1st Money Privacy Notice

If you DO live in the UK, or EEA region, 1st Money, Inc., or other Associates in the "1st Money Companies Group", provides our Services to you under this "Privacy Notice for UK, or EEA region" and: "Terms of Service for UK, or EEA region"

If you DON'T live in the UK, or EEA region, please look for the "Privacy Notice for U.S., and all other countries".

This notice describes your rights under the UK GDPR. If you're in the EEA, the EU GDPR gives you equivalent rights, and your supervisory authority is the one for your country rather than the ICO.

We're one Associate of the 1st Money Companies Group. We share information within the Group only to operate, support, and secure the Services, and to meet legal obligations. We don't share it so another Associate can market to you on its own account.

This notice tells you what information we hold, why we hold it and who we give it to. It also tells you how long we keep it, and what you can do about it.

This notice helps explain our data practices, including the information we process to provide our Services ("Services") as defined in our Terms of Service ("Terms"). Please also read 1st Money's Terms. The Terms describe the terms under which you use, and we provide, our Services.

This notice talks about what information we collect and how this affects you. It also explains the steps we take to protect your privacy. This includes building our Services so that processing is under a legal basis. This also includes giving you control over who you communicate with on our Services.

This notice applies to all of our Services unless specified otherwise.

 

Information we collect

1st Money receives or collects some information to operate, provide, improve, understand, customise, support, and market our Services, including when you install, access, or use our Services.

The types of information we receive and collect depend on how you use our Services. We require certain information to deliver our Services and without this we can't provide our Services to you. For example, you must provide and verify your mobile number and email to use our Services.

Our Services have optional features which, if used by you, require us to collect additional information to provide such features. You'll be notified of such collection, as appropriate. If you decide not to provide the information needed to use a feature, you'll be unable to use the feature.

 

1.   Information you provide

• Your Account information. Your mobile number, email, and identifying information is needed to create a 1st Money Account. If you don't provide us with this information, you can't create an Account to use our Services. You're welcome to add other information to your Account, such as a portrait, and contact information.
• Your messages. We don't retain your messages, such as emails, in the ordinary course of providing our Services to you. Instead, your messages are stored on your device and not typically stored on our servers. Once your messages are delivered, they're deleted from our servers. The following scenarios describe circumstances where we may store your messages in the course of delivering them:
• Undelivered messages. If a message can't be delivered immediately (for example, if the recipient is offline), we keep it on our servers for up to 30 days as we try to deliver it. If a message is still undelivered after 30 days, we delete it.
• Status information. You may choose to provide us your work-time status.
• What you tell us at setup. When an organisation is set up we ask a few things about it, such as its business type and who does its bookkeeping. Those are facts about the organisation rather than about you. We use them to run the Services, to price them, and to decide whether our other services are worth mentioning to its commercial contact.
• Transactions and payments data. If you, or Your Orgs, use our Services, we process additional information about you, including payment account and transaction information. Payment account and transaction information includes information needed to complete the transaction.
• Customer support and other communications. When you contact us for customer support or otherwise contact us, you may provide us with information related to your use of our Services, including copies of your messages, any other information you deem helpful, and how to contact you (e.g., your email).
• TimeSpot selfie clock-ins. A selfie clock-in or clock-out on a TimeSpot device gives us a photo of your face, as evidence you were there at the time. Only you and your Org's admins can see it, and no third party can. We delete it automatically after six months, which covers payday processing and a reasonable dispute period. The clock-in and clock-out times remain.

 

2.   Automatically collected information

• Usage and log information. We collect how you use our Services. That means your settings, how you interact with others and with Your Orgs, and the time, frequency, and duration of that activity. We also collect log files and diagnostic, crash, and performance reports. This includes when you registered, the features you use, and your payments, payroll, attendance, and HR information.
• Device and connection information. We collect device and connection-specific information when you install, access, or use our Services. This includes information such as hardware model, operating system information, app version, browser information, connection information (including phone number), language and time zone, IP address, device operations information, and identifiers (including identifiers unique to 1st Money Company Services associated with the same device or Account).
• Cookies. Without asking, we set only what's strictly necessary to run the Services and remember choices you've made, such as language. For anything beyond that we ask first. The first time you open any page on our site, or log in to the product, a message asks whether you agree to cookies that aren't strictly necessary. Nothing of that kind is set until you say yes. We use those to see which Help articles are popular and to customise the Services for you. Saying no costs you nothing and the Services work the same. You can change your answer at any time in Settings, and the same message will ask again if you clear your cookies. We use no advertising cookies, tracking pixels or third party ad tech, and neither do our promotional banners.

 

3.   Third party information

• Information others provide about you. Other Users give us information about you, including people in an Org you belong to or have been invited to. It may include your name, phone number, and information from their HR systems, and they may invite you to join or to apply for a job. Each must hold lawful rights to share it. Where your employer or a business gave us your details rather than you, they stay responsible for their own use of them, we tell you where we got them when we first contact you, and you can email privacy@1st.money to ask what we hold.
• User reports. Similar to how you may decide to report other Users, other Users or third parties may also decide to report to us. These reports may include your interactions with them or others on our Services. For example, to report possible violations of our Terms or policies. When a report is made, we collect information on both the reporting User and reported User.
• Orgs on 1st Money. Orgs you interact with using our Services may provide us with information about their interactions with you. We require each of these Orgs to act under applicable law when providing any information to us.
  • Content you share in an Org may be visible to several people in it. An Org may also use third party service providers, which can include other Associates of the 1st Money Companies Group, to help run its operations. It might give one access to its payroll, to process the Org's tax information.
• Third party service providers. We work with service providers and other Associates of the 1st Money Companies Group to run, support, secure, and market our Services. They distribute our apps, provide infrastructure and engineering support, process payments, run our service centre, and handle customer service. They may give us information about you, such as an app store report that helps us fix a fault.
  • The "How we work with Associates of the 1st Money Companies Group" section below provides more information about how 1st Money collects and shares information with the other Associates of the 1st Money Companies Group.
• Third party services. You can use our Services alongside third party services and other 1st Money Company Services, and we may receive information about you from them. For example, if Your Org turns on an integration that shares payroll transactions with an accounting system or a tax authority. Their own terms and privacy policies govern your use of them.

 

If we contacted you and you're not a customer

We may contact a business that doesn't use our Services, to tell it about our payroll software. Your details didn't come from you, so here's everything we'd have told you if they had.

• What we hold. The business name, address, industry, website, and telephone number, and a contact name where the source gave us one. No payroll data, no financial data, and nothing about anyone's private life.
• Where it came from. Commercial data providers, and publicly available business sources such as a company's own website or a public business directory.
• Why we hold it. To offer business software to businesses that might want it. We rely on our legitimate interests in doing that, weighed against yours in a written assessment. Email privacy@1st.money for a summary of it.
• What we do with it. We call you. We don't email you on this basis.
• How long we keep it. Until the business tells us it isn't interested or the campaign ends, whichever comes first. After that we keep only the entry that stops us contacting you again.
• Saying no. Tell us to stop and we'll stop, permanently. That right is absolute and we don't weigh it against anything of ours. Tell whoever calls, or email privacy@1st.money.
• Complaining. You can complain to your data protection authority, which in the UK is the Information Commissioner's Office at ico.org.uk. We'd rather you told us first, but you don't have to.

When we should tell you this is a month from when we got your details, or when we first contact you, whichever comes first. We load and screen leads in bulk and many are never called. For those we hold a work telephone number and no email or postal address. Writing to every one of them would cost far more than the exercise is worth. We rely on the exemption that covers exactly that. This page is how we give you the information instead, and whoever calls you gives it again on the call.

 

Who our Services are for

Our Services are for businesses, and for the people who work in them. We don't market them to anyone in a personal capacity. Where consumer law applies to you anyway, it applies, and nothing here takes it away. If you're a sole trader, you're a business to us, though some laws still treat you as an individual and we apply those where they do.

 

Children

Our Services are for businesses and the people who work in them, and we don't market to children. You need to be 18 to log in. We go by the date of birth the employer gives us. Where it shows someone's under 18 we don't let them start a session, and we send them no invitation to join an organisation. If a date of birth arrives after they've logged in, we end the session right away. That doesn't stop anyone being paid. We hold and process an under-18's payroll record on the employer's instructions exactly as anyone else's. Their payslip, year-end, and leaver documents reach them as PDF attachments they keep, needing no login; those emails carry a link back to the product as a convenience that nobody has to follow. The employer decides what goes in that record and why, so it's the controller and a request about it goes to them first. We collect nothing from the person themselves. When they turn 18 their employer can invite them, and they can log in from then. If you think we hold information about a child who shouldn't be in our records, email privacy@1st.money.

