Privacy Policy

Sample description

Privacy at Incard

Hi, we are Incard, a financial hub for digital entrepreneurs. We are a technology company and we provide a platform through which customers may access a variety of financial products and services offered by our partners, licensed issuers and us. We want to build a long-lasting relationship based on trust with you, so we have prepared a clear and transparent document about how we use your personal information.

Your privacy is important to us, your personal data belongs to you and you have the right to understand and control how it’s used.

We are committed to protecting and respecting your privacy.

We will:

If you have any queries about this Privacy Policy or how we may collect, store or use your data, please contact us by email at dpo@incard.co.

Who we are

Incard is your Data Controller

Incard is the Data Controller of your data, which means we’re responsible for your personal data processed in relation to your use of the products and services accessible via the Incard Platform.

Incard is a group made up of different companies:

When you visit our website www.incard.co and/or receive services via the Incard Platform we collect, process, use and are responsible for certain personal data about you.

When we do so,

For the purposes of these laws we are responsible as a ‘Data Controller’ for the processing of your personal data.

Incard is also your Data Processor in some cases

When using some of our services and products, like the Visa Card, Incard is a ‘Data Processor’ and our Card Issuer is a ‘Data Controller’ which means we process personal data solely for the purposes of providing you with the Incard Card issued by Transact Payments Limited.

Also when we process personal data you provide to us that is related to other individuals (such as your employees or customers), we may be acting as a Data Processor. In this case Incard is a ‘Data Processor’ and you are a ‘Data Controller’, which means we process personal data solely for the purposes of providing you with our Incard Products and Services and based on your instructions.

In particular, when you engage with Incard Products and Services, or those of our partners, Incard will likely be acting as a Data Processor of that data.

Your personal data held in our database will be stored on the servers of our hosting service providers and the hosting services providers of our services providers. Incard Ltd is managing the hosting environment for incard iOS App and incard Web App and is hence a processor of the organisation which uses incard products.

Incard engaged Amazon Web Services Inc. as sub-processor in order to provide certain cloud services. Its servers are located in eu-west-2, Europe (London).

What personal information we collect and how we use it

The types of personal data we collect may vary from person to person. It depends on the relationship we have with you, whether you are simply visiting our site or have an account with us and are using all of our features.

1. For visitors to our Website2
What personal information we collect about you

To improve and grow our business, including our website, and to understand our customer’s needs, desires and requirements, we or the third party on our behalf will collect the following information about you:

How we use your personal information

We use the data collected from you to understand how customers and visitors to our website use the website and interact with it via data analysis.

A word about cookies

We may also receive Website, Device and Technical Information automatically from technologies such as cookies that are installed on our website. The information created and recorded automatically when you visit our Website (please refer to the definition of Automated decision making and the Cookie Policy).

2. For customers and users of our Service
What personal information we collect about you

To open and operate your incard account, we, or third parties on our behalf, may collect and use any of the following:

How we use your personal information

We collect your personal information to:

Source of personal information

We collect personal data from you when you:

We also collect personal data from a number of different third parties, including our service partners (please referring to Schedule 2 - Data collect from and/or share to Parties).

Information we need to provide Services to you

We need certain types of personal information (please referring to Schedule 3 - Types of personal information) for the purpose of providing services to you and perform contractual and other legal and regulatory obligations that we have (please referring to Schedule 4 - Using personal information by legal reason(s)). If you do not provide us with such personal information, or if you ask us to delete it, you may no longer be able to access our services.

3. For prospective customers and people who contact us with enquiries
What personal information we collect about you

In order to improve and grow our business, including our website, and to understand our customer’s needs, desires and requirements, we or the third party on our behalf will collect the following information about you:

How we use your personal information

We collect your personal information to:

Source of personal information

We collect personal data from you when you:

We also collect personal data from a number of different third parties, including our service partners (please referring to Schedule 2 - Data collect from and/or share to Parties).

