Privacy Notice

Chip is strongly committed to the protection of privacy and the choices of all Chip users in the use of their personal data by Chip.

We also aim to be clear and transparent regarding the data we hold, as well how and why we use it. This Privacy Notice aims to clearly set out the information we collect from Chip users, what we do with that information, how we securely protect that information and the choices Chip users have to erase or amend that information from Chip.

For the purpose of this Privacy Notice Chip Financial Ltd (Chip) of Sixth Floor, Fora Montacute Yards, 186 Shoreditch High Street, London, E1 6HU. UK registered company number 10113174 is the Data Controller, however at times may hold this position jointly with a number of partner providers (together Chip or Chip and its partner providers, as the context requires). Both Chip and the partner providers are registered with the Information Commissioner's Office. Chip's registration number is ZA192036.

Relevant personal data will be processed in accordance with the Data Protection Act 2018 and the UK General Data Protection Regulation (UKGDPR).

Chip has appointed a Data Privacy Officer who is responsible for overseeing questions in relation to our Privacy Notice, including any requests to exercise your legal rights. The partner providers have also appointed Data Protection Officers, or similar. To contact Chip's Data Privacy Officer or to make a request to be put in contact with a Data Protection Officer, or similar, of a partner provider, please address:
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(a) postal correspondence to the Data Privacy Officer, Sixth Floor, Fora Montacute Yards, 186 Shoreditch High Street, London, E1 6HU

(b) emails to dpo@getchip.uk

We will ensure your query is responded to within 30 days.

Chip needs to collect information from our users in order to provide the best possible service and to fulfil our legal and regulatory obligations.

‍In particular, understanding a Chip user's transaction data and their flow of income and expenditure enables Chip's artificial intelligence to make informed financial decisions for that user. 

This Privacy Notice should be read together with Chip's Terms of Use.

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).

During the course of creating and maintaining a Chip account and or using any Chip service, the information you give to Chip and partner providers may include:

‍(a) identity data such as and not limited to your full name*, date of birth, copies of personal identification documents such as your passport or driving licence, which may also indicate ID numbers, nationality and sex, photographs or other descriptions of your likeness;

(b) contact data such as and not limited to your residential address, email address, telephone number, social media identifiers and the ability to communicate with you via in-app push notifications;

(c) financial data such as and not limited to your bank account numbers, bank account sort codes, debit card numbers and debit card payment details and details of other accounts you may use in connection to your Chip connected bank account;

(d) transaction data such as and not limited to your transaction information including the transaction amounts, merchant descriptions, merchant types, credit or debit type and dates and times of transactions;

You may also provide us with certain information by filling in other forms, entering competitions or promotions, creating goals and adding images or by corresponding with us by phone, email, text message or through our live chat function.
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We do not collect any special categories of personal data about you. This includes details about your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health or your biometric or genetic information.

*Where possible, your full name will be used by our partner bank ClearBank to verify that your full name matches the name linked to the account number and sort code of your Chip Instant Access Account and Chip Prize Savings Account. This step is performed before you finalise the payment instruction from your linked current account and submit a payment. This extra security step is called “Confirmation of Payee”.

We work closely with partner providers and Chip may receive the following information about you when you use the Chip service:

‍(a) technical data such as your IP address, geo-location, browser information and operating system;
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(b) usage data such as information about how you use our service;

(c) marketing and communications data such as your preferences in receiving marketing from us and your communication preferences which we have collected directly from you.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this does not directly or indirectly reveal your identity.

We, or our partner providers, may also use cookies to collect information about you and use personal data to provide personalised advertisements. This helps us to provide you with a good experience while you use our service. See our Cookie Policy here.

Our website or App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.

If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract and may therefore be unable to provide you with one or more of our products or services.

We will only use your personal data when the law allows us to. Most commonly we will use your personal data:

(a) to provide you with Chip's automatic saves AI and the Chip services you have selected;

(b) to permit your participation in any Chip Prize Savings Account Competition;

(c) to enhance your individual user experience, for instance by enabling us to offer suitable products to you or to verify that you meet the target market for products you have bought from us;
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(d) where it is necessary for our legitimate interests (or those of a third party provider) and your interests and fundamental rights do not override those interests;

(e) to enable us to identify instances where you may benefit from additional support or assistance in the management of your account;

(f) where we need to comply with a legal or regulatory obligation.

