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1st Money Privacy Notice

Hi! You're reading 1st Money's Privacy Notice. We take the private nature of your personal information very seriously.

This notice describes how we treat the information we collect when you visit and use our websites. You should read this carefully before you use 1st Money. If you've got any questions or suggestions, feel free to contact 1st Money's free support ... Mon-Fri, 8 am to 4 pm, UK time.


 

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If you DO live in the UK, or EEA region, 1st Money UK Holdings Ltd, 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 all other countries".

We're one Associate of the 1st Money Companies Group.

Respect for your privacy is coded into our DNA. Since we started 1st Money, we've built our Services with a set of strong privacy principles in mind.

This Privacy 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 Privacy 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 in accordance with a legal basis. This also includes giving you control over who you communicate with on our Services.

This Privacy Notice applies to all of our Services unless specified otherwise.

 

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.

 
  • 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.
  • 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 communicate with 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).
 
  • Usage and log information. We collect information about your activity on our Services, like service-related, diagnostic, and performance information. This includes information about your activity (including how you use our Services, your Services settings, how you interact with others using our Services (including when you interact with Your Orgs), and the time, frequency, and duration of your activities and interactions), log files, and diagnostic, crash, website, and performance logs and reports. This also includes information about when you registered to use our Services, the features you use, 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 Products associated with the same device or Account).
  • Cookies. We use cookies to operate and provide our Services, including to provide our Services that are web-based, app based, and installation based, to improve your experiences, understand how our Services are being used, and customise them. We may also use cookies to understand which of our Help articles are most popular and to show you relevant Content related to our Services. Additionally, we may use cookies to remember your choices, like your language preferences, to provide a safer experience, and otherwise to customise our Services for you.
 
  • Information others provide about you. We receive information about you from other Users. These Users include other Users you know, including in an Org that you belong to, or that are invited. When these Users use our Services, they may provide your information, as you may provide theirs. This information may include phone number, name, and other information (like information from their company HR systems). They may also send you messages to invite you to join their Org, or to invite you to apply for a job opening. We require each of these Users to have lawful rights to collect, use, and share your information before providing any information to us.
  • 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 in accordance with applicable law when providing any information to us.
    • When you join an Org on 1st Money, it's important to keep in mind that the Content you share may be visible to several people in that Org. In addition, some Orgs might be working with third party service providers (which may include other Associates of the 1st Money Companies Group) to help manage their operations with their employees. For example, an Org may give such third party service provider access to its payroll. This may be to send, store, read, manage, or otherwise process tax information for the Org.
  • Third party service providers. We work with third party service providers and other Associates of the 1st Money Companies Group to help us operate, provide, improve, understand, customise, support, and market our Services. For example, we work with them to distribute our apps; provide our technical and physical infrastructure, delivery, and other systems; provide engineering support, cybersecurity support, and operational support; process payments; help us understand how people use our Services; market our Services; help you connect with Orgs using our Services; conduct surveys and research for us; make sure safety, security, and integrity; and help with customer service. These companies may provide us with information about you in certain circumstances. For example, app stores may provide us with reports to help us diagnose and fix service issues.
    • 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. We allow you to use our Services in connection with third party services and 1st Money Company Products. If you use our Services with such third party services or 1st Money Company Products, we may receive information about you from them. For example, if Your Org turns on an integration to automatically share payroll transactions with an external accounting system or tax authority. Please note that when you use third party services or 1st Money Company Products, their own terms and privacy policies will govern your use of those services and products.
 

We use information we've got (subject to choices you make and applicable law) to operate, provide, improve, understand, customise, support, and market our Services. Here's how:

  • Our Services. We use information we've got 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've got to understand how people use our Services; evaluate and improve our Services; research, develop, and test new services and features; and conduct troubleshooting activities. We also use your information to respond to you when you contact us.
  • Safety, security, and integrity. Safety, security, and integrity are an integral part of our Services. We use information we've got to verify Accounts and activity; combat harmful conduct; protect Users against bad experiences and spam; and promote safety, security, and integrity on and off our Services, such as by investigating suspicious activity or violations of our Terms and policies, and to make sure our Services are being used legally. Please see the "Law, our rights, and protection" section below for more information.
  • Communications about our Services and the 1st Money Companies Group. We use information we've got 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.
    • Please see the "How you exercise your rights" section for more information.
  • 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 Privacy Notice.
 

