Privacy Policy

Who are we?

Cospay Limited (COSPAY and we) is a fast-growing technology company and e-money payments institution with office in the UK. Cospay is authorised and regulated by the Financial Conduct Authority in the UK, as an electronic money institution, under reference number 900088. We provide own label and white label e-money financial solutions, including e-wallets, prepaid cards, and current accounts. Cospay provides complete end to end solutions for clients by designing, developing, implementing, and managing these programmes.

What, Why?

It is important that you know exactly what we do with the personal information you and others make available to us, why we collect it and what it means for you. This document outlines the COSPAY approach to Data Privacy; specifically how COSPAY collects and processes your personal data you may provide through this website when you purchase a service or take part in a competition / survey.

We were delighted to welcome the advent of General Data Protection Regulation and the Data Protection Act 2018, as it provided COSPAY with a further an opportunity to reassure our customers of the importance we place on keeping your personal data secure, and of the strict guidelines we apply to its use. COSPAY is the data controller and responsible for your personal data. For any requests to exercise your legal rights, please contact the DPO using the details set out at the end of this Policy

We keep our privacy policy under regular review. This version was last updated on 24.03.2022.

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

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 policy of every website you visit.

The Personal Data We Collect From 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 set out below:

First Name and Surname (with title);

Date of birth;

Email;

Telephone number (including home phone and mobile);

Proof of address documents;

Residential address;

ID Documents;

Other personal information such as telephone recordings;

Security questions and your answers;

Profile data (including User ID, user name, password, interests, preferences, feedback and survey responses);

Address;

Bank Account details;

Card details;

Technical data (including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website);

Usage data (information about how you use our website and services);

Marketing and Communications data (includes your preferences in receiving marketing from us )

Transactional information;

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy

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). We have access to and use information about criminal convictions and offences as part of our due diligence procedures.

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:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Please contact our DPO if you have any questions regarding COSPAY’s marketing.

Promotional Offers From Us

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Cookies

We do not use cookies to collect or store information about you.

Withdrawal of Consent Conditions

You may withdraw consent from direct marketing at any time by contacting our Data Protection Officer. As a payment service provider, COSPAY are obliged to retain data concerning financial transactions for 6 years in accordance with national law for the purpose of preventing, detecting and investigating, possible money laundering or terrorist financing.

Change Of Purpose

We will only use your personal data for the purposes for which we collected 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.

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.

Disclosures Of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in the table above.

External Third Parties:

Service providers acting as data processors (such as Decta Limited) based in the United Kingdom or Gibraltar, Austria, Latvia, Lithuania, Malta, Luxembourg who provide IT, system administration, identification and authentication services.

HM Revenue & Customs, Government Digital Service (UK), regulators and supervisory bodies, court authorities, electoral registers and other authorities acting as processors or joint controllers based in the United Kingdom and the EU countries, to comply with Law requirements;

KYC-AML and Due Diligence partners (such as Sum and Substance Limited), who act as our data processors and are based in the United Kingdom, Gibraltar, Austria, Latvia, Malta, to ensure the processing of applications and verification of applicants, and fraud prevention.

Our banking partners and financial institutions (such as Banking Circle), who act as controllers and are based in the United Kingdom, Germany, Luxembourg, Lithuania, Latvia, to provide you with necessary financial services.

To governmental and fraud prevention agencies for assistance in conducting or co-operating in investigations of fraud, crime prevention or other illegal actions where we believe it is reasonable and appropriate to do so;

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Internal Third Parties:

such as other entities within the Cospay Limited group acting as joint controllers or processors based in the UK and the EU providing communications, compliance, IT and infrastructure administration and reporting services.

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. We do not have a specific list of all third parties with which we share your data, as this will depend on your specific use of our Services. However, if you would like more information about who we shared your data with or to be provided with a list that applies to you, we can provide the information upon your request sent to [email protected]

International Data Transfers & Third-Party Disclosures

In limited situations where COSPAY stores or transfers personal information outside the European Economic Area (including the UK), we ensure that robust procedures and safeguarding measures apply to secure, encrypt and maintain the integrity of your personal data. COSPAY complete regular reviews of the countries with sufficient adequacy decisions grant by the EU Commission, provisions for binding corporate rules, standard data protection clauses or approved codes of conduct. COSPAY will further perform due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the personal data prior to transfer. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. For further details

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.

Retention Period

COSPAY will process personal data for the duration of the contract for services and will store the personal data for six (6) years after that date of termination of the contract. By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six (6) years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see your legal rights below for further information. In some circumstances we will 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.

Your Rights as a Data Subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

Right of access – you have the right to request a copy of the information that we hold about you;

Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete;

Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. Your data relating to financial transactions, accounts or cards cannot be deleted due to national law associated with the prevention of fraud, money laundering, counter terrorist financing or misuse of services for crime;

Right to restriction of processing – where certain conditions apply to have a right to restrict the processing;

Right of portability – you have the right to have the data we hold about you transferred to another organisation;

Right to object – you have the right to object to certain types of processing such as direct marketing;

Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling; and right to judicial review, in the event that COSPAY refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below. All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data. You may request a copy of our Subject Access Request Form at [email protected]; and

Right to withdraw your consent - 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.

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 could 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 could 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.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by COSPAY (or third parties as above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and COSPAY’s Data Protection Officer by email to [email protected]