We share your information with our selected third party providers including:

(a) business partners, partner providers, suppliers and sub-contractors for the performance of any contract we enter into with them or you, including (but not limited) to:

1. Truelayer Ltd of Fleet Place House, 2 Fleet Place, London, EC4M 7RF to provide encrypted online banking connections and the UK Open Banking API.

2. Onfido Limited, 3 Finsbury Avenue, EC2M 2PA to conduct the required background, identity and compliance checks.

3. Intercom R&D Unlimited Company to facilitate the in-App chat function; and

4. Nexmo inc of 217 Second Street, San Francisco, CA 94105, USA to facilitate verification of phone numbers and the use of SMS.

5. Capdesk, CapDesk UK, 199 Bishopsgate, Spitalfields, London EC2M 3TY to facilitate investment management.

6. ClearBank Limited, Borough Yards, 13 Dirty Ln, London SE1 9PA to provide banking services. See their Privacy Notice here.

7. Checkout.com, Wenlock Works, Shepherdess Walk, London N1 7LH to provide debit card services.
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8. Seccl Custody Limited 20 Manvers St, Bath, BA1 1JW for the provision of our investment platform

9. Vuzo Ltd Moor Place, 1 Fore St Ave, Barbican, London EC2Y 9DT for the provision of data science and insights that will help us better understand our customers needs and improve the service we offer.

(b) analytics and search engine providers that assist us in the improvement and optimization of our service;

(c) if we sell or buy any business or assets, in which case we may need to disclose your personal information to the prospective seller or buyer of such business or assets;

(d) if we, or substantially all of our assets, are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets; and

(e) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use, and other agreements; or to protect our rights, property, or safety or those of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

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 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 are careful to correctly store your data.

(a) Security
‍We have put in place 256-bit bank level encryption 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 partner providers who have a needs to know basis. They will only process your personal data on our instructions and 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 legally required to do so.

(b) Outside of the UK
Some of our partner providers perform some functions outside the United Kingdom so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by:
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(i) only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the Information Commissioner's Office (ICO);

(ii) using specific contracts approved by the ICO (known as model contracts) together with appropriate safeguards which give personal data the same protection it has in the United Kingdom, or;
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(iii) where we use providers based in the US, we may transfer data to them but only where they can  provide similar protection to personal data within the UK.

(c) Data retention
‍We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

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

We will need to confirm your identity and ensure your right to access your personal data or to exercise any of the other rights listed below.

‍We may also need further information from you in order to speed up your request. You will not have to pay a fee to access your personal data (or to exercise any of the other rights listed below), however we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

Alternatively, we may refuse to comply with your request in these circumstances. We try to respond to all legitimate requests within one month, but occasionally this may take longer if your request is particularly complex or you have made a number of requests (we will notify you and keep you updated).

You have the right to request access to your personal data (commonly known as a data subject access request). If you would like a copy of the information held on you, please contact our Data Privacy Officer.

‍You have the right to request a correction of the personal data that we hold about you.

This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

‍You have the right to request erasure of your personal data.

‍This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.

You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.

Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party provider) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights.

You have the right to request restriction of processing of your personal data.

This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a) if you want us to establish the data's accuracy;

(b) where our use of the data is unlawful but you do not want us to erase it;

(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

‍You have the right to request the transfer of your personal data to you or to a third party.

Subject to the rules and regulations that govern the products and services we provide, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.

Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

‍You have the right to withdraw consent at any time 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.

‍Chip will not disclose your information to any third party for marketing purposes, without your further consent.

You have the right, at any time, to ask us not to process your personal information for marketing purposes. You can do so by unsubscribing from the marketing communication or contacting the Data Privacy Officer.

What can you do if you are unhappy with how your personal data is processed? You can contact Chip’s Data Privacy Officer (see section 2 above).

You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:

Information Commissioner's Office Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF

Phone: 0303 123 1113 (local rate)

We may make changes to this Privacy Notice, so please review it from time to time. If appropriate we will notify you by email about changes.

‍In order to process your application we may supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history.

We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity. We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations.
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When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates.

The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at:

1. TransUnion (CallCredit)

2. Equifax

3. Experian

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found at www.cifas.org.uk/fpn or direct to Chip’ email at dpo@getchip.uk where the DPO can provide the customer with Cifas full fair processing notice.