 

How we use information

We use information we hold (subject to choices you make and applicable law) to operate, provide, improve, understand, customise and support our Services. We market them only as described under "Opting out of marketing", "If you're a commercial contact" and "Promotional banners", and never using payroll data. Here's how:

• Our Services. We use information we hold to operate and provide our Services, including providing customer support; completing purchases or transactions; improving, fixing, and customising our Services.
  • We also use information we hold to understand how people use our Services, to evaluate, improve, and test them, and to troubleshoot. Where we do that we use the least we need, and we don't use anyone's pay, bank details or identifiers for it. We also use your information to respond to you when you contact us.
• Safety, security, and integrity. We use what we hold to verify Accounts and activity, detect fraud and unauthorised access, investigate misuse of payments or filings, and keep the Services secure and lawful, including by investigating suspicious activity or breaches of our Terms. See "Law, our rights, and protection" below.
• Communications about our Services and the 1st Money Companies Group. We use information we hold to communicate with you about our Services and let you know about our terms, policies, and other important updates. We may provide you marketing for our Services and those of the 1st Money Companies Group.
• No third party banner ads. We still don't allow third party banner ads on our Services. We've got no intention to introduce them, but if we ever do, we'll update this notice.

 

Information you and we share

You share your information as you use and communicate through our Services, and we share your information to help us operate, provide, improve, understand, customise, support, and market our Services.

• What you send through the Services. Payslips, notices, messages, and documents you send through the Services reach the people you address them to, and the administrators your Org has given access.
• Information associated with your Account. Anyone in an Org you've joined sees your first name, the first initial of your family name, job title, job grade, portrait, division, department, time zone, work-time status, manager, and managees. Your manager, supervisors, project leaders, and managees also see your last name, phone number, email, and limited contact information. Your admins see more. Pay, bank details and identifiers aren't part of that. Only people your Org gives payroll access can see those, as set out below. Use your settings and the "ghost" feature to manage some of this.
• Your Org. If an Org runs your payroll, it sees the records it needs to run it, including your pay, bank details, and identifiers. It decides who within it can see them. We also give an Org metrics about its own use of our Services.
• Third party service providers. We work with service providers and other Associates of the 1st Money Companies Group to run, support, secure, and market our Services. They provide technical infrastructure and delivery systems, run surveys and research, protect Users, and assist with customer service. We require each to use your information on our behalf, on our instructions and terms.
• Third party services. Where a third party service, or another 1st Money Company Service, is integrated with ours, it may receive what you share with it, and may learn your IP address and that you're a User. Its own terms and privacy policy govern your use of it, not this notice. Your Org chooses which integrations to turn on and can turn them off.

 

How we work with Associates of the 1st Money Companies Group

As part of the 1st Money Companies Group, 1st Money receives information from, and shares information with, the other Associates of the 1st Money Companies Group. The link above says which companies those are and where they're based.

We do this to promote safety, security and integrity across the 1st Money Company Services, e.g., to fight spam, threats, abuse, or infringement activities.

We also share information with other Associates of the 1st Money Companies Group acting for us, to run, support, secure, and market our Services. That covers infrastructure and systems for reliable Payroll Payments, understanding how our Services are used, and connecting you with Orgs. They use what we share on our behalf and on our instructions only.

 

Our legal basis for processing data

The law requires a legal basis for processing data. We rely on different bases for different purposes, and sometimes on more than one for the same purpose. For each basis below we set out why we process your information, how, and which categories of your data we use.

You also have particular rights available to you depending on which legal basis we use, and we've explained these below. You should know that no matter what legal basis applies, you always have the right to request access to, rectification of, and erasure of your data. To exercise your rights, see the "How you exercise your rights" section below.

We collect, use, and share the information described in the "Information we collect" section:

Unless a basis below says otherwise, the data used is what's described under "Information you provide", "Automatically collected information" and "Third party information", and which of it applies depends on what you give us and how you use the Services.

1. To operate and provide Services. As necessary to operate and provide the tax calculation and payment services, described in the "About our Services" section of our Terms. Learn more in the "Provision of the Services under the Terms" section.
2. With your consent. Where applicable (including where consent is legally required), if you've given your consent, which you can revoke at any time. Learn more in the "Your consent" section.
3. To comply with legal obligations. As necessary to comply with legal obligations such as when we're required to respond to a legal request from law enforcement. Learn more in the "Compliance with a legal obligation" section.
4. To protect your vital interests. When and as necessary, to protect your vital interests, or those of others such as in the event of an emergency. This additionally includes where there's a threat to your life or someone else's. Learn more in the "Protection of your vital interests, or those of another person" section.
5. For legitimate interests. As necessary for our interests, or others', in providing an innovative, relevant, safe, and profitable service, unless your interests or fundamental rights override them. For example, to stop our Services being used for harmful or illegal activity. See the "Legitimate interests" section.
6. Necessary in the public interest. Where it's necessary in the public interest. Learn more in the "Tasks carried out in the public interest" section.

Learn more in the "How we process your information" section, about the ways and purposes for which we process your data. This section also includes our legal bases for doing so.

 

How we process your information

The legal bases we rely on in certain instances when processing your data are set out below.

 

1.   Provision of the Services under the Terms

We process the data described under "Information we collect" as necessary to perform our contract with you, the Terms. Which categories we use depends on what you give us and how you use the Services. That in turn shapes what we collect automatically and what Your Orgs provide. The contractual purposes are:

Why and how we process your data:

• To run, improve, customise and support our Services as set out under "About our Services" in our Terms, including connecting you with other Users and Orgs. That covers collecting what we need to create your Account, connecting you with Orgs and analysing your use of the Services. It also covers answering support issues, and deleting your data if you close your Account.
• To keep our Services safe, secure, and available. That means verifying what you gave us at signup, analysing suspicious activity on your Account, and preventing, detecting, investigating, and fixing security incidents, vulnerabilities, malware, spam and unauthorised access to the Services or to User devices.
• To transfer, transmit, store or process your data outside the UK, including in the Netherlands and the U.S., where that's necessary to provide the Services. This is explained under the "Our global operations" section. Transfers to our service centre are for marketing and support, and rest on legitimate interests or your consent, not on this contract basis.
• To communicate with you on Services-related issues, such as sending you a notification about an update or to respond to you when you contact us.
• "How we use information" and "Our global operations" explain each purpose. Where we process your data to perform our contract with you, you can port it. See "How you exercise your rights".

 

2.   Your consent

We process data for the purposes described below when you've given us your consent to do so. We rely on your consent:

Why and how we process your data. For collecting and using information you allow us to receive through the device-based settings you enable. This allows us to provide the services described when you enable the settings.

Why and how we process your data. For sending you marketing email about discounts and special offers on our products. That applies where you're a sole trader, an unincorporated partnership, a charity, a club or an association. It also applies to another organisation that isn't a limited company or an LLP. That's the whole of what we ask for and the whole of what we send on it. Every email on this basis carries a discount or a special offer. If we want to email you about something else, we ask you again for that. We ask separately in the product, we don't ask by email, and we ask at most three times. If you say no we stop asking, and if all three of your marketing switches are off we don't ask at all.

• Data categories used. For the device-based settings, device information. For marketing email, your name, email address, your organisation's name and legal form, and your marketing preferences.
• You can withdraw consent at any time, and withdrawing doesn't affect what we did before. Where the law gives you a right to a copy in a portable form, it applies to what you gave us. See "How you exercise your rights" in this notice.

 

3.   Compliance with a legal obligation

Why and how we process your data. To comply with a legal obligation, such as a valid law enforcement order for data in an investigation. That data may include your name, portrait or IP address, and we disclose only what the obligation requires. We may also be required to keep payroll and accounting records even after you ask us to delete them. The periods are set out under "Managing and retaining your information".

 

4.   Protection of your vital interests, or those of another person

Why and how we process your data. To protect your life, physical integrity or safety, or someone else's. We rely on this to combat harmful conduct, for example when investigating a report or when someone needs help. It can include giving data to law enforcement in an emergency, where they ask for it and it's necessary to protect a person's life or safety.

 

5.   Legitimate interests

We rely on our legitimate interests or the legitimate interests of a third party where they're not outweighed by your interests or fundamental rights and freedoms ("legitimate interests"):

Why and how we process your data:

1. For measuring and improving our own Services, where we decide how that's done. Where an Org's own reporting is involved we act on that Org's instructions, and it decides, not us.
   • Legitimate interests relied on:
     1. To give an Org accurate and reliable aggregated reporting about its own use of our Services, and to keep our own performance statistics accurate.
     2. In an Org's interest, to show it how its own payroll and HR run on our Services. Also to help us see which parts of the Services work and which don't. We don't build profiles of individuals and we don't share an Org's data with anyone outside it for this.
2. For creating anonymised data from an Org's bookkeeping records, so we can train our own models.
   • Legitimate interests relied on. To improve how accurately the Services categorise and reconcile, for that Org and for every other. The Org instructs us to do it, and can stop it at any time, free.
   • Data categories used. The Org's financial records and, where they're part of them, its payroll records. Everything identifying is replaced with imaginary values before anything reaches a training corpus, and health information is replaced with a general absence before anything is used. You can object under Article 21(1) before your data is anonymised. Once it's anonymised there's nothing left to object to.
3. For providing marketing communications to you.
   • Legitimate interests relied on. To promote 1st Money Company Services and send direct marketing. We rely on legitimate interests for marketing telephone calls, and for marketing email to a limited company or LLP. You can opt out at any time. For a sole trader, an unincorporated partnership, a charity, a club or an association, we don't rely on legitimate interests for marketing email. We ask for your consent first, and send nothing without it. Email privacy@1st.money for a summary of our legitimate interests assessment.
   • Data categories used. For marketing we use your name, telephone number, email address, your business name, address, and legal form, and your marketing preferences. We transfer those to our service centre provider so its agents can contact you for us.
4. To share information with others including tax authorities, law enforcement, and to respond to legal requests. See the "Law, our rights, and protection" section for more information.
   • Legitimate interests relied on:
     1. To prevent and address fraud, unauthorised use of the 1st Money Company Services, violations of our terms and policies, or other harmful or illegal activity.
     2. To protect ourselves (including our rights, property or products), our Users or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm.
5. To share information with other Associates of the 1st Money Companies Group to promote safety, security, and integrity. See also "How we work with Associates of the 1st Money Companies Group" for more information.
   • Legitimate interests relied on. To secure systems and fight spam, threats, abuse, or infringement activities and promote safety and security across the 1st Money Company Services.

