Privacy and Cookie Notice

Last updated: 29th June 2021 22:59

Who We Are

Upside Money Limited (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations and explains how, why and when we process your personal data.

Upside Money Limited’s registered office is at 71-75 Shelton Street, London, WC2H 9JQ and we are a company registered in England and Wales under company number 12393337. We are registered on the Information Commissioner's Office Register; registration number ZA747081, and the Financial Conduct Authority; registration number 926577, and act as the data controller when processing your data. Our designated Data Protection Officer/Appointed Person is Steve Fourie, Chief Operating Officer and Co-Founder, who can be contacted at the address specified above or by emailing compliance@upsidesaving.com.

Information That We Collect

Upside Money Limited processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice. Our complete GDPR Policy is available online and by hardcopy on request.

The personal data that we may collect from you is:

  1. Name & Surname
  2. Country of residence
  3. Date of birth
  4. Home Address
  5. Personal Email
  6. Business Email
  7. Home Telephone Number
  8. Mobile Telephone Number
  9. National Insurance Number
  10. Passport Number
  11. Driver’s License Number
  12. Open Banking Information

PLEASE NOTE: As part of your consent to use Upside services - we will also use the specified email address for communication and mailing purposes. The email address that you use to sign up to and register your Upside account will supersede any other email address you provided and as such we take your consent to use the Upside service as your consent to update our marketing database(s). You have the right to withdraw marketing consent, the means which will be provided through the channel the communication was issued.

We collect information in the following ways:

  1. contact us via post, email or telephone and provide any personal data
  2. place an order for products or services on our website
  3. complete online contact form either on our website or our social media pages
  4. provide your contact details to us when registering to use an online account for accessing your order history
  5. contact us offline for example by telephone, fax, email or post
  6. visit or browse our website in accordance with our cookie policy at the end of this notice

How We Use Your Personal Data (Legal Basis for Processing)

Upside Money Limited takes your privacy very seriously and we will never disclose, share or sell your data without your consent, unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and/or marketing, you are free to withdraw this consent at any time.

The purposes and reasons for processing your personal data are detailed below:

We may also contact you for feedback on your use of our products, services or our website and may need to use your information to send important notices, such as updated product or service content where there have been regulation/law revisions or changes to our terms, conditions and policies.

  1. We collect your personal data in the performance of a contract or to provide a service and to ensure that services are completed and can be sent out to your preferred address inline with your communication and consent preferences
  2. We collect and store your personal data as part of our legal and regulated obligation for business accounting and tax purposes
  3. We have a legal obligation to share your personal data with Onfido Limited who are a credit reference agency and provide us with financial background checks prior to you commencing any relationship, financial or otherwise with us
  4. We will occasionally send you marketing information where we have assessed that it is beneficial to you as a customer and in our mutual interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests with your prior consent

Your Rights

You have the right to access any personal information that Upside Money Limited processes about you and to request information about: -

  1. What personal data we hold about you
  2. The purposes of the processing
  3. The categories of personal data concerned
  4. The recipients to whom the personal data has/will be disclosed
  5. How long we intend to store your personal data for
  6. If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.

If we receive a request for any of the above rights, we may ask you to verify your identity before acting on the relevant request; this is to ensure that your data is protected and kept secure. If you create an online account with us, you are able to modify and update your own personal information by logging into your user account.

Sharing and Disclosing Your Personal Information

Upside Money Limited provides you with regulated account information services as an agent of Plaid Financial Ltd., an authorised payment institution regulated by the Financial Conduct Authority under the Payment Services Regulations 2017 (Firm Registration Number: 804718) for the provision of payment services, including account information services.

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice, to validate your qualifying transactions for cashback with our retail partners or where there is a legal requirement. Upside Money Limited uses third-parties to provide the below services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

Plaid Financial Ltd.

(Company number: 11103959) registered in England and Wales whose registered office is at:
Attn: Legal
New Penderel House, 4th Floor
283-288 High Holborn, London, United Kingdom, WC1V 7HP
https://plaid.com/legal/#privacy-statement

PLEASE NOTE: Upside acts as a data controller as an agent of Plaid Financial Ltd and will use specific data elements of your OpenBanking as "Proof of Purchase" with our merchant partners to establish eligibility for the cashback paid into your Upside account. This will be through the form of a "Report" created from Upside operational data which will be derived from your OpenBanking data. Under no circumstances will your retrieved banking data be shared or sold to any party, merchant or otherwise.

The third-party processors/controllers that we work with are:

Onfido Limited

(Company number: 07479524) registered in England and Wales whose registered office is at:
3 Finsbury Avenue, London, United Kingdom, EC2M 2PA
https://onfido.com/privacy/

To assist us with meeting our regulatory obligations, we may carry out an electronic verification check and credit reference checks via third-party providers in order to verify your identity. If such searches are carried out, we may keep records of the contents and results of such searches in accordance with all current and applicable laws. You acknowledge that us carrying out an electronic verification check or credit reference agency check will leave a soft footprint on your credit history.