4. For our suppliers and employees of our suppliers who work for us
How we use your personal information

We will collect, use and store the personal information mentioned in Schedule 3:

Source of personal information

We collect and obtain your personal information from yourself, our partners and vendors, and third party sites. Depends on the relationship between you and us, we collect different kinds of your personal information as necessarily. For example, our website may contain links to third-party websites. If you click and follow those links, then these will take you to the third-party website. Those third-party websites may collect personal information from you and you will need to check their privacy notices to understand how your personal information is collected and used by them.

Information we need to provide Services to you

We need certain types of your personal information to provide a service to you, to fulfil the contractual, legal and legislative obligations that we have. If you do not provide us with the necessary information or you request to delete it, we cannot provide services to you and you may no longer to access the services.

Keeping your information up to date

It is important that you keep your personal information up to date. If any of your personal information changes, please contact us as soon as possible to let us know. If you do not do this, then we may be prevented from supplying the services to you.

We will use reasonable efforts to ensure that your personal data is accurate, complete and up-to-date. Please ensure you notify us without undue delay of any changes to the personal data that you have provided to us by updating your details on the Incard Platform or by contacting us in our in-app chat or at the details provided in this Privacy Policy.

We may share anonymised data

Sometimes we may anonymise personal information so that you can no longer be identified from it and use this for our own purposes. In addition, sometimes we may use some of your personal information together with other people’s personal information to give us statistical information for our own purposes. Because this is grouped together with other personal information and you are not identifiable from that combined data we are able to use this.

We may transfer your personal data outside the UK and the EEA

If any transfer of personal information by us will mean that your personal information is transferred outside of the EEA, then we will ensure that safeguards are in place to ensure that a similar degree of protection is given to your personal information as is given to it within the EEA and that the transfer is made in compliance with data protection laws (including, where relevant, any exceptions to the general rules on transferring personal information outside of the EEA that are available to us – these are known as ‘derogations’ under data protection laws). We may need to transfer personal information outside of the EEA to other organisations within our group or to the third parties listed in Schedule 2 who may be located outside of the EEA.

How we will retain and delete your personal data
Your rights under data protection laws
How do we protect your personal data?

incard understands the importance of safeguarding and maintaining your personal information. We will treat any personal data we process with the greatest care and security. This section explains some of the safeguards we have in place.

How to contact us and How to complain?
Our Key Partners

How to withdraw your consent or Opt-out of Processing?

You can withdraw your consent to our processing of your data at any time. Please contact us if you want to do so at support@incard.co.

This will only affect the way we use data when our basis for processing your data is your consent. See the section ‘Your Rights’ and more specifically your right to restricting use of your data.

You may also opt out of some forms of data processing we are conducting, such as:

If you withdraw your consent and/or opt-out, we may not be able to provide certain products or services to you. If this is so, we will tell you. You then have the option to give us your consent again if you want to access our products or services.

Schedule 1 - Key Definitions

Data Protection Laws: the Data Protection Act 2018 (UK) and the General Data Protection Regulation ((EU) 2016/679) (the GDPR) and such other laws as may be applicable from time to time, including any replacements.

GDPR: the General Data Protection Regulation ((EU) 2016/679).

Data Controller: under UK data protection law, this is the organisation or person responsible for deciding how personal information is collected and stored and how it is used.

Data Processor: a Data Controller may appoint another organisation or person to carry out certain tasks in relation to the personal information on behalf of, and on the written instructions of, the Data Controller. (This might be the hosting of a site containing personal data, for example, or providing an email-marketing service that facilitates mass distribution of marketing material to a Data Controller’s customer base.)

Personal Information: in this privacy notice, we refer to your personal data as ‘personal information’. ‘Personal information’ means any information from which a living individual can be identified. It does not apply to information that has been anonymised.

Special Information: certain very sensitive personal information requires extra protection under data protection law. Sensitive data includes information relating to health, racial and ethnic origin, political opinions, religious and similar beliefs, trade union membership, sex life and sexual orientation and also includes genetic information and biometric information.