You can object to, and seek restriction of, such processing. If you object to direct marketing we stop, with no balancing and no exceptions. For the rest we'll stop unless we've got compelling legitimate grounds that override your interests. To exercise your rights, visit the "How you exercise your rights" section of this notice.

 

6.   Tasks carried out in the public interest

Why and how we process your data. We rely on this basis only where a law places a public interest task on us directly. In practice that's rare. Tax collection and reporting is covered by "Compliance with a legal obligation" above, and safety, security, and integrity by "Legitimate interests".

We'll take steps to make sure that we're transparent, as appropriate, when we undertake processing on this basis.

• When we process your data as necessary for a task carried out in the public interest, you've got rights. This includes the right to object to, and seek restriction of, our processing. To exercise your rights, read the "How you exercise your rights" section of this notice.

We're a Delaware corporation with no UK premises, and we perform no part of the Services in the UK. The UK GDPR applies to us under Article 3(2), because we offer services to people in the UK.

 

If our business changes hands

If we're involved in a merger, acquisition, restructuring, bankruptcy or sale of assets, we may share your information with the buyer or successor. They'll be bound by this notice until they tell you otherwise. We'll tell you as soon as we reasonably can, before the change where we can.

 

Special category information

Running payroll means we hold bank details and National Insurance numbers. Those aren't special category data under Article 9, but we treat them with the same care. An Org's payroll records may contain special category data, such as sickness absence, or criminal offence data under Article 10. That Org decides why and how, and holds the condition or authorisation the law requires. We process it only on that Org's instructions to provide the Services.

We don't ask about anyone's health on a call, and we don't need to. Sickness, pension ill-health, and similar matters are for you and your Org to handle, and if one comes up our agent will say so and stop. To catch it, software scans every transcript for words that suggest health, and flags the call for deletion. Nobody reads the transcript to do this. If a recording or transcript turns out to contain health information, we delete both, and we don't use them for training or quality control. The scan exists to find and remove that information, not to use it. We don't rely on any Article 9 condition to keep it, because we don't keep it.

 

How you exercise your rights

Under applicable data protection law, you can access, rectify, port, and erase your information. You also have the right to restrict and object to certain processing of your information.

Direct marketing. You can object to our processing of your information for direct marketing at any time. This right is absolute. We stop, permanently, and we don't weigh it against our own interests. We do that by setting your marketing switches, which are the record of your choice. Objecting to all of it means all three are set, and after that we won't ask you about marketing again.

Other processing. You can also object where we act in the public interest or pursue legitimate interests. Here we weigh it up, considering your reasonable expectations, the benefits and risks to everyone involved, and whether a less invasive route exists. We stop, unless the processing rests on compelling legitimate grounds or the law needs it.

You can access and port your information yourself with "Request account info" (Person > More > About), which gives you a machine-readable copy of what we hold about you. You can close your Account with "Decommission & close org" (Org > More > Decommission & close org). If either doesn't give you what you need, email privacy@1st.money.

When we process data on your consent, you can withdraw it at any time. Withdrawal doesn't affect processing we did before you withdrew. If you consented to marketing email when you signed up, you can withdraw that in Settings or by using the unsubscribe link in any message.

You can lodge a complaint with the Information Commissioner's Office (ICO), our supervisory authority in the UK, at ico.org.uk, or with any other competent supervisory authority. We'd rather you told us first, at privacy@1st.money, but you don't have to.

 

Who your information belongs to

If you're an employee or worker whose payroll an Org runs on our Services, that Org decides what to collect and why. It's the controller and we act on its instructions, so send access, correction, and deletion requests to your employer first. We'll help them answer you.

If your Org asks us for help with your payroll, a support agent working for our provider outside the UK can open your payroll record. They do that to answer the request, and only for that. They can't copy, download or print it, and they see it one person at a time. It works differently if your Org buys our Monthly Bookkeeping service. Then your payroll questions go straight to the bookkeeper assigned to your Org, rather than to our general support team. That bookkeeper can see your Org's payroll records at any time, because they keep its books. Nobody on the general support team can see them at all.

You might've signed up yourself, be your organisation's commercial contact, or be someone we hold as a business prospect. In those cases we decide those things, and the rest of this notice applies to you directly.

If you appear in the books of a business that buys our Monthly Bookkeeping service, that business is the controller. The section below explains what that means for you.

 

Who we are

1st Money, Inc. is a Delaware corporation. It's the controller of your personal information for the purposes described under "Who your information belongs to" above. That section also says where your employer is the controller instead. For anything about your information, email privacy@1st.money.

 

Opting out of marketing

You can opt out in any of these ways. Use Settings in the product, where marketing calls, marketing email, and promotional banners are three separate switches you can set independently. Setting one doesn't change the others, so if you want none of it, set all three. Turning banners off turns off every banner we'd otherwise show you, whether it's for something we charge for or something that's free. Use the unsubscribe link in any marketing email, which stops marketing email. Or tell whoever calls you, and they'll end the call and set your marketing calls switch. That one stops the calls. To stop the email and the banners as well, set those switches in Settings, or use the unsubscribe link in any marketing email. Those switches are the only record we keep of your choice. Stopping everything means all three are off, and after that we won't ask you about marketing again.

Your opt-out is recorded against you, not against your organisation. It applies at once in every organisation you belong to that uses our Services, and in any you join later. It stays in force if you stop being your organisation's commercial contact, and if you're appointed again afterwards. We keep that record for as long as it takes to honour it.

 

If you're a commercial contact

An outside adviser an organisation invites into its account, such as its accountant or bookkeeper, counts as one of that organisation's people once they accept. They see what any administrator there sees, and the organisation can name them as its commercial contact. Where it does, everything in this section applies to them the same way, and their organisation for these purposes is the client that invited them. Every organisation using our Services names one person as its commercial contact. That person's name, telephone number and email address appear on the organisation's billing page, visible to its administrators. We contact them about the organisation's plan and about our other services. Any administrator can change who holds the role, and we email the new contact to explain what it means.

 

Promotional banners

We also show promotional banners for our own services inside this product. They're the same for everyone who sees them, and they're not based on your payroll data or on anything you do in the product. Employees and workers see only banners for 1st Money, Inc. tools that are free for them to use. Banners for our paid services appear only to org admins, payroll admins, and the commercial contact. No banner ever appears on a payslip. Turning them off is covered under: "Opting out of marketing"

 

Calls and recording

• What we record. Every call we make to you and every call you make to us, whether it's about marketing or support. That includes calls handled by the provider that answers for us.
• Why. To train our agents, to check they follow our scripts and honour your choices, and to confirm details you give us during the call.
• On a support call. If the request needs it, the agent opens the relevant payroll record while the call is going on, and only for that request. What they see isn't part of the recording.
• How you're told. This notice and our Terms both say so, and we show links to both when an organisation is created and when you accept an invite to join one. If you call us, a recorded message tells you before we connect you.
• When recording starts. The moment the call connects, so that message, and anything an agent says about recording, is inside the recording itself.
• Who carries the call. Our own telephone system records the call on our servers in the Netherlands, and the recording is held nowhere else. Getting the call to and from the public telephone network is done for us by a telecommunications carrier in the U.S. The audio crosses that carrier while the call is happening. They act as our processor under a contract that carries the UK Addendum to the standard contractual clauses, or an equivalent approved mechanism. Email privacy@1st.money for the current one.
• Transcripts. Software turns every recording into a text transcript. We use it for two things and nothing else. First, to confirm automatically that the recording announcement was made. Second, to scan for words that suggest health. Where health came up on a call, we delete the recording and the transcript instead of keeping them. No person reads a transcript to run either check, and "Special category information" says more about the health scan.
• The announcement log. It holds the number called, the date and time, whether the announcement was found, and how confident the software was. Nothing else that was said. We keep it for six years from the date of the call, then delete it.
• Who can listen. Only named people, only for the reasons above.
• If you'd rather not be recorded. We can't run a call without recording it, so tell whoever calls and they'll end the call. You can reach us by email instead.
• How long we keep recordings. Each recording and its transcript for 30 days from the date of the call, then both are deleted. The announcement log is kept for six years, as above. See "Managing and retaining your information" for everything else.

