ScribePay Privacy Policy

​ Date of last update: Nov 8th

 

1. Introduction

This Privacy Policy describes how ScribePay Limited (“ScribePay”) processes personal data ("Personal Data") collected from you, or that you provide to us via the ScribePay website ("our site") and our mobile application (“our App”).

​In this Privacy Policy, we use the terms "we", "us", and "our" (and other similar terms) to refer to ScribePay and "you" and "your" (and other similar terms) to refer to our customers and Website visitors.

​This Privacy Policy is an important document. We recommend that you read it carefully and print and keep a copy for your future reference. When you deal with ScribePay, we will assume you agree to the uses of your Personal Data described in this Privacy Policy unless you tell us otherwise in writing.

2. Controller

For data that you provide in relation to applying for the ScribePay Card, our partner and issuer of the ScribePay Card Transact Payments Limited (“TPL”) will be the controller. TPL is an e-money institution, authorised and regulated by the Gibraltar Financial Services Commission. TPL’s registered office address is 6.20 World Trade Center, 6 Bayside Road, Gibraltar, GX11 1AA and its registered company number is 108217. When you apply for a ScribePay Card, you will be shown the TPL Privacy Policy (available here) within the app and then be asked to accept the terms to continue.

For data relating to you as an accountholder and cardholder of the ScribePay Card, Lerex Technology Limited will be the controller. Lerex’s registered office address is Abacus House, Caxton Place, Cardiff, CF23 8HA and its registered company number is 09829039. [When you apply for a ScribePay Card, you will be shown the Lerex Privacy Policy (available here) within the app and then be asked to accept the terms to continue.

For any other data relating to you, ScribePay will be the controller. ScribePay is incorporated and registered in England and Wales with company number 12776732 at the address 9 Perseverance Works, Kingsland Road, London, England, E2 8DD.  

We recommend that you read each of these policies carefully and print them to keep a copy for your future reference.

3. Contact details

If you have any questions about this privacy policy, including any request to exercise any of your legal rights, please contact the data protection manager using the contact details below.

Full name of legal entity: ScribePay Limited

Email address: hey@scribepayments.co.uk

Postal address: 9 Perseverance Works, Kingsland Road, London, E2 8DD

Telephone number: +44 (0)203 715 8293

You have the right to complain at any time to the Information Commissioner’s Office (ICO), which is the UK’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 do contact us in the first instance.

 

4. Updates to this Privacy Policy

You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of the online Privacy Policy.

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. Any changes will be posted on this page and, where appropriate, notified to you by email. We will obtain your consent to any material Privacy Policy changes where required by applicable data protection laws.

​It is important that the personal data we hold about you is accurate and current. Please let us know if any of your personal data changes during your relationship with us by contacting us at hey@scribepayments.co.uk address.

[●]. 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 parties and are not responsible for their privacy policies. When you leave our website, we recommend that you read the privacy policy of every website you visit and every plug-in or application you use.

 

5. What Personal Data we collect

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes name, date of birth, identification documents, nationality, and country of residence.

  • Contact Data includes postal address, email address, and phone number.

  • Financial Data includes bank account and payment card details.

  • Transaction Data includes details about payments to and from you.

  • Device Data includes internet protocol (IP) address, unique device identifiers, browser type and version, [location data,] and operating system and platform.

  • Profile Data includes username and password, and subscription details.

  • Usage Data includes information about how you use our website

  • [Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.]

 

If we need to collect personal data in order to comply with law or under the terms of any contract we have with you, and you fail to provide this data when requested, we may not be able to perform a contract we have or are trying to make with you (e.g. to provide you with goods or services). In this situation, we may need to cancel an order or service you have with us, but we will tell you if this is the case.

6. How is your personal data collected:

We will collect and process the following data about you:

  • Information you give us. This is information (including [Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by, or by corresponding with us (for example, by email or chat). It includes information you provide when you download or register the App, subscribe to any of our services, make an in-App purchase, share data via an App's social media functions, enter a competition, promotion or survey and when you report a problem with an App, our services, or Website. If you contact us, we will keep a record of that correspondence.

  • Information we collect about you and your device. Each time you visit our Website or use our App we will automatically collect personal data including [Device, Content and Usage Data]. We collect this data using cookies and other similar technologies. Please see our cookie policy [LINK] for further details.

