about you to help us better understand your interests..

  • if you agree, provide you with information about our partners’ promotions or offers which we think you might be interested in.

  • if you agree, allow our partners and other organisations to provide you with information about their products or services.

  • measure or understand the effectiveness of our marketing and advertising, and provide relevant advertising to you.

  • ask your opinion about our products or services.

  • process applications for products and services available through us, and make decisions about whether to approve applications.

 

TO KEEP OUR SERVICES UP AND RUNNING

We use your personal data to manage our website and the Whizzy Money app, (including troubleshooting, data analysis, testing, research, statistical and survey purposes), and to make sure that content is presented in the most effective way for you and your device.

 

PROVIDING LOCATION-BASED SERVICES

We use your personal data to provide relevant advertising to you (for example, information on nearby merchants), to protect against fraud, and to let you know when any of your contacts who are Whizzy customers are in the same area as you (if they have location services switched on).

 

MEETING OUR LEGAL OBLIGATIONS, ENFORCING OUR RIGHTS AND OTHER LEGAL USES

We may need to share personal data about you:

  • with other organisations (for example, fraud-prevention agencies);

  • if this is necessary to meet our legal obligations or in connection with legal claims; or

  • to help detect or prevent crime.

 

Use of your information for marketing

If you sign up to our services, and where allowed by law, we will assume you want us to contact you by post, email and SMS text message with information about Whizzy Money products, services, offers and promotions. We may use the personal data we have collected about you in order to tailor our offers to you.

3) Your rights

Your right

What it means

You have the right to be told about how we use your personal data.

We provide this privacy policy to explain how we use your personal data.

If you ask, we will provide a copy of the personal data we hold about you. We can’t give you any personal data about other people, personal data which is linked to an ongoing criminal or fraud investigation, or personal data which is linked to settlement negotiations with you. We also won't provide you with any communication we've had with our legal advisers.

You can ask us to correct your personal data if you think it's wrong.

You can have incomplete or inaccurate personal data corrected. Before we update your file, we may need to check the accuracy of the new personal data you have provided.

You can ask us to delete your personal data.

You can ask us to delete your personal data if:

✓ there's no good reason for us to continue using it;

✓ you gave us consent (permission) to use your personal data and you have now withdrawn that consent;

✓ you have objected to us using your personal data;

✓ we have used your personal data unlawfully; or

✓ the law requires us to delete your personal data.

Just to let you know, we may not be able to agree to your request. As a regulated financial services provider, we must keep certain customer personal data even where you ask us to delete it (we've explained this in more detail below). If you've closed your Whizzy account, we may not be able to delete your entire file because these regulatory responsibilities take priority.

 

You can object to us processing other personal data (if we are using it for legitimate interests).

If our legal basis for using your personal data is 'legitimate interests' and you disagree with us using it, you can object.

However, if there is an overriding reason why we need to use your personal data, we will not accept your request.

If you object to us using personal data which we need in order to provide our services, we may need to close your account as we won’t be able to provide the services.

 

You can ask us to carry out a human review of an automated decision we make about you.

If we make an automated decision about you that significantly affects you, you can ask us to carry out a manual review of this decision.

Your ability to exercise these rights will depend on a number of factors. Sometimes, we will not be able to agree to your request (for example, if we have a legitimate reason for not doing so or the right does not apply to the particular information we hold about you).

To exercise any of your rights set out above, you can contact us through the Whizzy app

For security reasons, we can't deal with your request if we are not sure of your identity, so we may ask you for proof of your ID.

  1. Sharing your DATA

OTHER WHIZZY CUSTOMERS

We will ask you to let us sync your mobile phone contacts. This will help you to identify which of your trusted mobile phone contacts are Whizzy customers. Your ‘trusted contacts’ will also be able to see if you are a Whizzy customer.

Whizzy can introduce features like requesting money from your friends, splitting bills, group vaults and paying other Whizzy customers near you.

We use technological safeguards to ensure a ‘trusted contact’ is somebody you already know and who knows you (for example, you have each other saved in each other’s mobile phone contacts lists or have already received or given money through a peer-to-peer payment with them).

Both you and your trusted contact must have synced your mobile phone contacts lists with Whizzy to be viewable to each other in the Whizzy app.

We only show your basic contact details in the Whizzy app to your trusted contacts who are also Whizzy customers (for example, your name (as saved in your friend’s contacts list), mobile phone number, Whizzy username, your Whizzy profile photo (if you have one)).