 

AI features

If your Org buys Monthly Bookkeeping, we use AI to help categorise its bank feed and its transactions. Part of that runs on our own servers in Amsterdam, using a model we host ourselves, and nothing leaves for it. The rest is sent to an AI provider in the U.S. to be analysed and sent straight back. Those providers act as our processors under a contract that bars them from training on it. That contract carries the UK Addendum to the standard contractual clauses. We only use providers hosted in the U.S. for this, and we don't use any hosted in China. Which provider we use will change over time, and you can email privacy@1st.money for the current one.

If you use our AI features, we keep a record of the interaction for 30 days. That's so we can support you and investigate problems, then we delete it. We don't use what you type into the AI features to train any model, ours or a provider's. Training on bookkeeping records is separate, and "Training our models" below explains it.

 

Training our models

If an Org buys our Monthly Bookkeeping service, we use its records to train our own models, so the Services get better at categorising and reconciling. The Org instructs us to do that in our Terms, and it can stop it at any time, free, by asking its dedicated bookkeeper, without any change to its price or its Services.

Records are anonymised before anything reaches a training corpus, and nothing that identifies anyone is ever held in it. We drop free-text descriptions, and replace who a payment was to or from with an imaginary counterparty. We replace names, addresses, account numbers, tax and national identifiers with imaginary identifiers. Where a payroll record shows sickness absence we replace it with a general absence first, so nothing about anyone's health is used.

When an Org opts out we take its records out of the corpus right away. They're used in no further training of any model, new or existing. Models we've already released aren't retrained or withdrawn.

We never try to re-identify anonymised data, and anyone we give it to is contractually bound not to either.

 

Talking to your bookkeeper

If your Org buys Monthly Bookkeeping you choose how you reach your bookkeeper, and we record that choice when you join. We ask two things: how you'd like us to reach you with a short question, and how you'd like to hold a longer meeting.

Telephone runs on our own system on our servers in Amsterdam, and those calls are recorded. "Calls and recording" says why, and how long we keep them. Email is hosted by Zoho. The chat inside the product is hosted by tawk.to. Chat and video on WhatsApp, Messenger, Microsoft Teams, Google Meet or Zoom is hosted by whichever of those you pick, and those calls aren't recorded.

We publish no incoming number for bookkeeping. You ask for a call on any channel and we call the number you gave us. So every bookkeeping call is one we placed, to a number you chose.

We keep the chat history inside the product for 90 days, then delete it. Messages you send us on a platform you chose stay in your own account there on that platform's terms, not ours.

Keep records, documents, and anything sensitive inside the product rather than in a chat. We never ask for a password or a bank credential on any channel.

 

Automated decisions

We make no decision about you by automated means alone that produces a legal or similarly significant effect, so Article 22 isn't engaged. Three things run automatically, and none is that kind of decision. Software scans a call transcript for words suggesting health and flags the call for deletion, so it removes information rather than using it. Software checks the same transcript for the recording announcement and logs the finding and a confidence score. That records what was said to you rather than deciding anything about you. And where your Org buys Monthly Bookkeeping, AI suggests a category for each transaction, confident suggestions applied and the rest reviewed by a person. That categorises a transaction rather than a person. Everyone in the same audience sees the same promotional banner, and it isn't chosen using your data or your activity in the product.

 

How long we take

We answer a rights request within one month. If it's complex, or you've made several, we may take up to two more months, and we'll tell you within the first month if that happens. There's no charge, unless a request is clearly unfounded or excessive.

 

What we don't do

We don't sell your information. We don't share it for advertising. We don't use advertising cookies, tracking pixels or third party ad tech. We don't build a profile of you as an individual, and nothing you do in the product decides whether we contact you. We don't buy lists of people's personal contact details. Where we buy business contact data we use it to call a business, never to email one. We don't put adverts on payslips or show them to employees. And we don't use your payroll data to market to you.

 

How we protect your information

We encrypt your information in transit, and restrict access to the people who need it for their work. We grant and remove that access on a recorded basis, and review who holds it. It sits on servers we control in the Netherlands, run for us by a hosting company based in the U.S., and isn't copied anywhere else. No role in the Services lets anyone export, download, copy or print a payroll record. Bookkeeping is different, because it's done in an accounting package rather than our own systems. We can't switch off that package's export and print features, and don't claim to. The protections there are a named account for each bookkeeper that nobody shares, and the narrowest role the package offers. They also include multi-factor login, its audit trail, and a contractual ban on taking anything off it. We assess those measures against the risk as Article 32 requires, and review that every year and on any material change. We record the reasoning where our regulator can ask for it. Our service centre provider reaches your information only through our own systems, holds no copy, and is audited. No system is perfectly secure, so if a breach affects you we'll tell you and the relevant authority where the law requires it.

 

Managing and retaining your information

We keep information for as long as the purposes in this notice need, including to provide the Services, meet legal obligations, enforce our Terms, and protect our rights, property, and Users. How long depends on what the information is, why we hold it, and what the law requires. For marketing we apply these periods:

• Call recordings and their transcripts: 30 days from the date of the call, then both are deleted automatically.
• The recording announcement log: six years from the date of the call, then deleted.
• Marketing switches: kept indefinitely, because that record is what lets us honour your choice.
• Consent asks and your answers: kept for six years, with the version of the wording we used, so we can show what you were asked and what you said.
• Commercial contact records: kept while your organisation holds an account. We stop using them for marketing the moment you stop being the commercial contact.
• Prospect records: deleted when the business declines or the campaign ends, apart from the do-not-contact entry.

For the rest of the Services:

• TimeSpot selfie clock-ins: six months, then deleted automatically. The clock-in and clock-out times remain.
• AI feature interaction records: 30 days, then deleted.
• An invitation to an adviser that's never accepted: we delete the name and email address 90 days after we send it. In the meantime they're used for nothing but delivering that invitation, and never for marketing. Your Org can send a fresh invitation at any time.
• Read-only access after we withdraw a free service: three years from the date we withdraw it, so Your Org can still log in and download its payroll records.

Where the law sets the period, or the Services do:

• Legal obligations. We keep information where the law requires it, to enforce our Terms, or to protect rights, property, and Users. See "Law, our rights, and protection". We may be required to keep records for longer than we'd otherwise need them, and how long depends on the record. Payroll records for three years after the end of the tax year (see gov.uk). A limited company's accounting records for six years from the end of the financial year (see gov.uk). A sole trader's or a partner's records for five years after the 31 January filing deadline for that tax year (see gov.uk). VAT records for six years (see gov.uk), and CIS records for three years after the end of the tax year (see gov.uk). We keep the records that let us honour your marketing objection indefinitely. Apart from those, nothing here needs keeping longer than seven years from the end of the financial year in which the Account ended.
• Operational retention needs. We don't keep your messages, apart from the limited cases above. Once delivered they're deleted from our servers. If one can't be delivered we hold it for up to 30 days while we try, then delete it.

If you'd like to further manage, change, limit, or delete your information, do that through the following tools:

• Services settings. You can change your Services settings to manage certain information available to other Users. You can manage your "Follow" list, or use our "Ghost" feature to manage who you communicate with on our Services.
• Changing your mobile number, email, portrait, and contact information. If you change your mobile number, you must update it using our change number feature and transfer your Account to your new mobile number. You can also change your email, portrait, and contact information at any time.
• Deleting your 1st Money Account. You can delete your 1st Money Account at any time using our "Decommission & close org" feature.
  • Once you initiate the deletion process for your Account, that Account can no longer be used (i.e., you can't log in or re-register).

 

What happens to your information when you delete your Account?

When you delete your 1st Money Account, we delete the information we hold about you, apart from the information listed below which we retain in limited circumstances.

Where an Org's Services have ended, we keep its data for 30 days so it can export it. We then delete it on the same basis as any other closure. That's where an Account closes. Where we withdraw a free service instead, the Account stays open in a read-only state for three years so Your Org can log in and download its payroll records, and our Terms list what stays available.

Deleted information. When you delete your 1st Money Account, your undelivered messages are deleted from our servers. We also delete any of your other information we no longer need to operate and provide our Services. You'll be removed from all Orgs where you've received no payments, and marked as deleted in the Orgs where you've received payments. Note that it takes up to 90 days from the beginning of the deletion process to delete your 1st Money information. For an Org, the deletion process starts after the 30 day export window closes. Copies of your information may also remain after the 90 days for a limited time in the backup storage. We use the backup storage to recover lost data in the event of a disaster, software error, or other data loss event.

 

Information we retain

• In certain circumstances, to maintain the security of our Services, we need to retain certain logs that we're reviewing past the normal retention period to analyse/investigate a security incident or vulnerability.
• Copies of some materials such as certain log records remain in our database but are disassociated from personal identifiers and no longer linked to your Account. To disassociate this data from your Account, we replace the User identifier with a randomly generated replacement. This is so that it can't be linked back to your Account.
• Copies of certain information may also be retained such as when we're under a legal obligation to retain data, to enforce and prevent violations of our Terms or if necessary to protect our rights, property, and Users. Our "Law, our rights, and protection" section provides more information on this.
• Where we do an Org's bookkeeping, we keep its records for as long as the law requires the Org to keep them, then delete them. For a limited company that's six years from the end of the financial year. For a sole trader or a partner it's five years after the 31 January filing deadline for that tax year. VAT records are six years, and CIS records three years after the end of the tax year.