Automated Decision Making: A decision is automatically made without any human involvement. Under data protection laws, this includes profiling. ‘Profiling’ is the automated processing of personal data to evaluate or analyse certain personal aspects of a person (such as their behaviour, characteristics, interests and preferences). Data protection laws place restrictions upon us if we carry out any automated decision making (including profiling) that produces a legal effect or similarly significant effect on you. We do not carry out any automated decision making (including profiling) that produces a legal effect or similarly significant effect on you. If we do decide to do this then we will notify you and we will inform you of the legal reason we are able to do this.

Marketing: You may receive marketing from us about similar goods and services, where either you have consented to this, or we have another legal reason by which we can contact you for marketing purposes. However, we will give you the opportunity to manage how or if we market to you. In any email that we send to you, we provide a link to either unsubscribe or opt out, or to change your marketing preferences. If you have an account with us, you can login to your account and manage your preferences there too. To change your marketing preferences, and/or to request that we stop processing your personal information for marketing purposes, you can always contact us on the details set out at the beginning of this notice. If you do request that we stop marketing to you, this will not prevent us from sending communications to you that are not to do with marketing (for example in relation to services that you have purchased from us). We do not pass your personal information on to any third parties for marketing purposes.

Schedule 2 - Data collect from and/or share to Parties
Depending on the circumstances, the organisations or people who we share your personal information with will be acting as either Data Processors or Data Controllers. When we share your personal information with a Data Processor, we will ensure that we have in place contracts that set out the responsibilities and obligations of us and them, including in respect of security of personal information.
We do not sell or trade any of the personal information that you have provided to us.
The list of Parties we collect data from and/or share to (1)
Type of Third Party
Description
Collect
Share
Member of the incard Group
Our affiliated companies and subsidiaries
check
check
Card Issuer
Providing the Visa Card service
check
check
Payment Processing Partners and Vendors
Financial services providers, including card issuers, payment processors and banking partners to facilitate payment transactions. These third parties may be part of Open Banking, which means they may be able to send information they hold about your account and transactions to us (based on your consent).
check
check
Support tools and operational partners
These include analytics, search engine service providers, customer experience support platforms to optimise and improve our services, as well as subcontractors we may use to supplement our customer support resources.
x
check
Hosting and IT Service Provider
IT vendors, including cloud storage providers, to securely store your personal data.
x
check
Incard Card Manufacturers and Delivery Providers
Card manufacturing, personalisation and delivery companies.
x
check
Identity and other information verification providers
We work with third parties to verify the information you provide to us, for example your identity and address.
check
check
Social networks and other online platforms providers
Social media sites, for the purposes of conducting market research, marketing campaigns, targeted and retargeted marketing and understanding the success of our marketing activities.These social media sites may check if you hold an account with them and, based on the characteristics they have about you, provide targeted advertising to you (for example, to show you tailored advertisements on their social media platforms, depending on your potential interest in Tide Products and Services).
check
check
Public Data Sources
Companies House, LinkedIn and other public data sources.
check
x
Marketing, Business Development and Sales Partners
Third parties that help us generate sales and marketing leads, and create and deliver our marketing activities.
check
check
Insurers and Professional Advisors
x
check
Data Services Third Parties
Such as data analytics and insight firms, for example to test the quality of our data, to improve the effectiveness of our crime prevention controls, etc.
x
check
Government and regulatory organisations
Government, law enforcement agencies, authorities and regulatory bodies when Tide has to comply with its legal obligations.
x
check
Schedule 3 - Types of personal information
The types of personal information we collect about you may differ from person to person, depending on who you are and the relationship between us. We do not collect information from you relating to criminal convictions or offences.
Where we rely on consent for a specific purpose as the legal reason for processing your personal information, you have the right under data protection law to withdraw your consent at any time. If you do wish to withdraw your consent, please contact us using the details set out in this notice. If we receive a request from you withdrawing your consent to a specific purpose, we will stop processing your personal information for that purpose, unless we have another legal reason for processing your personal information – in which case, we will confirm that reason to you.
