Important information you need to know

This privacy policy is designed to inform individuals about how Spot Payments Limited (the "Company") collects, uses, and shares personal information. The Company is committed to protecting the privacy and security of personal information in accordance with the General Data Protection Regulation (GDPR) and other applicable laws.

 

Who are we and what do we do?

The Sites and our Services are operated by Spot Payments Limited, (“Spot”, “we”, “us” or “our”) who is the data controller.

 

Spot Payments Limited is an English company with registered company number: 13762907 and whose registered office is at 35 Ballards Lane, London, United Kingdom, N3 1XW.

 

How to contact us?

If you have any questions about this Privacy Policy, please contact us by:

• sending an e-mail to support@spot-app.co.uk; or

• writing to us at: Spot Payments Limited, 35 Ballards Lane, London, United Kingdom, N3 1XW.

 

What personal information do we collect and how do we use it?

Our primary goal in collecting personal information from you is to: (i) verify your identity (“Know Your Customer” checks); (ii) help us improve our services and develop new and services; (iii) carry out requests made by you on Spot; (iv) investigate or settle inquiries or disputes; (v) comply with applicable laws, court orders, other judicial process and the requirements of regulators; (vi) enforce our agreements with you; (vii) protect the rights, property and safety of us and third parties, including our other customers and users of the Site; (viii) provide support for the provision of our Services; and (ix) use as otherwise required or permitted by law.

 

We may share your information with third parties such as credit reference agencies in order to verify your identity and details that you have provided and to conduct account opening checks (such as “Know Your Customer” checks). We may share your information with fraud prevention organisations which will use it for identity verification and prevention of fraud and money-laundering. Suspicious activity may be reported to law enforcement. If fraud is detected, the relevant individual or entity could be refused finance, employment, contract, tenancy or certain services. It is for the purposes of fulfilling our obligations under a contract to use your personal information in such a way to ensure that we verify your identity before approving you for an account and for our legitimate interest in complying with the law and preventing and detecting money laundering, fraud and other crime. We also have a legal obligation to report certain suspicious activity under anti-money laundering legislation.

 

The information we collect for “Know Your Customer” includes:

• Full name

• E-mail address

• Phone number

​

Spot may also collect financial information such as your bank account numbers, information about your transactions, information identifying the bank account you have with your connected bank, information about your bank balance, information to initiate and process the transfer of money on your behalf, transactions made on those bank accounts, your direct debits and standing orders (this is all collected via Yapily Connect UK)

​

How do we obtain your consent?

Where our use of your personal information requires your consent, you can provide such consent:

• at the time we collect your personal information following the instructions provided; or

• by informing us by e-mail or post using the contact details set out in this Privacy Policy.

 

Our use of cookies and similar technologies

Spot use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.

 

Storage and Sharing of Personal Information

We store some personal data in data centres in the United Kingdom. In order to provide you with some of the services via the Sites, we may need to share your personal data with third party service providers.

 

Third Party Links and Services

Our Sites may contain links to third party websites and services. When you use a link to go from our Sites to another website or you request a service from a third party, this Privacy Policy no longer applies.

 

How long do we keep your personal information for?

We keep your personal information for a period of 6 (six) years from the date of our last interaction with you or such longer period as is required by law or regulation.

 

Confidentiality and security of your personal information

Protecting your personal information is a top priority for us, and we take reasonable measures to ensure its security and prevent unauthorized access, loss, misuse, or alteration.

 

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

• unauthorised access;

• improper use or disclosure;

• unauthorised modification; and

• unlawful destruction or accidental loss.

 

All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Sites.

 

How to access your information and your other rights?

Your right of access - You have the right to ask us for copies of your personal information.

 

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

 

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

 

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

 

Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.

 

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

 

Your right to withdraw consent - If we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

 

Your right to lodge a complaint with the supervisory authority - If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

 

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy periodically. We will update it to reflect any changes in how we use your personal information and to comply with applicable laws and regulations. We will send you an email notification of significant changes, but we recommend reviewing this policy periodically to stay informed.

 

The Data Controller,
Spot Payments Limited,
35 Ballards Lane,

London,

United Kingdom,

N3 1XW