Privacy Notice Version 1

Our mission is to enable you to pay your friends and family, businesses, and charities the fastest and the most secure way.

Payments processed through Yotta Pay are being handled by your bank, and funds move directly from payer bank account to payee bank account.

We are not a bank, we do not open accounts for you, and do not handle or have access to your money

We only facilitate and organise your transactions. Each and every transaction is being confirmed by you via your mobile bank application. We do not access your mobile bank application usernames, passwords, or other security information, your ordinary level of security is not compromised.

We do not handle or store your card details, so it cannot be lost or stolen.

Use of Yotta Pay requires only working mobile bank application on your mobile device. We use proven bank grade security protocols, encryption, and employ every best practice security instruments currently available.

Personal data we collect from you is very limited, and we keep your information as concise as possible.

When we ask you for additional information, it is only for the purpose of delivering you our services.

We do not sell your data to third parties;
Where we track your use of the App, we do this to continuously improve and personalise your experience;
Where we reuse your personal data, we do so to avoid asking you the same data twice;
We may pass your information to the parties you have a transaction with, for example, your postal address to the charity you support for the purpose of Gift Aid claim, but we will only do so:

According to your explicit request
With your explicit consent
When it is clear to you what you sent

You have the right to be forgotten.

You can delete your Yotta Pay. We will then delete all data we have about you. You decide what banks to connect to the app or not. You can disconnect a bank at any time.

We want to create a relevant experience for you, so the data we collect might be used anonymously in communications such as:

When we ask you for additional information, it is only for the purpose of delivering you our services.

Blog posts and infographics;
Service update emails from Yotta Pay;
Social media posts;
Campaigns;
Our public insights, posts and infographics are always anonymised and aggregated and can never be tracked down to you personally.

Your data is stored in the UK and protected by UK’s rules and regulations.

Personal data you give us.

You may give us personal data about you by filling in forms on, or interacting with, the App, our website, or by corresponding with us by phone, email or otherwise. Examples of personal data include:

Name, address, email address and phone number;
Information we need to initiate and process the transfer of money on your behalf and send an instruction to your connected bank(s) (payment initiation services);
Content you share with us in our community (Facebook, Twitter etc) or via our social media channels or via our Customer Care;
Biometric data (such as fingerprint or facial recognition data) to grant access to our app on your device.

Personal data we collect from you.

When you use the App or our website we may – ourselves or through our partners like Google Analytics - collect information such as:

IP address;
Device details;
Your login information;
Information about each visit you make to the App (such as page response times and length of visit);
Location data;
Information about your use of the App or website through tracking tools;
Information we require to comply with our legal and regulatory obligations (such as “Know-Your-Customer” and “Customer Due Diligence”);
Information to verify the data you give us;
Information from your phone (like contact details from your address book) if you give us consent to use that data.

We use well-known advertising platforms such as Facebook and Google to tell you about the App.

If you click through such an advert and agree to the App Terms, an automated process will confirm to the advertising platform that you have signed up to the App and how much you use the App. If you don’t use these platforms we will not collect or process this data. We use tools to improve the user experience of our website and to personalise your App experience. Therefore, we perform statistical analyses about the way you use our services, such as information on how you navigate, how much time you spend, how long you visit, and from where you came to our service. We use Google Analytics and Google Firebase software to process this information.

Your consent.

We rely on your consent to process and use your personal data for the following purposes:

Initiate payments on your behalf;
Inform you about payments sent to you by other Yotta Pay users;
(Re)Using personal information we have collected to identify you and to verify your identity to validate the data we hold about you and enrich your data;
Run competitions and referral programmes that you enter.

Legitimate interest.

We use your personal data on the basis of our legitimate interest and to your benefit so that we can:

1. Сreate a persona about you

We can deliver you all the benefits of our app;
Provide you with updates about our services;
Improve your experience of our service;

2. Assess the use of the App;

Help us identify people like you that might enjoy the App;
Make a secure connection between your device and the App
Take action if we need to defend our rights under the App Terms if you would misbehave or act in deviation of laws or regulations or our App Terms;
Track and examine the use of the App and the website to prepare reports on its activities and analyse that data;
Perform research and trend analysis to optimise your experience;
Creating content using some personal data will enable us to engage with you in a relevant and human way.