Under data protection laws, we can only use your personal information for the purposes we have told you about, unless we consider that the new purpose is compatible with the purpose(s) we told you about. If we want to use your personal information for a different purpose that we do not think is compatible with the purpose(s) we told you about, then we will contact you to explain this and what legal reason is in place to allow us to do this.
General personal information
General Category
Types of Personal Data in that category
Retention Periods
Identity information
This is information relating to your identity such as your name (including any previous names and any titles that you use), gender, marital status and date of birth
At least five years from the date terminated the services save that involve any suspicious activities.
Contact information
This is information relating to your contact details such as email address, addresses, telephone numbers
At least five years from the date terminated the services save that involve any suspicious activities.
Account information
This is information relating to your account with us (including username and password)
It is no longer than 1 years after termination of the service, save that it is involved in any suspicious activities.
Payment information
This is information relating to the methods by which you provide payment to us such as [bank account details, credit or debit card details] and details of any payments (including amounts and dates) that are made between us
At least five years from the last of the transactions save that it is involved in any suspicious activities.
Transaction information
This is information relating to transactions between us such as details of the goods, services and/or digital content provided to you and any returns details
At least five years from the last of the transactions save that it is involved in any suspicious activities.
Survey information
This is information that we have collected from you or that you have provided to us in respect of surveys and feedback
It is no longer 2 years after the survey was completed.
Marketing information
This is information relating to your marketing and communications preferences
It is no longer than 1 years after termination.
Website, Device and Technical Information
This is information about your use of our website and technical data which we collect (including your IP address, the type of browser you are using and the version, the operating system you are using, details about the time zone and location settings on the device and other information we receive about your device)
At least five years from the date terminated the services or from the last of the transactions saved that involve any suspicious activities.
Special Information
Type of Special Information
Retention Periods
Data used by
Race, Ethnic origin, Politics, Religion, Trade union membership, Genetics, Health, Sex life, Sexual orientation.
N/A
Race, Ethnic origin, Politics, Religion, Trade union membership, Genetics, Health, Sex life, Sexual orientation.
“Biometric identifiers” or “Biometric information” processed solely to identify a human being.
When the initial purpose for collecting or obtaining such identifiers or information has been satisfied or within 3 years of the individual’s last interaction with Veriff’s Clients, whichever occurs first.
Veriff LTD is the third party vendor providing verification service to the Users on behalf of Incard Limited and Incard Europe Limited. Incard Limited and Incard Europe Limited have the liability to supervise Veriff LTD to ensure their data collection, processing and security procedures and controls compliance with the applicable laws and regulations. Please refer to Veriff’s Privacy Policy: https://www.veriff.com/privacy-policy.
Schedule 4 - Using personal information by legal reason(s)
We have explained below the different purposes for which we use your personal information and, in each case, the legal reason(s) allowing us to use your personal information. Please also note the following:
Legal reasons to use personal information
Purpose
Legal Reason (s) for using the personal information
Identity customer
Contract Reason
Legitimate Interests Reason (in order to offer you services and/or digital content which helps us to develop our business)
To process your order, which includes taking payment from you, advising you of any updates in relation to your order or any enforcement action against you to recover payment
Contract Reason
Legitimate Interests Reason (in order to recover money that you owe us)
To manage our contract with you and to notify you of any changes
Contract Reason
Legal Obligation Reason
To comply with audit and accounting matters
Legal Obligation Reason
For record keeping, including in relation to any guarantees or warranties provided as part of the sale of services and/or digital content
Contract Reason
Legal Obligation Reason
To improve the services, and/or digital content that we supply
Legitimate Interests Reason (in order to improve the goods, services, and/or digital content for future customers and to grow our business)
To recommend and send communications to you about services, and/or digital content that you may be interested in. More details about marketing are set out in section 11 below
Legitimate Interests Reason (in order to grow our business)
Consent Reason
To ensure the smooth running and correct operation of our website www.incard.co
Legitimate Interests Reason (to ensure our website runs correctly)
To understand how customers and visitors to our website use the website and interact with it via data analysis
Legitimate Interests Reason (to improve and grow our business, including our website, and to understand our customer’s needs, desires and requirements)