Deleting the app without using "Decommission & close org" leaves your information with us for longer. Deleting your Account doesn't affect information relating to Orgs you created. Nor does it affect what other Users and Orgs hold about you, such as their copy of your messages or payments they made to you.

 

Law, our rights, and protection

We disclose to an authority only where the law compels it, or where the grounds below apply. We make sure a request is valid, and we disclose the minimum it demands. We tell you unless the law forbids it or there's a risk to someone's safety. We keep a record of every request.

We're a U.S. company, and so is the firm running our servers. So a U.S. authority can in principle demand information from either of us, even though the servers are in the Netherlands. We hand nothing over voluntarily and need a legally binding demand, properly served. A demand might come from a country other than the one whose law protects your information. We check first whether it rests on a treaty between the two. A foreign court order isn't reason enough on its own. We push back on anything too wide, give the least the demand compels, and tell you unless forbidden. Where forbidden we ask to be released, and record that we asked. Nobody answers a demand alone: our Chief Executive Officer decides. One thing we can't promise is that we'll know. If a demand goes to the company running our servers rather than to us, it isn't obliged to tell us.

We access, preserve, and share your information described in the "Information we collect" section, including sharing with regulators, tax authorities, law enforcement, other government agencies, industry partners, and others under the "Our legal basis for processing data" section if we believe in good faith that it's necessary to:

• Respond pursuant to applicable law or regulations, legal process, or government requests.
• Enforce our Terms and any other applicable terms and policies, including for investigations of potential violations.
• Detect, investigate, prevent, or address fraud and other illegal activity or security, and technical issues, or;
• Protect the rights, property, and safety of our Users, 1st Money, the 1st Money Companies Group, or others, including to prevent death or imminent bodily harm.

Further information on the different legal bases we rely on to carry out this processing depending on the circumstances is set out in the "Our legal basis for processing data" section, including under the "Provision of the Services under the Terms", "Legitimate interests" and "Protection of your vital interests, or those of another person" headings.

 

Our global operations

1st Money shares information globally, both internally in the 1st Money Companies Group, and externally with our partners and service providers, and with those with whom you communicate around the world, under this notice and our Terms.

Information we control may be transferred to, or stored and processed in, countries outside the UK for the purposes in this notice. Our servers are in Amsterdam, Netherlands, and we're incorporated in the U.S. with no UK premises. The UK GDPR still applies to us because we offer our Services to people in the UK. Our service centre is covered below.

Our servers are run for us by a hosting company based in the U.S. Holding your information in the Netherlands isn't a transfer out of the UK, because UK adequacy regulations cover the Netherlands. Our own access to our own systems isn't one either. That company may move your information to the U.S. for its own support and operations. It relies there on its EU-U.S. Data Privacy Framework certification and the UK Extension, which the UK recognises. If that framework ever falls, the standard contractual clauses and the UK Addendum take over. Both still mean a U.S. authority could in principle demand your information, so we've assessed that risk alongside the others. "Law, our rights, and protection" above says how we answer a demand.

These transfers let us provide the Services set out in our Terms. Where we transfer your information out of the UK, we rely on UK adequacy regulations if they cover the destination, and otherwise on the Information Commissioner's International Data Transfer Agreement (IDTA), or the UK Addendum to the EU Standard Contractual Clauses. Our servers are in Amsterdam, Netherlands, which UK adequacy regulations cover.

Our service centre. If you're an organisation's nominated commercial contact, or a business prospect, we may transfer your name, telephone number, email address and marketing preferences to our service centre provider, so its agents can contact you and answer account questions for us. Its sales agents can't reach anyone's pay, National Insurance number or bank details. Its support agents can look up an employee's payroll record when a customer asks them to help with one, and only for that. The service centre isn't covered by UK adequacy regulations, so an IDTA is in place and we've completed a transfer risk assessment. Email privacy@1st.money for a summary of it.

If Your Org buys our Monthly Bookkeeping service, the bookkeeper who does that work is at the same provider. To keep the books they see all of Your Org's accounting records, every transaction and the documents behind them. They also see its payroll records in full, for as long as the assignment lasts. Your Org's payroll questions go to them rather than our general support team, which sees none of it. The books are kept in an accounting package rather than our own systems. So we can't switch off its export and print features, and don't claim to; we rely instead on a named account nobody shares, the narrowest role the package offers, and multi-factor login. We also rely on its audit trail, and a contractual ban on taking anything off it. They hold no copy, and access ends with the assignment. The same IDTA and transfer risk assessment cover it.

If you appear in a client's books. A business that buys our Monthly Bookkeeping service might record you as a supplier, a customer or a contact. Then your name and contact details appear in the records we keep for it. That business decides what goes in its books and why, so it's the controller and we act on its instructions. Ask it first, and we'll help it answer you. Your details didn't come from you, so Article 14 applies: we hold your name and contact details to keep that business's books, and where it instructs us we also use its records, anonymised first, to train our models. You can object to that under Article 21(1) before anonymisation.

AI features. If you use our AI features, what you type is sent to an AI provider that generates the response. They act as our processor under a contract that bars them from training on it. Where they're outside the UK, that contract carries the UK Addendum to the standard contractual clauses. Don't type sensitive information into the AI unless a secure field asks for it.

 

Updates to our policy

We may amend or update this notice. We'll tell you before a material change takes effect, and say what changed. Where a change means using your information for a new purpose, we'll tell you before that starts. This version took effect on 5 Sep 2026, and the "Last revised" date at the bottom shows the same.

 

Contact us

Email privacy@1st.money for anything about your information or this notice. Write to us at 1st Money, Inc., 1207 Delaware Ave #1996, Wilmington, DE 19806, USA.

We're not required to appoint a Data Protection Officer and haven't. For data protection questions, email dpo@1st.money and someone responsible for this notice will answer.

If you've got questions about this notice, please contact us or write to us here:

1st Money
Attn: Privacy Notice
1207 Delaware Ave #1996, Wilmington, DE 19806, USA.

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© 2020–2026 1st Money, Inc. All rights reserved. Last revised 5 Sep 2026. Retrieved 6 Nov 2026.

If you DON'T live in the UK, or EEA region, 1st Money, Inc., or other Associates in the "1st Money Companies Group", provides our Services to you under this "Privacy Notice for U.S., and all other countries" and: "Terms of Service for U.S., and all other countries"

If you DO live in the UK, or EEA region, please look for the "Privacy Notice for UK, or EEA region".

We're one Associate of the 1st Money Companies Group. We share information within the Group only to operate, support, and secure the Services, and to meet legal obligations. We don't share it so another Associate can market to you on its own account.

This notice tells you what information we hold, why we hold it and who we give it to. It also tells you how long we keep it, and what you can do about it.

This notice helps explain our data practices, including the information we process to provide our Services ("Services") as defined in our Terms of Service ("Terms"). Please also read 1st Money's Terms. The Terms describe the terms under which you use, and we provide, our Services.

This notice talks about what information we collect and how this affects you. It also explains the steps we take to protect your privacy. This includes building our Services so that processing is under a legal basis. This also includes giving you control over who you communicate with on our Services.

This notice applies to all of our Services unless specified otherwise.

 

Information we collect

1st Money receives or collects some information to operate, provide, improve, understand, customise, support, and market our Services, including when you install, access, or use our Services.

The types of information we receive and collect depend on how you use our Services. We require certain information to deliver our Services and without this we can't provide our Services to you. For example, you must provide and verify your mobile number and email to use our Services.

Our Services have optional features which, if used by you, require us to collect additional information to provide such features. You'll be notified of such collection, as appropriate. If you decide not to provide the information needed to use a feature, you'll be unable to use the feature.

 

1.   Information you provide

• Your Account information. Your mobile number, email, and identifying information is needed to create a 1st Money Account. If you don't provide us with this information, you can't create an Account to use our Services. You're welcome to add other information to your Account, such as a portrait, and contact information.
• Your messages. We don't retain your messages, such as emails, in the ordinary course of providing our Services to you. Instead, your messages are stored on your device and not typically stored on our servers. Once your messages are delivered, they're deleted from our servers. The following scenarios describe circumstances where we may store your messages in the course of delivering them:
• Undelivered messages. If a message can't be delivered immediately (for example, if the recipient is offline), we keep it on our servers for up to 30 days as we try to deliver it. If a message is still undelivered after 30 days, we delete it.
• Status information. You may choose to provide us your work-time status.
• What you tell us at setup. When an organisation is set up we ask a few things about it, such as its business type and who does its bookkeeping. Those are facts about the organisation rather than about you. We use them to run the Services, to price them, and to decide whether our other services are worth mentioning to its commercial contact.
• Transactions and payments data. If you, or Your Orgs, use our Services, we process additional information about you, including payment account and transaction information. Payment account and transaction information includes information needed to complete the transaction.
• Customer support and other communications. When you contact us for customer support or otherwise contact us, you may provide us with information related to your use of our Services, including copies of your messages, any other information you deem helpful, and how to contact you (e.g., your email).
• TimeSpot selfie clock-ins. A selfie clock-in or clock-out on a TimeSpot device gives us a photo of your face, as evidence you were there at the time. Only you and your Org's admins can see it, and no third party can. We delete it automatically after six months, which covers payday processing and a reasonable dispute period. The clock-in and clock-out times remain.

