Date of last update: December 15th, 2021
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.
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
Full name of legal entity: ScribePay Limited
Email address: firstname.lastname@example.org
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.
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 email@example.com address.
5. Third party links
6. 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.
7. 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.
- 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.
8. 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 of processing|
|To register you as a new App user||Identity data Contact data Financial data Device data||Your consent|
|To manager our relationship with you including notifying you of changes to the app or any services||Identity data Contact data Financial data Transactional data Profile data Marketing and communication data||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 data Contact data Device data Usage data||Necessary for our legitimate interest (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||Technical data Usage data||Necessary for our legitimate interest (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 and services that may be of interest to you||Identity data Contact data Technical dataUsage data Profile data Marketing and communication data||Necessary for our legitimate interests (to develop our products/services and grow our business)|
9. 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.
10. 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 8 above:
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.
11. International transfers of Personal Data
We do not transfer your personal data outside the UK.
12. How we look after your Personal Data
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.
On the technical side, for example, we maintain a layer of separation between the customers’ access front-end instances and the administrative back-end. Permitted user sessions are managed using an industry standard identity management system, which issues a web token for user authentication. We use secure web connections (HTTPS) to route data requests including payment transactions to the correct back-end service, and we have an architectural set-up which with aids intrusion prevention.
We also 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, and 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.
13. 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.
14. 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.
This policy explains when and why we collect Personal Data (as defined in General Data Protection Regulation) about you, how we use it, the conditions under which we may disclose it to others and how we keep it secure.
TPL is committed to safeguarding the privacy of your information. By “your data”, “your personal data”, and “your information” we mean any personal data about you which you or third parties provide to us.
We may change this Policy from time to time so please check this page regularly to ensure that you’re happy with any changes.
Who are we?
Transact Payments Limited (“TPL”, “we”, “our” or “us”) is the issuer of your card and is the Data Controller for the personal data which you provide to us in relation to the card only. TPL is an e-money institution, authorised and regulated by the Gibraltar Financial Services Commission. Our registered office address is 6.20 World Trade Center, 6 Bayside Road, Gibraltar, GX11 1AA and our registered company number is 108217.
Lerex Technology Ltd is the Program Manager for your card program and is the Data Controller for any personal data which you provide in relation to the program but which is not related to the card. Lerex is incorporated and registered in England and Wales with its registered office at 67 High Street, Leatherhead Surrey KT22 8AH.
How do we collect your personal data?
We collect information from you when you apply online or via a mobile application for a payments card which is issued by us. We also collect information when you use your card to make transactions. We also obtain information from third parties (such as fraud prevention agencies) who may check your personal data against any information listed on an Electoral Register and/or other databases.
On what legal basis do we process your personal data?
Your provision of your personal data and our processing of that data is necessary for each of us to carry out our obligations under the contract (known as the Cardholder Agreement or Cardholder Terms & Conditions or similar) which we enter into when you sign up for our payment services. At times, the processing may be necessary so that we can take certain steps, at your request, prior to entering into that contract, such as verifying your details or eligibility for the payment services. If you fail to provide the personal data which we request, we cannot enter into a contract to provide payment services to you or will take steps to terminate any contract which we have entered into with you.
We may also process your personal data to comply with our legal or regulatory obligations.
We, or a third party, may have a legitimate interest to process your personal data, for example:
- To analyse and improve the security of our business;
- To anonymise personal data and subsequently use anonymized information.
What type of personal data is collected from you?
When you apply for a card, we, or our partners on our behalf, collect the following information from you: full name, physical address, email address, mobile phone number, phone number, date of birth, gender, login details, IP address, identity and address verification documents.
When you use your card to make transactions, we store that transactional and financial information. This includes the date, amount, currency, card number, card name, account balances and name of the merchant, creditor or supplier (for example a supermarket or retailer). We also collect information relating to the payments which are made to/from your account.
How is your personal data used?
We use your personal data to:
– set up your account, including processing your application for a card, creating your account, verifying your identity and printing your card.
– maintain and administer your account, including processing your financial payments, processing the correspondence between us, monitoring your account for fraud and providing a secure internet environment for the transmission of our services.
– comply with our regulatory requirements, including anti-money laundering obligations.
– improve our services, including creating anonymous data from your personal data for analytical use, including for the purposes of training, testing and system development.
Who do we share your information with?
When we use third party service providers, we have a contract in place that requires them to keep your information secure and confidential.
We pass your information to the following categories of entity:
- identity verification agencies to undertake required verification, regulatory and fraud prevention checks;
- information security services organisations, web application hosting providers, mail support providers, network backup service providers and software/platform developers;
- document destruction providers;
- Mastercard, Visa, digital payment service providers or any third parties involved in processing the financial transactions that you make;
- anyone to whom we lawfully transfer or may transfer our rights and duties under this agreement;
- any third party as a result of any restructure, sale or acquisition of TPL or any associated entity, provided that any recipient uses your information for the same purposes as it was originally supplied to us and/or used by us.
- regulatory and law enforcement authorities, whether they are outside or inside of the EEA, where the law requires us to do so.
Sending personal data overseas
To deliver services to you, it is sometimes necessary for us to share your Personal Data outside the European Economic Area (EEA), e.g.:
- with service providers located outside the EEA;
- if you are based outside the EEA;
- where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and Gibraltar data protection law.
These non-EEA countries do not have the same data protection laws as Gibraltar and EEA. We will, however, ensure the transfer complies with data protection law and all Personal Data will be secure. We will send your data to countries where the European Commission has made an adequacy decision, meaning that it has ruled that the legislative framework in the country provides an adequate level of data protection for your Personal Data. You can find out more about this here.
Where we send your data to a country where the European Commission has not made an adequacy decision, our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses, please go to the European Commission’s website.
If you would like further information please contact our Data Protection Officer on the details below.
How long do we store your personal data?
We will store your information for a period of five years after our business relationship ends in order that we can comply with our obligations under applicable legislation such as anti-money laundering and anti-fraud regulations. If any changes to applicable legislation require us to retain your data for a longer period of time, we shall retain it for that period. We will not retain your data for longer than is necessary.
Your rights regarding your personal data?
You have certain rights regarding the personal data which we process:
- You may request a copy of some or all of it.
- You may ask us to rectify any data which we hold which you believe to be inaccurate.
- You may ask us to erase your personal data.
- You may ask us to restrict the processing of your personal data.
- You may object to the processing of your personal data.
- You may ask for the right to data portability.
If you would like us to carry out any of the above, please email the Data Protection Officer at DPO@transactpaymentsltd.com.
How is your information protected?
We implement security policies and technical measures in order to secure your personal data and take steps to protect it from unauthorised access, use or disclosure.
While we strive to protect your Personal Data, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your Personal Data.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Gibraltar is the Gibraltar Regulatory Authority. Their contact details are as follows:
Gibraltar Regulatory Authority,
2nd floor, Eurotowers 4, 1 Europort Road, Gibraltar.
(+350) 20074636/(+350) 20072166 firstname.lastname@example.org
How to contact us