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.

  • Send your information to those with whom you decide to communicate. You share your information (including messages) as you use and communicate through our Services.
  • Information associated with your Account. The following information is available to anyone who belongs to an Org you've joined. Your first name, first initial of your family name, job title, job grade, portrait photo, division, department, time zone, work-time status, manager, and managees. Additional information, like last name, phone number, email, and limited contact information will be available to your manager, supervisors, project leaders and managees. Other additional information is available to your admins. You can use your Services settings and the "ghost" feature to manage certain information you share.
  • Orgs on 1st Money. We offer specific Services and features to Orgs such as providing them with metrics regarding their use of our Services.
  • Third party service providers. We work with third party service providers and other Associates of the 1st Money Companies Group to help us operate, provide, improve, understand, customise, support, and market our Services. We work with these companies to support our Services, such as to provide technical infrastructure, delivery and other systems; market our Services; conduct surveys and research for us; protect the safety, security, and integrity of Users and others; and assist with customer service. When we share information with third party service providers and other Associates of the 1st Money Companies Group in this capacity, we require them to use your information on our behalf in accordance with our instructions and terms.
  • Third party services. When you or others use third party services or other 1st Money Company Products that are integrated with our Services, those third party services may receive information about what you or others share with them. For example, if you use the mortgage search service integrated with our Services, they'll receive information you share with them, such as your search preferences. If you interact with a third party service or other 1st Money Company Products linked through our Services, information about you, like your IP address and the fact that you're a 1st Money User, may be provided to such third party or other 1st Money Company Products. Please note that when you use third party services or other 1st Money Company Products, their own terms and privacy policies will govern your use of those services and products.
 

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

1st Money also works, and shares information with, the other Associates of the 1st Money Companies Group who act on our behalf to help us operate, provide, improve, understand, customise, support, and market our Services. This includes the provision of infrastructure, technology, and systems, e.g., for providing you with reliable payday payments; improving infrastructure and delivery systems; understanding how our Services are used; helping us provide a way for you to connect with Orgs; and securing systems. When we receive services from other Associates of the 1st Money Companies Group, the information we share with them is used on 1st Money's behalf and in accordance with our instructions.

 

Under applicable data protection law, companies must have a legal basis to process data. We rely on different legal bases to process your data for the various purposes described in this Privacy Notice. As explained below, depending on the circumstances, we may rely on different legal bases when processing your data for the same purpose. For each legal basis below, we describe the purposes of our processing (why we process your information). We also describe our processing operations (how we process your data, e.g., we collect information from you and use it to create your Account). We also list the categories of your data that we process for each purpose.

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:

  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 in accordance with 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 (or others') legitimate interests, including our interests in providing an innovative, relevant, safe, and profitable service to our Users and partners. This applies, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data. For example, to prevent our Services being used for harmful or illegal activity. Learn more in 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.

 

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

 

We process the data we've got about you (as described in the "Information we collect" section) as necessary to perform our contract with you (the Terms). The categories of data we process will depend on the data you decide to provide and the manner in which you use our Services. This also determines the information we collect automatically, and the information Your Orgs are likely to provide. The processing purposes necessary to provide our contractual services are:

Why and how we process your data:

  • To operate, provide, improve, customise, and support our Services as described in the "About our Services" section of our Terms which includes providing ways for you to connect and communicate with other 1st Money Users, including Orgs. This includes collecting information from you to create a 1st Money Account, connecting you with Orgs reachable via 1st Money, analysing your use of our Services, providing customer support in response to an issue or deleting your data if you decide to close your Account.
    • Data categories used. We use information described in the "Information you provide," "Automatically collected information," and "Third party information" sections of this Privacy Notice for this purpose.
  • To make sure of the safety, security, and integrity of our Services. This could involve verifying the data you've provided when you created an Account. This could also involve analysing suspicious activity in connection with your Account to prevent our Services from being used illegally. We use system data to make sure of the safety and security of our Services, which includes their availability, authenticity, integrity and confidentiality, and in particular the prevention, detection, investigation and remediation of security incidents, vulnerabilities, malware and factors that could negatively affect the availability of our Services such as spam or enable unauthorised access to or use of the Services or User devices.
    • Data categories used. We use information described in the "Information you provide," "Automatically collected information," and "Third party information" sections of this Privacy Notice for this purpose.
  • To transfer, or transmit to, store or process your data in third countries, which may include the United States and other countries or territories. This is explained under the "Our global operations" section.
    • Data categories used. We use information described in the "Information you provide," "Automatically collected information," and "Third party information" sections of this Privacy Notice for this purpose.
  • 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.
    • Data categories used. We use information described in the "Information you provide" section of this Privacy Notice for this purpose.
  • Each of these purposes is explained in more detail, under the "How we use information" and "Our global operations" sections. When we process data you provide to us as necessary to perform our contractual relationship with you under the GDPR, you've got rights. This includes the right to port your data. To exercise your rights, visit the "How you exercise your rights" section of this Privacy Notice.
 