 

2.   Automatically collected information

• Usage and log information. We collect how you use our Services. That means your settings, how you interact with others and with Your Orgs, and the time, frequency, and duration of that activity. We also collect log files and diagnostic, crash, and performance reports. This includes when you registered, the features you use, and your payments, payroll, attendance, and HR information.
• Device and connection information. We collect device and connection-specific information when you install, access, or use our Services. This includes information such as hardware model, operating system information, app version, browser information, connection information (including phone number), language and time zone, IP address, device operations information, and identifiers (including identifiers unique to 1st Money Company Services associated with the same device or Account).
• Cookies. Without asking, we set only what's strictly necessary to run the Services and remember choices you've made, such as language. For anything beyond that we ask first. The first time you open any page on our site, or log in to the product, a message asks whether you agree to cookies that aren't strictly necessary. Nothing of that kind is set until you say yes. We use those to see which Help articles are popular and to customise the Services for you. Saying no costs you nothing and the Services work the same. You can change your answer at any time in Settings, and the same message will ask again if you clear your cookies. We use no advertising cookies, tracking pixels or third party ad tech, and neither do our promotional banners.

 

3.   Third party information

• Information others provide about you. Other Users give us information about you, including people in an Org you belong to or have been invited to. It may include your name, phone number, and information from their HR systems, and they may invite you to join or to apply for a job. Each must hold lawful rights to share it. Where your employer or a business gave us your details rather than you, they stay responsible for their own use of them, we tell you where we got them when we first contact you, and you can email privacy@1st.money to ask what we hold.
• User reports. Similar to how you may decide to report other Users, other Users or third parties may also decide to report to us. These reports may include your interactions with them or others on our Services. For example, to report possible violations of our Terms or policies. When a report is made, we collect information on both the reporting User and reported User.
• Orgs on 1st Money. Orgs you interact with using our Services may provide us with information about their interactions with you. We require each of these Orgs to act under applicable law when providing any information to us.
  • Content you share in an Org may be visible to several people in it. An Org may also use third party service providers, which can include other Associates of the 1st Money Companies Group, to help run its operations. It might give one access to its payroll, to process the Org's tax information.
• Third party service providers. We work with service providers and other Associates of the 1st Money Companies Group to run, support, secure, and market our Services. They distribute our apps, provide infrastructure and engineering support, process payments, run our service centre, and handle customer service. They may give us information about you, such as an app store report that helps us fix a fault.
  • The "How we work with Associates of the 1st Money Companies Group" section below provides more information about how 1st Money collects and shares information with the other Associates of the 1st Money Companies Group.
• Third party services. You can use our Services alongside third party services and other 1st Money Company Services, and we may receive information about you from them. For example, if Your Org turns on an integration that shares payroll transactions with an accounting system or a tax authority. Their own terms and privacy policies govern your use of them.

 

If we contacted you and you're not a customer

We may contact a business that doesn't use our Services, to tell it about our payroll software. Your details didn't come from you, so here's everything we'd have told you if they had.

• What we hold. The business name, address, industry, website, and telephone number, and a contact name where the source gave us one. No payroll data, no financial data, and nothing about anyone's private life.
• Where it came from. Commercial data providers, and publicly available business sources such as a company's own website or a public business directory.
• Why we hold it. To offer business software to businesses that might want it. We rely on our legitimate interests in doing that, weighed against yours in a written assessment. Email privacy@1st.money for a summary of it.
• What we do with it. We call you. We don't email you on this basis.
• How long we keep it. Until the business tells us it isn't interested or the campaign ends, whichever comes first. After that we keep only the entry that stops us contacting you again.
• Saying no. Tell us to stop and we'll stop, permanently. That right is absolute and we don't weigh it against anything of ours. Tell whoever calls, or email privacy@1st.money.
• Complaining. You can complain to your data protection authority, which in the UK is the Information Commissioner's Office at ico.org.uk. We'd rather you told us first, but you don't have to.

When we should tell you this is a month from when we got your details, or when we first contact you, whichever comes first. We load and screen leads in bulk and many are never called. For those we hold a work telephone number and no email or postal address. Writing to every one of them would cost far more than the exercise is worth. We rely on the exemption that covers exactly that. This page is how we give you the information instead, and whoever calls you gives it again on the call.

 

Who our Services are for

Our Services are for businesses, and for the people who work in them. We don't market them to anyone in a personal capacity. Where consumer law applies to you anyway, it applies, and nothing here takes it away. If you're a sole trader, you're a business to us, though some laws still treat you as an individual and we apply those where they do.

 

Children

Our Services are for businesses and the people who work in them, and we don't market to children. You need to be 18 to log in. We go by the date of birth the employer gives us. Where it shows someone's under 18 we don't let them start a session, and we send them no invitation to join an organisation. If a date of birth arrives after they've logged in, we end the session right away. That doesn't stop anyone being paid. We hold and process an under-18's payroll record on the employer's instructions exactly as anyone else's. Their payslip, year-end, and leaver documents reach them as PDF attachments they keep, needing no login; those emails carry a link back to the product as a convenience that nobody has to follow. The employer decides what goes in that record and why, so it's the controller and a request about it goes to them first. We collect nothing from the person themselves. When they turn 18 their employer can invite them, and they can log in from then. If you think we hold information about a child who shouldn't be in our records, email privacy@1st.money.

 

How we use information

We use information we hold (subject to choices you make and applicable law) to operate, provide, improve, understand, customise and support our Services. We market them only as described under "Opting out of marketing", "If you're a commercial contact" and "Promotional banners", and never using payroll data. Here's how:

• Our Services. We use information we hold to operate and provide our Services, including providing customer support; completing purchases or transactions; improving, fixing, and customising our Services.
  • This includes connecting our Services with 1st Money Company Services that you may use.
  • We also use information we hold to understand how people use our Services, to evaluate, improve, and test them, and to troubleshoot. Where we do that we use the least we need, and we don't use anyone's pay, bank details or identifiers for it. We also use your information to respond to you when you contact us.
• Safety, security, and integrity. We use what we hold to verify Accounts and activity, detect fraud and unauthorised access, investigate misuse of payments or filings, and keep the Services secure and lawful, including by investigating suspicious activity or breaches of our Terms. See "Law, our rights, and protection" below.
• Communications about our Services and the 1st Money Companies Group. We use information we hold to communicate with you about our Services and let you know about our terms, policies, and other important updates. We may provide you marketing for our Services and those of the 1st Money Companies Group.
• No third party banner ads. We still don't allow third party banner ads on our Services. We've got no intention to introduce them, but if we ever do, we'll update this notice.

 

Information you and we share

You share your information as you use and communicate through our Services, and we share your information to help us operate, provide, improve, understand, customise, support, and market our Services.

• What you send through the Services. Payslips, notices, messages, and documents you send through the Services reach the people you address them to, and the administrators your Org has given access.
• Information associated with your Account. Anyone in an Org you've joined sees your first name, the first initial of your family name, job title, job grade, portrait, division, department, time zone, work-time status, manager, and managees. Your manager, supervisors, project leaders, and managees also see your last name, phone number, email, and limited contact information. Your admins see more. Pay, bank details and identifiers aren't part of that. Only people your Org gives payroll access can see those, as set out below. Use your settings and the "ghost" feature to manage some of this.
• Your Org. If an Org runs your payroll, it sees the records it needs to run it, including your pay, bank details, and identifiers. It decides who within it can see them. We also give an Org metrics about its own use of our Services.
• Third party service providers. We work with service providers and other Associates of the 1st Money Companies Group to run, support, secure, and market our Services. They provide technical infrastructure and delivery systems, run surveys and research, protect Users, and assist with customer service. We require each to use your information on our behalf, on our instructions and terms.
• Third party services. Where a third party service, or another 1st Money Company Service, is integrated with ours, it may receive what you share with it, and may learn your IP address and that you're a User. Its own terms and privacy policy govern your use of it, not this notice. Your Org chooses which integrations to turn on and can turn them off.

 

How we work with Associates of the 1st Money Companies Group

As part of the 1st Money Companies Group, 1st Money receives information from, and shares information with, the other Associates of the 1st Money Companies Group. The link above says which companies those are and where they're based.

We may use the information we receive from them, and they may use the information we share with them, to help operate, provide, improve, understand, customise, support, and market our Services and their offerings, including the 1st Money Company Services. This includes:

• Helping improve infrastructure and delivery systems.
• Understanding how our Services or theirs are used.
• Promoting safety, security, and integrity across the 1st Money Company Services, e.g., securing systems and fighting spam, threats, abuse, or infringement activities.
• Improving their services and your experiences using them, such as making suggestions for you, personalizing features and Content, helping you complete payments, and showing relevant offers and promotions across the 1st Money Company Services, and;
• Providing integrations which enable you to connect your 1st Money experiences with other 1st Money Company Services. For example, allowing you to connect your 1st Payroll Payments to savings products, by connecting your 1st Money Account.