  • [Location Data. We also use [specific technology used e.g. GPS or otherwise]] to determine your current location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by [disabling Location Data in your settings OR [specify how consent is otherwise withdrawn

  • Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties [and public sources] as set out below:

Technical data including from the following parties:

  •  analytics providers such as Google based within the EU;

  •  advertising networks such as Google Ads based within the EU;

  •  search information providers such as Google based within the EU;

  • contact, financial and transaction data from providers of technical, payment and delivery services:

  • identity and contact data from data brokers or aggregators;

  • other individuals under our “refer a friend” scheme;

  • identity and contact data from publicly available sources based within the EU such as Companies House, the Electoral Register and government sanction lists; and

  • other data/other third parties/publicly available sources.

 

We use cookies [and/or similar tracking technology] to distinguish you from other users of the App and Website and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse our Website and also allows us to improve the App and Website. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy [LINK].

 

7. How we use your Personal Data

We will only use your personal data when the law allows us to do so. Our most common uses of your personal data will be:

  • in order for us to perform a contract we are about to make or have made with you (or to take steps at your request before entering such a contract);

  • if it is necessary to do so for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or

  • in order for us to comply with a legal or regulatory obligation

We do not generally rely on your consent as a legal basis for processing your personal data except in relation to sending third party direct marketing communications to you via email or text. You have the right to withdraw your consent to marketing at any time by contacting us using the information above in section 3.

Purposes for which we will use your personal data:

Purpose/activity

Type of data

Lawful basis for processing

To register you as a new App user

Identity

Contact

Financial

Device

 

Your consent.

To manage our relationship with you including notifying you of changes to the App or any services

Identity

Contact

Financial

Transaction

Profile

Marketing and Communications

 

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ services)

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

 

To administer and protect our business and this website:

Identity

Contact

Device

Usage

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers 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

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

8. 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 which is compatible with the original purpose. If you want an explanation as to how processing for the new processing is compatible with the original purpose, please contact us using the information provided above in section 3.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Please be aware that we may process your personal data without your knowledge or consent if this is required or permitted by law.

 

9. Who we share your Personal Data with

We may disclose your Personal Data with the following categories of recipients for the purposes set out in the table in section 7 above:

  • Group companies, business partners (i.e. our Partners), service providers and other affiliated third parties who provide data processing services to us (for example, to support the delivery of our Website or due diligence services), or who otherwise process your Personal Data for purposes that are described in this Privacy Policy or notified to you when we collect your Personal Data which currently consists of Transact Payments Limited and Lerex Technology Limited. Links to their privacy policies are available in section 2.

  • Any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person. An actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your Personal Data only for the purposes disclosed in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only disclose the personal data each third party needs in order to provide the specified purposes, and we do not allow any of 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 only share your personal data with a third party for it to use for its own purposes if you have given your express opt-in consent to this.

​10. International transfers of Personal Data

We do not transfer your personal data outside the UK.

 

11. How we look after your Personal Data

Further details of the security measures ScribePay have in place to ensure the security of the data provided by customers to be added here.  This should include details on :

  • Server security

  • Security of payment transactions made within the app

  • App/website security credentials

  • Any personal data stored on a device

We have put in place appropriate security measures to protect your personal data from being:

•          accidentally or unlawfully destroyed, lost or altered; or

•          disclosed or accessed in an unauthorised way.

We limit access to your personal data to those of our employees, agents, contractors and other third parties who have a business need to know this data. We put in place strict confidentiality agreements (including appropriate data protection obligations) with our third-party service providers, and they will only process your personal data on our instructions.

 

12. Data Retention / how long will you use my personal data

We will only retain Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of complying with any legal, accounting, and/or reporting obligations.

To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from its unauthorised use or disclosure, the purposes for which we process it, and whether we can achieve those purposes through other means, and the applicable legal requirements.

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.

 

13. Your data protection rights

In certain circumstances, you have rights under data protection laws in relation to your personal data, as set out below. If you wish to exercise any of these rights, please contact us using the information above in section 3.

  • Right to access your personal data (a “subject access request”)

  • Right to correction (“rectification”)

  • Right to erasure (the “right to be forgotten”)

  • Right to restrict processing

  • Right to object to processing

  • Right to object to automated decision making and profiling

You can read more about your rights on  the UK Information Commissioner’s Office website <here>.

You will not usually have to pay a fee to access your personal data or to exercise any of the other rights below. However, if your request is clearly unfounded, repetitive or excessive, we may refuse to comply with your request or charge a reasonable fee for the administrative costs of complying with your request.

We may need to ask you for specific information to help us confirm your identity and to ensure your right to access your personal data or exercise any of your other rights. This is a security measure to ensure your personal data is not disclosed to anyone who is not entitled to receive it. We may also ask you for further information in relation to your request, in order to speed up our response.

 

We try to respond to all requests within one month. Occasionally it may take us longer than a month to respond, particularly if your request is particularly complex or you have made a number of requests. We will let you know within a month if this is the case and will keep you updated.