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.

  • Data categories used. We use device information, for this purpose.
  • When we process data based on your consent, you've got the right to withdraw your consent at any time. Your withdrawal of consent doesn't affect the lawfulness of processing based on such consent before the consent is withdrawn. You also have the right to port data you provide to us and that we process based on your consent. To exercise your rights, visit the "How you exercise your rights" section of this Privacy Notice.
 

Why and how we process your data. For processing data when we comply with a legal obligation. This includes, for example, if there's a valid legal request for certain data. A valid legal request includes as an order from law enforcement to provide data in relation to an investigation. This data may include your name, portrait or IP address. We'll disclose data pursuant to the legal obligation. As a platform with payroll data storage features, and in consideration of a request for deletion, 1st Money may be legally required to keep payroll records gov.uk, and accounting records gov.uk.

  • Data categories used. The information we use for this processing varies depending on the circumstances, but it generally consists of information described in the "Information you provide" and "Automatically collected information" sections of this Privacy Notice.
 

Why and how we process your data. For processing data for protecting your vital interests or those of another person. The vital interests we rely on for this processing include protection of your life, physical integrity, or safety, or that of others. We rely on it to combat harmful conduct and to promote safety, security and integrity. This includes, for example, when we're investigating reports of harmful conduct or when someone needs help. This could include the promotion of safety, security, and integrity by providing law enforcement with data. This includes in the event of an emergency where it's requested and is necessary to protect a person's life or safety. For example, where there's a risk of imminent harmful conduct such as an attack or where a person's safety is at risk.

  • Data categories used. The information we use for this processing varies depending on the circumstances, but it generally consists of information described in the "Information you provide" and "Automatically collected information" sections of this Privacy Notice.
 

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 providing measurement, analytics, and other Org Services where we're processing data as a controller.
    • Legitimate interests relied on:
      1. To provide accurate and reliable aggregated reporting to Orgs and other partners. To make sure of the accurate statistics on performance. To demonstrate the value our partners realise using our Services.
      2. In the interests of Orgs and other partners to help them understand their employees and customers. To improve their Orgs, and evaluate the effectiveness and distribution of their payroll, HR, and other services. To understand how people interact with them on our Services.
    • Data categories used. We use information described in the "Information you provide," "Automatically collected information," and "Third party information" sections of this Privacy Notice for these purposes.
  2. For providing marketing communications to you.
    • Legitimate interests relied on. The legitimate interests we rely on for this processing are: To promote 1st Money Company Products and send direct marketing.
    • Data categories used. We use information described in the "Information you provide," "Automatically collected information," and "Third party information" sections of this Privacy Notice for this purpose.
  3. 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 Products, 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.
    • Data categories used. We use information described in the "Information you provide," "Automatically collected information," and "Third party information" sections of this Privacy Notice for this purpose.
  4. 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 Products.
    • Data categories used. We use information described in the "Information you provide," "Automatically collected information," and "Third party information" sections of this Privacy Notice for this purpose.

You've got the right to object to, and seek restriction of, such processing; to exercise your rights, visit the "How you exercise your rights" section of this Privacy Notice.

 

Why and how we process your data. For assisting in tax collection and reporting, undertaking research and to promote safety, security, and integrity as described in more detail under the "How we use information" section, where this is necessary in the public interest, as further specified by applicable law (e.g., in European Union law) and in consideration that "Taxation is a vital resource for governments to achieve their public service agenda". ActionAid 2011; HM Revenue and Customs (HMRC) 2015; Isbister 1968

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

  • Data categories used. The information we use for this processing varies depending on the circumstances, but it might be comprised of information described in the "Information you provide" and "Automatically collected information" sections of this Privacy Notice.
  • 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 Privacy Notice.
 