 

Assignment, change of control, and transfer

In the event that we're involved in the following, we'll share your information with the successor entities. A merger, acquisition, restructuring, bankruptcy, or sale of all or some of our assets. This includes the new owners in connection with the transaction under applicable data protection laws.

 

Where your information goes

Our servers are in Amsterdam, Netherlands. If you're the nominated commercial contact for an organisation that uses our Services, or a business contact we hold as a prospect, we transfer your name, telephone number, email address and marketing preferences to our service centre provider in the Philippines, so its agents can contact you for us. If your employer asks us for help with your payroll, a support agent working for that provider can open your payroll record. They do that to answer the request, and only for that. They can't copy, download or print it, and they see it one person at a time. Email privacy@1st.money for the provider's name.

If your employer buys our Monthly Bookkeeping service, the bookkeeper who does that work is at the same provider. To keep the books they see all of your employer's accounting records, every transaction and the documents behind them. They also see its payroll records in full, for as long as the assignment lasts. Your employer's payroll questions go to them rather than our general support team, which sees none of it. The books are kept in an accounting package rather than our own systems. So we can't switch off its export and print features, and don't claim to; we rely instead on a named account nobody shares, the narrowest role the package offers, and multi-factor login. We also rely on its audit trail, and a contractual ban on taking anything off it. They hold no copy, and access ends with the assignment.

 

How to reach us about your information

You can access and port your information yourself with "Request account info" (Person > More > About), which gives you a machine-readable copy of what we hold about you. You can close your Account with "Decommission & close org" (Org > More > Decommission & close org). If either doesn't give you what you need, email privacy@1st.money.

Email privacy@1st.money about anything in this notice, including a request to see, correct or delete what we hold. We'll verify your identity before we act, and we'll tell you if we can't do what you've asked and why.

 

Marketing choices

We honour an email opt-out within 10 business days, as the CAN-SPAM Act requires, and usually at once. We screen marketing calls against the National Do Not Call Registry and applicable state registries, and against our own internal do-not-call list.

 

Who your information belongs to

If you're an employee or worker whose payroll an Org runs on our Services, that Org decides what to collect and why. It's the controller and we act on its instructions, so send access, correction, and deletion requests to your employer first. We'll help them answer you.

If your Org asks us for help with your payroll, a support agent working for our provider outside the UK can open your payroll record. They do that to answer the request, and only for that. They can't copy, download or print it, and they see it one person at a time. It works differently if your Org buys our Monthly Bookkeeping service. Then your payroll questions go straight to the bookkeeper assigned to your Org, rather than to our general support team. That bookkeeper can see your Org's payroll records at any time, because they keep its books. Nobody on the general support team can see them at all.

You might've signed up yourself, be your organisation's commercial contact, or be someone we hold as a business prospect. In those cases we decide those things, and the rest of this notice applies to you directly.

If you appear in the books of a business that buys our Monthly Bookkeeping service, that business is the controller. The section below explains what that means for you.

 

Who we are

1st Money, Inc. is a Delaware corporation. It's the controller of your personal information for the purposes described under "Who your information belongs to" above. That section also says where your employer is the controller instead. For anything about your information, email privacy@1st.money.

 

Opting out of marketing

You can opt out in any of these ways. Use Settings in the product, where marketing calls, marketing email, and promotional banners are three separate switches you can set independently. Setting one doesn't change the others, so if you want none of it, set all three. Turning banners off turns off every banner we'd otherwise show you, whether it's for something we charge for or something that's free. Use the unsubscribe link in any marketing email, which stops marketing email. Or tell whoever calls you, and they'll end the call and set your marketing calls switch. That one stops the calls. To stop the email and the banners as well, set those switches in Settings, or use the unsubscribe link in any marketing email. Those switches are the only record we keep of your choice. Stopping everything means all three are off, and after that we won't ask you about marketing again.

Your opt-out is recorded against you, not against your organisation. It applies at once in every organisation you belong to that uses our Services, and in any you join later. It stays in force if you stop being your organisation's commercial contact, and if you're appointed again afterwards. We keep that record for as long as it takes to honour it.

 

If you're a commercial contact

An outside adviser an organisation invites into its account, such as its accountant or bookkeeper, counts as one of that organisation's people once they accept. They see what any administrator there sees, and the organisation can name them as its commercial contact. Where it does, everything in this section applies to them the same way, and their organisation for these purposes is the client that invited them. Every organisation using our Services names one person as its commercial contact. That person's name, telephone number and email address appear on the organisation's billing page, visible to its administrators. We contact them about the organisation's plan and about our other services. Any administrator can change who holds the role, and we email the new contact to explain what it means.

 

Promotional banners

We also show promotional banners for our own services inside this product. They're the same for everyone who sees them, and they're not based on your payroll data or on anything you do in the product. Employees and workers see only banners for 1st Money, Inc. tools that are free for them to use. Banners for our paid services appear only to org admins, payroll admins, and the commercial contact. No banner ever appears on a payslip. Turning them off is covered under: "Opting out of marketing"

 

Calls and recording

• What we record. Every call we make to you and every call you make to us, whether it's about marketing or support. That includes calls handled by the provider that answers for us.
• Why. To train our agents, to check they follow our scripts and honour your choices, and to confirm details you give us during the call.
• On a support call. If the request needs it, the agent opens the relevant payroll record while the call is going on, and only for that request. What they see isn't part of the recording.
• How you're told. This notice and our Terms both say so, and we show links to both when an organisation is created and when you accept an invite to join one. If you call us, a recorded message tells you before we connect you.
• When recording starts. The moment the call connects, so that message, and anything an agent says about recording, is inside the recording itself.
• Who carries the call. Our own telephone system records the call on our servers in the Netherlands, and the recording is held nowhere else. Getting the call to and from the public telephone network is done for us by a telecommunications carrier in the U.S. The audio crosses that carrier while the call is happening. They act as our processor under a contract that carries the UK Addendum to the standard contractual clauses, or an equivalent approved mechanism. Email privacy@1st.money for the current one.
• Transcripts. Software turns every recording into a text transcript. We use it for two things and nothing else. First, to confirm automatically that the recording announcement was made. Second, to scan for words that suggest health. Where health came up on a call, we delete the recording and the transcript instead of keeping them. No person reads a transcript to run either check, and "Special category information" says more about the health scan.
• The announcement log. It holds the number called, the date and time, whether the announcement was found, and how confident the software was. Nothing else that was said. We keep it for six years from the date of the call, then delete it.
• Who can listen. Only named people, only for the reasons above.
• If you'd rather not be recorded. We can't run a call without recording it, so tell whoever calls and they'll end the call. You can reach us by email instead.
• How long we keep recordings. Each recording and its transcript for 30 days from the date of the call, then both are deleted. The announcement log is kept for six years, as above. See "Managing and retaining your information" for everything else.

 

AI features

If your Org buys Monthly Bookkeeping, we use AI to help categorise its bank feed and its transactions. Part of that runs on our own servers in Amsterdam, using a model we host ourselves, and nothing leaves for it. The rest is sent to an AI provider in the U.S. to be analysed and sent straight back. Those providers act as our processors under a contract that bars them from training on it. That contract carries the UK Addendum to the standard contractual clauses. We only use providers hosted in the U.S. for this, and we don't use any hosted in China. Which provider we use will change over time, and you can email privacy@1st.money for the current one.

If you use our AI features, we keep a record of the interaction for 30 days. That's so we can support you and investigate problems, then we delete it. We don't use what you type into the AI features to train any model, ours or a provider's. Training on bookkeeping records is separate, and "Training our models" below explains it.

 

Training our models

If an Org buys our Monthly Bookkeeping service, we use its records to train our own models, so the Services get better at categorising and reconciling. The Org instructs us to do that in our Terms, and it can stop it at any time, free, by asking its dedicated bookkeeper, without any change to its price or its Services.

Records are deidentified before anything reaches a training corpus, and nothing that identifies anyone is ever held in it. We drop free-text descriptions, and replace who a payment was to or from with an imaginary counterparty. We replace names, addresses, account numbers, tax and national identifiers with imaginary identifiers. Where a payroll record shows sickness absence we replace it with a general absence first, so nothing about anyone's health is used.

When an Org opts out we take its records out of the corpus right away. They're used in no further training of any model, new or existing. Models we've already released aren't retrained or withdrawn.

We never try to re-identify deidentified data, and anyone we give it to is contractually bound not to either.

 

Talking to your bookkeeper

If your Org buys Monthly Bookkeeping you choose how you reach your bookkeeper, and we record that choice when you join. We ask two things: how you'd like us to reach you with a short question, and how you'd like to hold a longer meeting.

Telephone runs on our own system on our servers in Amsterdam, and those calls are recorded. "Calls and recording" says why, and how long we keep them. Email is hosted by Zoho. The chat inside the product is hosted by tawk.to. Chat and video on WhatsApp, Messenger, Microsoft Teams, Google Meet or Zoom is hosted by whichever of those you pick, and those calls aren't recorded.

We publish no incoming number for bookkeeping. You ask for a call on any channel and we call the number you gave us. So every bookkeeping call is one we placed, to a number you chose.

