Updated 24th May 2018
- About Chip
Relevant personal data will be processed in accordance with the Data Protection Act 1998 and the European Union General Data Protection Regulation (GDPR) 2016/679.
(a) postal correspondence to the Data Protection Officer, Chip Financial, 89 New Bond Street, London, W1S 1DA
(b) emails to firstname.lastname@example.org
We will ensure your query is responded to within 30 days.
- Why we collect personal data
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.
- Other relevant policies and terms
- Information Chip may collect
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).
- Information you give us
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 name, date of birth, copies of personal identification documents such as your passport or driving license, 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 or by corresponding with us by phone, email, text message or through our live chat function
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.
- Information we collect or receive from other sources
We work closely with partner providers and Chip may receive the following information about you when you use the Chip service:
- technical data such as your IP address, geo-location, browser information and operating system;
- usage data such as information about how you use our service;
- 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.
- Links to other websites
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.
- If you fail to provide personal data
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.
- What we do with your information
We will only use your personal data when the law allows us to. Most commonly we will use your personal data:
- to provide you with Chip's automatic savings AI and the Chip services you have selected;
- 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 or regulatory obligation.
- Disclosing your information
We may share your information with selected third parties 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:
- The electronic money institution Prepaid Financial Services of Langham House, 302 Regent Street, W1B 3AT (FCA number 900036).
- SaltEdge Inc of 40 King Street West, Suite 2100, Toronto, Canada to provide encrypted online banking connections and the UK Open Banking API.
- Truelayer Limited of Fleet Place House, 2 Fleet Place, London, EC4M 7RF to provide encrypted online banking connections and the UK Open Banking API.
- GoCardless Ltd of Sutton Yard, 65 Goswell Road, London, EC1V 7EN to facilitate Direct Debits.
- First Data Europe Ltd of Janus House, Endeavor drive, Basildon, SS14 3WF to provide debit card payments.
- Experian Ltd of Sir John Peace building, Experian Way, Nottingham, NG80 1ZZ to conduct the required background, credit and compliance checks.
- Intercom R&D Unlimited Company to facilitate the in-App chat function; and
- Nexmo inc of 217 Second Street, San Francisco, CA 94105, USA to facilitate verification of phone numbers and the use of SMS.
(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
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 out 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.
- Storing your information
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 need to know. 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.
- Out of the EEA
Some of our partner providers perform some functions outside the European Economic Area so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by:
(a) only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
(b) using specific contracts approved by the European Commission which give personal data the same protection is has in Europe (known as ‘model contracts’); or
(c) where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
- 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.
- Your rights
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).
- Access to your personal data
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 Protection Officer.
- Correction of your personal data
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.
- Erasure of your personal data
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.
- Objection to processing of your personal data
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) 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.
- Restriction of processing your personal data
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.
- Transfer of your personal data
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.
- Withdrawing consent
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.
- Withdrawing consent to marketing
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 contacting the Data Protection Officer.
- Changes to this Privacy Notice