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

This includes the right to object to our processing of your information for direct marketing. It also includes the right to object to our processing of your information where we're doing one of the following. (1) Performing a task in the public interest. (2) Pursuing our legitimate interests or those of a third party. We'll consider several factors when assessing an objection including: our Users' reasonable expectations; the benefits and risks to you, us, other Users, and third parties; and other available means to achieve the same purpose that may be less invasive and don't require disproportionate effort. Your objection will be upheld, and we'll cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons.

You can object to our processing of your information. Where we use your information for direct marketing, you can always object and opt out of future direct marketing messages. You can do this by using the unsubscribe link in such communications.

You can access or port your information using our "Request account info" feature (available under Person > More > About). You can delete your Account by clicking the "Delete my account" feature (available under Person > More > About).

When we process data you provide to us based on your consent, you've got the right to withdraw your consent at any time. Such withdrawal won't affect the lawfulness of processing based on consent before its withdrawal.

You've got the right to lodge a complaint with 1st Money's lead supervisory authority, the Hungarian National Authority for Data Protection and Freedom of Information (NAIH), or any other competent data protection supervisory authority.

 

We store information for as long as necessary for the purposes identified in this Privacy Notice, including to provide our Services, or for other legitimate purposes, such as complying with legal obligations, enforcing and preventing violations of our Terms, or protecting or defending our rights, property, and Users. The storage periods are determined on a case-by-case basis that depends on various factors. These factors include the nature of the information, why it's collected and processed, relevant legal or operational retention needs, and legal obligations.

  1. Legal obligations and issues. For example, we also keep your information for legal reasons such as when we've got a legal obligation to retain data, to enforce and prevent violations of our Terms or if necessary to protect rights, property and Users. Our "Law, our rights, and protection" section provides more information on this. 1st Money may be legally required to keep payroll records for three years gov.uk, and accounting records for six years gov.uk. No purpose in this Privacy Notice will require us keeping your personal information for longer than seven (7) years. The seven (7) years is measured from the end of the last company financial year of termination of the User's Account. Many countries require businesses to keep tax and accounting records for 6 years from the end of the last company financial year.
  2. Operational retention needs. For example, we don't retain your messages when providing our Services (except in the limited circumstances set out above), and so once your messages are delivered they're deleted from our servers. However, as stated above, if a message can't be delivered immediately, we keep it on our servers for up to 30 days. During this time we'll try to deliver it, after which it's deleted. 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 "Delete my account" 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).
 

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

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. 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.

 
  • In certain circumstances, in order 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've got 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.

Be mindful that if you only delete our app from your device (without using our "Delete my account" feature), your information will be stored with us for a longer period. Please remember that when you delete your Account, it doesn't affect your information related to the Orgs you created. It also doesn't affect the information other Users or Orgs have relating to you. For example, their copy of the messages you sent them, or payments they've made to you.

 

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 in accordance with the "Our legal basis for processing data" section if we've got a good-faith belief 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 in accordance with the Terms", "Legitimate interests" and "Protection of your vital interests, or those of another person" headings.

 

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, in accordance with this Privacy Notice and our Terms.

Information controlled by 1st Money may be transferred or transmitted to, or stored and processed in, the United States or other third countries outside of where you live for the purposes described in this Privacy Notice. 1st Money uses 1st Money's global infrastructure and data centres, which may include in the United States.

These transfers are necessary and essential to enable us to provide the Services set forth in our Terms and globally to operate and provide our Services to you. For transfers to third countries, we utilise standard contractual clauses approved by the European Commission (see an explanation of what these are here), or rely on the European Commission's adequacy decisions about certain countries. Through these adequacy decisions, the European Commission recognises the following. That a third country, territory, or one or more specified sectors in that third country make sure of protections. Namely, an adequate level of protection, or use equivalent mechanisms provided under applicable data protection law, as applicable. For data transfers from the European Economic Area to the United States, we rely on standard contractual clauses.