We keep the chat history inside the product for 90 days, then delete it. Messages you send us on a platform you chose stay in your own account there on that platform's terms, not ours.

Keep records, documents, and anything sensitive inside the product rather than in a chat. We never ask for a password or a bank credential on any channel.

 

Automated decisions

We make no decision about you by automated means alone that produces a legal or similarly significant effect, so Article 22 isn't engaged. Three things run automatically, and none is that kind of decision. Software scans a call transcript for words suggesting health and flags the call for deletion, so it removes information rather than using it. Software checks the same transcript for the recording announcement and logs the finding and a confidence score. That records what was said to you rather than deciding anything about you. And where your Org buys Monthly Bookkeeping, AI suggests a category for each transaction, confident suggestions applied and the rest reviewed by a person. That categorises a transaction rather than a person. Everyone in the same audience sees the same promotional banner, and it isn't chosen using your data or your activity in the product.

 

How long we take

We answer a rights request within one month. If it's complex, or you've made several, we may take up to two more months, and we'll tell you within the first month if that happens. There's no charge, unless a request is clearly unfounded or excessive.

 

What we don't do

We don't sell your information. We don't share it for advertising. We don't use advertising cookies, tracking pixels or third party ad tech. We don't build a profile of you as an individual, and nothing you do in the product decides whether we contact you. We don't buy lists of people's personal contact details. Where we buy business contact data we use it to call a business, never to email one. We don't put adverts on payslips or show them to employees. And we don't use your payroll data to market to you.

 

How we protect your information

We encrypt your information in transit, and restrict access to the people who need it for their work. We grant and remove that access on a recorded basis, and review who holds it. It sits on servers we control in the Netherlands, run for us by a hosting company based in the U.S., and isn't copied anywhere else. No role in the Services lets anyone export, download, copy or print a payroll record. Bookkeeping is different, because it's done in an accounting package rather than our own systems. We can't switch off that package's export and print features, and don't claim to. The protections there are a named account for each bookkeeper that nobody shares, and the narrowest role the package offers. They also include multi-factor login, its audit trail, and a contractual ban on taking anything off it. We assess those measures against the risk as Article 32 requires, and review that every year and on any material change. We record the reasoning where our regulator can ask for it. Our service centre provider reaches your information only through our own systems, holds no copy, and is audited. No system is perfectly secure, so if a breach affects you we'll tell you and the relevant authority where the law requires it.

 

Managing and retaining your information

We keep information for as long as the purposes in this notice need, including to provide the Services, meet legal obligations, enforce our Terms, and protect our rights, property, and Users. How long depends on what the information is, why we hold it, and what the law requires. For marketing we apply these periods:

• Call recordings and their transcripts: 30 days from the date of the call, then both are deleted automatically.
• The recording announcement log: six years from the date of the call, then deleted.
• Marketing switches: kept indefinitely, because that record is what lets us honour your choice.
• Consent asks and your answers: kept for six years, with the version of the wording we used, so we can show what you were asked and what you said.
• Commercial contact records: kept while your organisation holds an account. We stop using them for marketing the moment you stop being the commercial contact.
• Prospect records: deleted when the business declines or the campaign ends, apart from the do-not-contact entry.

For the rest of the Services:

• TimeSpot selfie clock-ins: six months, then deleted automatically. The clock-in and clock-out times remain.
• AI feature interaction records: 30 days, then deleted.
• An invitation to an adviser that's never accepted: we delete the name and email address 90 days after we send it. In the meantime they're used for nothing but delivering that invitation, and never for marketing. Your Org can send a fresh invitation at any time.
• Read-only access after we withdraw a free service: three years from the date we withdraw it, so Your Org can still log in and download its payroll records.

You can access and port your information yourself with "Request account info" (Person > More > About), which gives you a machine-readable copy of what we hold about you. You can close your Account with "Decommission & close org" (Org > More > Decommission & close org). If either doesn't give you what you need, email privacy@1st.money.

If you'd like to further manage, change, limit, or delete your information, do that through the following tools:

• Services settings. You can change your Services settings to manage certain information available to other Users. You can manage your "Follow" list, or use our "Ghost" feature to manage who you communicate with on our Services.
• Changing your mobile number, email, portrait, and contact information. If you change your mobile number, you must update it using our change number feature and transfer your Account to your new mobile number. You can also change your email, portrait, and contact information at any time.
• Deleting your 1st Money Account. You can delete your 1st Money Account at any time using our "Decommission & close org" feature.
  • This includes if you want to revoke your consent to our use of your information pursuant to applicable law. When you delete your 1st Money Account, your undelivered messages are deleted from our servers. We also delete any of your other information we no longer need to operate and provide our Services. You'll be removed from all Orgs where you've received no payments, and marked as deleted in the Orgs where you've received payments.

Deleting the app without using "Decommission & close org" leaves your information with us for longer. Deleting your Account doesn't affect information relating to Orgs you created. Nor does it affect what other Users and Orgs hold about you, such as their copy of your messages or payments they made to you.

 

Law, our rights, and protection

We disclose to an authority only where the law compels it, or where the grounds below apply. We make sure a request is valid, and we disclose the minimum it demands. We tell you unless the law forbids it or there's a risk to someone's safety. We keep a record of every request.

We're a U.S. company, and so is the firm running our servers. So a U.S. authority can in principle demand information from either of us, even though the servers are in the Netherlands. We hand nothing over voluntarily and need a legally binding demand, properly served. A demand might come from a country other than the one whose law protects your information. We check first whether it rests on a treaty between the two. A foreign court order isn't reason enough on its own. We push back on anything too wide, give the least the demand compels, and tell you unless forbidden. Where forbidden we ask to be released, and record that we asked. Nobody answers a demand alone: our Chief Executive Officer decides. One thing we can't promise is that we'll know. If a demand goes to the company running our servers rather than to us, it isn't obliged to tell us.

 

How long we keep things

Where an Org's Services have ended, we keep its data for 30 days so it can export it. We then delete it on the same basis as any other closure.

We keep payroll and tax records for as long as federal and state law requires. That's generally four years for federal employment tax records under IRS rules, and longer in some states. We keep accounting records for seven years. Apart from the records that let us honour your opt-out, which we keep indefinitely, we don't keep your information longer than those periods require.

 

Sensitive information

We collect information that some state laws treat as sensitive, including bank account details and government identifiers such as Social Security numbers. Payroll can't be run without them. We use it only to provide the Services, and never to infer anything about you or for advertising. We don't sell it, and we don't share it for cross-context behavioral advertising.

Social Security numbers, financial account numbers, and precise geolocation never enter our model training corpus.

Deidentified data. Where we deidentify an Org's bookkeeping records to train our models, we keep technical measures that prevent the data being linked back to anyone. We publicly commit not to re-identify it or attempt to. We require the same by contract from anyone we give it to. We don't sell deidentified data and we don't use it for advertising.

We don't ask about anyone's health on a call. If it comes up, our agent says so and stops. Software scans every call transcript for words that suggest health and flags the call, and we delete that recording and transcript rather than keep them. Nobody reads the transcript to do this.

 

Your state privacy rights

Depending on where you live, state privacy law may give you the right to know what personal information we hold. It may also let you correct or delete it, and obtain a copy. It may let you opt out of targeted advertising, and of any sale or sharing of your personal information. We don't sell your personal information, and we don't share it for cross-context behavioral advertising.

To exercise any of these, email privacy@1st.money. We won't discriminate against you for doing so. If we refuse a request we'll tell you why, and you can appeal by replying to that decision.

 

When we disclose to an authority

We access, preserve, and share your information described in the "Information we collect" section, if we believe in good faith that it's necessary to:

• Respond pursuant to applicable law or regulations, legal process, or government requests.
• Enforce our Terms and any other applicable terms and policies, including for investigations of potential violations.
• Detect, investigate, prevent, or address fraud and other illegal activity or security, and technical issues, or;
• Protect the rights, property, and safety of our Users, 1st Money, the 1st Money Companies Group, or others, including to prevent death or imminent bodily harm.

 

Our global operations

1st Money shares information globally, both internally in the 1st Money Companies Group, and externally with our partners and service providers, and with those with whom you communicate around the world, under this notice and our Terms.

Your information may be transferred to, or stored and processed in, the U.S., the Netherlands, the country where our service centre provider operates, or any country where an Associate of the 1st Money Companies Group, a partner or a service provider operates. These transfers are necessary to provide the Services set out in our Terms. Those countries may have different privacy laws from your own.

 

Updates to our policy

We may amend or update this notice. We'll tell you before a material change takes effect, and say what changed. Where a change means using your information for a new purpose, we'll tell you before that starts. This version took effect on 5 Sep 2026, and the "Last revised" date at the bottom shows the same.

 

Contact us

Email privacy@1st.money for anything about your information or this notice. Write to us at 1st Money, Inc., 1207 Delaware Ave #1996, Wilmington, DE 19806, USA.

If you've got questions about this notice, please contact us or write to us here:

1st Money
Attn: Privacy Notice
1207 Delaware Ave #1996, Wilmington, DE 19806, USA.

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© 2020–2026 1st Money, Inc. All rights reserved. Last revised 5 Sep 2026. Retrieved 6 Nov 2026.