You can, of course, choose not to sync your contacts list with Whizzy. This means that you will not be able to identify which of your mobile phone contacts are Whizzy customers.

PEOPLE OR COMPANIES THAT YOU TRANSFER MONEY TO

Where you make a payment from your Whizzy account, we will provide the recipient with your details (for example, your full legal name and account number).

SUPPLIERS

The table below explains which suppliers we can share your personal data with during the course of our relationship.

Type of supplier

Why we share your personal data

Suppliers who provide us with IT, payment and delivery services

To help us provide our services to you.

Our banking and financial-services partners and payments networks, including Visa and Mastercard

To help us provide our services to you. This includes banking and lending partners, banking intermediaries and international payment-service providers.

Card manufacturing, personalisation and delivery companies

To create and deliver your personalised Whizzy Card.

Analytics providers and search information providers

To help us improve our website or app.

Customer-service providers, survey providers and developers

To help us to provide our services to you.

Communications services providers

To help us send you emails, push notifications and text messages.

THIRD PARTY PAYERS

We may share your name with third parties that pay money into your Whizzy account. This is necessary to confirm that the payment has been made to the correct account.

PARTNERS WHO HELP TO PROVIDE OUR SERVICES

We will only share your personal data with a partner if you have asked for the relevant service or it is provided as part of one of our plans.

From time to time we may work with partners to offer you co-branded services or promotional offers, and we will share some of your personal data with those partners. We will always make sure you understand how we and our partners process your personal data for these purposes.

Our partners will have their own privacy policies explaining how they use your personal data. It's important that you read those privacy policies as well.

OTHER FINANCIAL INSTITUTIONS

We may share your personal data with other financial institutions where you do not ask us to. For example:

  • if you make an outbound payment, we share information about you alongside your payment. This is because we, like all payment institutions, are required by law to include certain information with payments; and

  • if a payment is made to your account by mistake, we can share your information with the financial institution the payment came from. This will help the payer and the other financial institution to try and get the payment back themselves.

FOR LEGAL REASONS

We also share your personal data with fraud-prevention agencies to check your identity, protect against fraud, keep to anti-money laundering laws and confirm that you are eligible to use our products and services.

We may also need to share your personal data with other third party organisations:

  • if we have to do so under any law or regulation;

  • if we sell our business;

  • in connection with criminal or fraud investigations;

  • to enforce our rights (and those of customers or others); or

  • in connection with legal claims.

SOCIAL MEDIA AND ADVERTISING COMPANIES

When we use social media for marketing purposes, your personal data may be shared with the social-media platforms so that they can check if you also hold an account with them. If you do, we may ask the advertising partner or social-media provider to:

  • use your personal data to send our adverts to you, because we think that you might be interested in a new Whizzy product or service;

  • not send you our adverts, because the marketing relates to a service that you already use; or

  • send our adverts to people who have a similar profile to you (for example, if one of our services is particularly useful to people with similar interests to the ones on your social-media profile, we may ask our advertising partner or social-media partner to send our adverts for that service to those people).

An example of how we may use social media for marketing purposes is through Facebook’s ‘Custom Audience’ tool, the terms of which are available here.

Our legal basis is:

  • legitimate interests.

 

WHERE YOU ASK US TO SHARE YOUR PERSONAL DATA

Where you direct us to share your personal data with a third party, we may do so. For example, you may authorise third parties to act on your behalf (such as a lawyer, accountant with power of attorney , or parent or guardian for junior accounts).

  1.  Protecting your personal data

We recognise the importance of protecting and managing your personal data. Any personal data we process will be treated with the utmost care and security. This section sets out some of the security measures we have in place.

We use a variety of physical and technical measures to keep your personal data safe and prevent unauthorised access to, or use or disclosure of it. Electronic data and databases are stored on secure computer systems with control over access to information using both physical and electronic means.

While we take all reasonable steps to ensure that your personal data will be kept secure from unauthorised access, we cannot guarantee it will be secure during transmission by you to our app, a website or other services. We use HTTPS (HTTP Secure), where the communication protocol is encrypted through Transport Layer Security for secure communication over networks, for all our app, web and payment-processing services.

If you use a password for the Whizzy app, you will need to keep this password confidential. Please do not share it with anyone.

When you use our services, which includes our social network accounts do not share any personal data that you don't want to be seen, collected or used by other customers, as this personal data will become publicly available.

We will keep your personal data as long as required by laws applicable to us and our regulatory obligations. We may keep your personal data for longer because of a potential or ongoing court claim or another legal reason.

Links to Other Sites

This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.

Contact Us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us.