 

We may amend or update this Privacy Notice. We'll provide you notice of amendments to this Privacy Notice, as appropriate, and update the "Last revised" date (at the bottom of this Privacy Notice). Please review this Privacy Notice from time to time.

 

The Data Protection Officer for 1st Money can be contacted here.

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

1st Money
Attn: Privacy Notice
71 Fort Street, George Town, KY1-1111, Cayman Islands


© Copyright 2020–2024 1st Money UK Holdings Ltd. All rights reserved. Last revised 2 Jul, 2020. Retrieved 19 Mar, 2024.











 

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

Respect for your privacy is coded into our DNA. Since we started 1st Money, we've built our Services with a set of strong privacy principles in mind.

This Privacy 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 Privacy 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 in accordance with a legal basis. This also includes giving you control over who you communicate with on our Services.

Learn more, below, in this Privacy Notice about the ways in which we share information across this Companies Group.

This Privacy Notice applies to all of our Services unless specified otherwise.

 

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.

 
  • 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.
  • 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 communicate with 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).
 
  • Usage and log information. We collect information about your activity on our Services, like service-related, diagnostic, and performance information. This includes information about your activity (including how you use our Services, your Services settings, how you interact with others using our Services (including when you interact with Your Orgs), and the time, frequency, and duration of your activities and interactions), log files, and diagnostic, crash, website, and performance logs and reports. This also includes information about when you registered to use our Services, the features you use, 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 Products associated with the same device or Account).
  • Cookies. We use cookies to operate and provide our Services, including to provide our Services that are web-based, app based, and installation based, to improve your experiences, understand how our Services are being used, and customise them. We may also use cookies to understand which of our Help articles are most popular and to show you relevant Content related to our Services. Additionally, we may use cookies to remember your choices, like your language preferences, to provide a safer experience, and otherwise to customise our Services for you.
 
  • Information others provide about you. We receive information about you from other Users. These Users include other Users you know, including in an Org that you belong to, or that are invited. When these Users use our Services, they may provide your information, as you may provide theirs. This information may include phone number, name, and other information (like information from their company HR systems). They may also send you messages to invite you to join their Org, or to invite you to apply for a job opening. We require each of these Users to have lawful rights to collect, use, and share your information before providing any information to us.
  • 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 in accordance with applicable law when providing any information to us.
    • When you join an Org on 1st Money, it's important to keep in mind that the Content you share may be visible to several people in that Org. In addition, some Orgs might be working with third party service providers (which may include other Associates of the 1st Money Companies Group) to help manage their operations with their employees. For example, an Org may give such third party service provider access to its payroll. This may be to send, store, read, manage, or otherwise process tax information for the Org.
  • Third party service providers. We work with third party service providers and other Associates of the 1st Money Companies Group to help us operate, provide, improve, understand, customise, support, and market our Services. For example, we work with them to distribute our apps; provide our technical and physical infrastructure, delivery, and other systems; provide engineering support, cybersecurity support, and operational support; process payments; help us understand how people use our Services; market our Services; help you connect with Orgs using our Services; conduct surveys and research for us; make sure safety, security, and integrity; and help with customer service. These companies may provide us with information about you in certain circumstances. For example, app stores may provide us with reports to help us diagnose and fix service issues.
    • 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. We allow you to use our Services in connection with third party services and 1st Money Company Products. If you use our Services with such third party services or 1st Money Company Products, we may receive information about you from them. For example, if Your Org turns on an integration to automatically share payroll transactions with an external accounting system or tax authority. Please note that when you use third party services or 1st Money Company Products, their own terms and privacy policies will govern your use of those services and products.
 

We use information we've got (subject to choices you make and applicable law) to operate, provide, improve, understand, customise, support, and market our Services. Here's how:

  • Our Services. We use information we've got 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 Products that you may use.
    • We also use information we've got to understand how people use our Services; evaluate and improve our Services; research, develop, and test new services and features; and conduct troubleshooting activities. We also use your information to respond to you when you contact us.
  • Safety, security, and integrity. Safety, security, and integrity are an integral part of our Services. We use information we've got to verify Accounts and activity; combat harmful conduct; protect Users against bad experiences and spam; and promote safety, security, and integrity on and off our Services, such as by investigating suspicious activity or violations of our Terms and policies, and to make sure our Services are being used legally. Please see the "Law, our rights, and protection" section below for more information.
  • Communications about our Services and the 1st Money Companies Group. We use information we've got 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 Privacy Notice.
 