3. Engage and activate our users by:

Learning from beta services;
Re-engaging our users on social media and via email;
We avoid asking you the same data twice and you can always validate and update this data.

4. We could use your personal data in an anonymised and aggregated form to enrich content in:

Blog posts and infographics
Emails, such as service updates
Social media posts
Campaigns.

(This will never contain data or insights or information that can be tracked down to you personally). We will always use the minimum data required and will process to the minimum extent required.

Legal obligations.

Identify you and verify your identity to comply with our Customer Due Diligence and Know-Your-Customer obligations
Prevent and detect fraud, money laundering, other crime, and security issues
Comply with laws and regulations, as well as any sector-specific guidelines and regulations.

Please be aware that if you do not want us to process the data for the purposes set out above, that we cannot deliver you our services.

You have the right to stop processing your data (right to object).

The App is designed to put you in control and enables you to withdraw your consent by:

Deleting your account or deleting a connected bank;
Disabling tracking your use of the App in the Privacy Settings of the App;
Sending us an email with the request to be forgotten if any of the above does not work or if you cannot connect to the App;
You have the right to ask us not to process your personal data for marketing purposes;
You can always unsubscribe to our emails and campaigns;
You have the right to object to us processing information about you where we do so on the basis of a legitimate interest. If we cannot make that work, it could mean that we may not be able to provide you with the App at all.

This would not invalidate any processing of the personal data prior to your withdrawal of consent.

Your other rights are:

Right of access and data portability. All data that you have provided us is accessible in the App. You can request a copy of all personal data you have provided us through the App. If technically possible, we will help you to automatically export this data to other platforms or users.
Right to rectification. You can control your data through the App. Where you cannot change this data through the App, you have the right to ask us to rectify inaccurate or incomplete personal data which we have about you.
Right to erasure. You have the right to ask us to erase your personal data.

We are committed to ensuring that your personal data (including your Account Information and financial details (described in the App Terms) is secure. In order to prevent unauthorised access to or disclosure of it, we have put in place suitable physical, electronic and operational procedures to safeguard and secure the personal data we collect about you. In particular, we protect your personal data by deploying SSL and high standard encryption algorithms. We also ensure that we meet security standards imposed by law that are applicable and fully follow the guidance of FCA and other relevant regulators on Open Banking and other frameworks we may rely on. We will never ask for your PIN or other security credentials.

Help us protect you.

Other than what is described above, we will only share your personal data in a very limited way. This will happen either where we need to use services we cannot build ourselves or have a duty or legal obligations to disclose it to our service providers (including their subcontractors). This may happen where they help us to run our service or the technology systems that are needed to operate our App and services. This includes:

Regulators in connection with their duties, such as crime prevention or carrying out regulatory oversight of what we do;
Fraud prevention agencies and law enforcement agencies, to prevent and detect fraud, money laundering or other crimes;
Data storage providers to safely and securely store your data;
Aggregation service providers, where necessary in order to retrieve Account Information for use in the App on your behalf;
Identification and verification service providers, to help us adhere to our legal
obligations to verify your identity and the information you give us;
Social Media Platforms via anonymised campaign-IDs so that we can provide relevant content to you on Social Media;
Email services e.g. to send you regular updates or communication;
Customer relation management to provide you with customer care services;
Website and app analytics to provide you with the best experience.

We are only allowed to keep your personal data for as long as it's still necessary for the purpose we initially required it. However, as we are in financial services and bound by strict regulations, this means that we need to retain the data we hold about you for a minimum of 7 years after termination of your Yotta Pay account. If regulations require us to retain it longer or delete it sooner, we will follow these retention periods. If you delete your account or invoke your right to be forgotten, we will use feasible solutions to make it no longer directly available in our systems, like archiving it, and we will no longer process your data.

Our contact details.

Yotta Digital Ltd, 1 Plasmarl terrace, Swansea, Wales, SA6 8LU, company number 12195240, VAT registration number is GB389048258. You can exercise any of the rights under this privacy notice or contact us at: info@yottapay.co.uk.

You have the right to complain to the privacy regulator. In the UK, the privacy regulator is the Information Commissioner's Office (the "ICO"). The ICO can be contacted at:
Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113 (local rate) or 01625 545 745
Email: https://ico.org.uk/global/contact-us/email/

Privacy notice Version 1, effective 01 March 2021