Onfido act as a data processor for us, providing us with the ability to carry out identity verification services (“Identity Services”), Anti-Money Laundering (“AML”) Checks, Politically Exposed Persons (“PEP”) checks and checks for Sanctions. As a financial institution, we are legally required to do by the industry regulators such as the Financial Conduct Authority (“FCA”). Both we and Onfido are committed to protecting the privacy and security of that identity. Please visit https://onfido.com/privacy/#1 for a detailed explanation of the data collected and to read more about the identity lifecycle. Onfido is a secure, cloud-based system and ensures that your personal information is secure and protected at all times and do not process your information for any other purpose other than identity verification and will never share or disclose your data.

Railsbank Technology Ltd.

(Company Number 10076912 registered in England and Wales whose registered office is at:
35-36 Eagle Street, London, United Kingdom, WC1R 4AQ
https://www.railsbank.com/privacypolicy
compliance@railsbank.com

We utilise Railsbank Ltd as the technology platform that enables Upside to open your Upside Saving account with PayrNet. They act in their own right as a data controller as they are legally accountable to ensure the prevention of financial crime. Railsbank ensure that your personal information is secure, protected and confidential at all times and that any data is only processed within their service and legal obligations and that no personal data is shared or disclosed unless they are required to do so by law.

PayrNet

(Company Number 09883437 registered in England and Wales whose registered office is at:
Head office: WeWork, 3 Waterhouse Square, 138 Holborn, London, EC1N 2SW and
Registered office: Kemp House, 152 City Road, London, United Kingdom, EC1V 2NX
http://www.payr.net/privacypolicy

We utilise PayrNet for services enabling cash to be placed or withdrawn on/from a payment account as well as all the operations required for operating a payment account. PayrNet act as a data controller for your personal data and have one of the highest levels of security in the industry. They are authorised by the Financial Conduct Authority under the Electronic Money Regulations 2011 (register reference 900594) for the issuing of electronic money.

Fidel Limited

(Company Number 08068829 registered in England and Wales whose registered office is at:
Registered office: 9th Floor, 107 Cheapside, London, EC2V 6DN
https://fidel.uk/legal/privacy/

We utilise FIDEL for services enabling customers to link a debit and credit card to the app to qualify for Cardlinked cashback offer.

Experian Group Limited

(Company Number 03720393 registered in England and Wales whose registered office is at:
Registered office: The Sir John Peace Building Experian Way, Ng2 Business Park, Nottingham, NG80 1ZZ
https://www.experian.co.uk/consumer/privacy.html

We utilise Experian as part of our ongoing ID verification and credit checks.

Safeguarding Measures

Upside Money Limited takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including:

  1. secure hosting of our website
  2. anti-virus, firewall and malware protections on all device and networks
  3. We use a site-wide SSL certificate, securing your data and access to our site

Transfers Outside the EU

Personal data in the European Union is protected by the General Data Protection Regulation (GDPR) but some other countries may not necessarily have the same high standard of protection for your personal data. Upside Money Limited does not transfer or store any personal data outside the EU.

Consequences of Not Providing Your Data

You are not obligated to provide your personal information to Upside Money Limited, however, as this information is required for us to provide you with our services in line with our products and your legitimate interests, we will not be able to offer some/all our services without it.

How Long We Keep Your Data?

Upside Money Limited only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

Marketing & Cookies

CONSENT DECLARATION

Occasionally, Upside Money Limited would like to contact/inform you about products/services/promotions that we provide. If you consent to us using your contact details for this purpose, you have the right to modify or withdraw your consent at any time by using the opt-out/unsubscribe options or by contacting compliance@upsidesaving.com directly.

You will be asked to provide consent to us contacting you with the above-mentioned marketing and offers and can withdraw this consent at any time. If you would prefer not to receive above-mentioned marketing and offers you have the right to opt-out of marketing at any time.

Use of Cookies on Our Website

A ‘cookie’ is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. When you visit a site that uses cookies for the first time, a cookie is downloaded onto your computer/mobile device so that the next time you visit that site, your device will remember useful information to provide a better customer experience and journey.

Under GDPR, a cookie acts as an online identifier or is classed as personal data. You have the right to turn such cookies off when visiting a website. At Upside Money Limited we use cookies on our site that are essential for the normal functioning of the website and as such cannot be turned off.

We use non-essential cookies (i.e. adverts, analytics, third-parties, social media etc) but do provide the option for you to turn these off.

Please see our cookie policy for details on you can control the settings of website cookies in your browser. You can see the full list of cookies used on our site.

Lodging A Complaint

Upside Money Limited only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. You have the right to lodge a complaint with the Information Commissioners Office (ICO), the supervisory authority if you are dissatisfied with our treatment of your personal data. They can be contacted at this website https://ico.org.uk, or the contact details supplied below, but we would welcome an opportunity to try to deal with your complaint first.

Upside Money Limited

FAO Compliance Department
71-75 Shelton Street
London
WC2H 9JQ
+44 (0) 7860 615221

compliance@upsidesaving.com

Information Commissioner’s Office

Wycliffe House
Water Lane
Wilmslow
SK9 5AF
0303 123 1113