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.

  • Send your information to those with whom you decide to communicate. You share your information (including messages) as you use and communicate through our Services.
  • Information associated with your Account. The following information is available to anyone who belongs to an Org you've joined. Your first name, first initial of your family name, job title, job grade, portrait photo, division, department, time zone, work-time status, manager, and managees. Additional information, like last name, phone number, email, and limited contact information will be available to your manager, supervisors, project leaders and managees. Other additional information is available to your admins. You can use your Services settings and the "ghost" feature to manage certain information you share.
  • Orgs on 1st Money. We offer specific Services and features to Orgs such as providing them with metrics regarding their use of our Services.
  • Third party service providers. We work with third party service providers and other Associates of the 1st Money Companies Group to help us operate, provide, improve, understand, customise, support, and market our Services. We work with these companies to support our Services, such as to provide technical infrastructure, delivery and other systems; market our Services; conduct surveys and research for us; protect the safety, security, and integrity of Users and others; and assist with customer service. When we share information with third party service providers and other Associates of the 1st Money Companies Group in this capacity, we require them to use your information on our behalf in accordance with our instructions and terms.
  • Third party services. When you or others use third party services or other 1st Money Company Products that are integrated with our Services, those third party services may receive information about what you or others share with them. For example, if you use the mortgage search service integrated with our Services, they'll receive information you share with them, such as your search preferences. If you interact with a third party service or other 1st Money Company Products linked through our Services, information about you, like your IP address and the fact that you're a 1st Money User, may be provided to such third party or other 1st Money Company Products. Please note that when you use third party services or other 1st Money Company Products, their own terms and privacy policies will govern your use of those services and products.
 

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.

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 Products. 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 Products, 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 (for example, of mortgage offers, or savings products), personalizing features and Content, helping you complete payments, and showing relevant offers and promotions across the 1st Money Company Products, and;
  • Providing integrations which enable you to connect your 1st Money experiences with other 1st Money Company Products. For example, allowing you to connect your 1st Payroll Payments to savings products, by connecting your 1st Money Account.
 

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 in accordance with applicable data protection laws.

 

We store information for as long as necessary for the purposes identified in this Privacy Notice, including to provide our Services, or for other legitimate purposes, such as complying with legal obligations, enforcing and preventing violations of our Terms, or protecting or defending our rights, property, and Users. The storage periods are determined on a case-by-case basis that depends on various factors. These factors include the nature of the information, why it's collected and processed, relevant legal or operational retention needs, and legal obligations.

You can access or port your information using our "Request account info" feature (available under Person > More > About). You can delete your Account by clicking the "Delete my account" feature (available under Person > More > About).

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 "Delete my account" 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.

Be mindful that if you only delete our app from your device (without using our "Delete my account" feature), your information will be stored with us for a longer period. Please remember that when you delete your Account, it doesn't affect your information related to the Orgs you created. It also doesn't affect the information other Users or Orgs have relating to you. For example, their copy of the messages you sent them, or payments they've made to you.

 

We access, preserve, and share your information described in the "Information we collect" section, if we've got a good-faith belief 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.
 

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, in accordance with this Privacy Notice and our Terms.

Your information may, for example, be transferred or transmitted to, or stored and processed in, the United States; countries or territories where other Associates of the 1st Money Companies Group, Associates and partners, or our service providers are located; or any other country or territory globally where our Services are provided outside of where you live for the purposes as described in this Privacy Notice. 1st Money uses 1st Money's global infrastructure and data centres, which may include in the United States. These transfers are necessary to provide the global Services set forth in our Terms. Please keep in mind that the countries or territories to which your information is transferred may have different privacy laws and protections. It may be different to what you've got in your home country or territory.

 

We may amend or update this Privacy Notice. We'll provide you notice of amendments to this Privacy Notice, as appropriate, and update the "Last revised" date (at the bottom of this Privacy Notice). Please review this Privacy Notice from time to time.

 

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

1st Money
Attn: Privacy Notice
71 Fort Street, George Town, KY1-1111, Cayman Islands


© Copyright 2020–2024 1st Money UK Holdings Ltd. All rights reserved. Last revised 2 Jul, 2020. Retrieved 19 Mar, 2024.










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