As part of our business, particularly providing our Collctiv app (the “App”), we collect basic personal details about users of the App, including group organisers who download the App, and group contributors, who pay money into a pot on the App (we refer collectively to such individuals in this policy as “you” or “your”).
This policy explains our privacy practices in relation to how the App is used, and covers the following:
Information that we collect
We will also see partial details concerning an Organiser’s and Contributor’s payment card but at an anonymised level (we can only see the last 4 digits) – so we will never have access to your full card details or bank account details, nor will we be able to identify you from that incomplete card number.
Information collected and used by our third party service providers
If you are an Organiser for a group on the App, and you wish to make a withdrawal from the central pot on the App, into a separate bank account, our third party service provider may need to obtain further ID from you, as part of anti-money laundering checks. This will usually entail asking for your name, photograph on an official document which confirms your identity (e.g. a passport) and your residential address and date of birth.
We do not currently collect, nor can we access any of the following types of personal information which are likely to be used as part of the services delivered through the App:
The above service providers may therefore also collect personal data about you separately from us when you use the App services. You can find out more information about what personal data the service providers collect about you and what they use it for, and how they protect it, via the following links:
However, if you have any queries about how your personal information is being used on the App, including by any of the above third party providers, please contact us in the first instance, using the details set out at paragraph 10 below – we may then refer you to the relevant third party provider, depending on the nature of your query.
Generally speaking, we only collect and use your personal information that you provide directly to us, whether this is when you register with the App, and/or when you make transactions using the App or contact us with a support query. We do not collect personal data about you from any third parties, except as follows:
We use your personal information in the following ways:
Name, email and password - Registering an Organiser as a user and managing their account e.g. handling support queries.
Date of birth - Verifying that an Organiser is old enough to use the App (it is only available to users who are aged 18 and over)
Transaction details and partial card number - Storing for audit purposes and ensuring that the App is used in a lawful and legitimate manner, in accordance with our App user terms.
Name and email - We may also, from time to time, alert Organisers about new features of the App and similar services, by email – however, you have the right to opt out of this marketing at any time by contacting us at email@example.com or clicking “unsubscribe” on any marketing message.
ID verification information - For anti-money laundering checks on Organisers
Name, email - Recording payments on the App, including for audit purposes
Transaction details and partial card number- Storing for audit purposes and ensuring that the App is used in a lawful and legitimate manner
We only share your personal information with the following parties, who are our third party service providers:
Organisers - For information on anti-money laundering checks, we need to be able to access this information for 5 years, so we retain it for this period. We retain all other personal information which we collect about you for as long as you have an App account with us, plus 7 years.
Contributors – we retain information about Contributors in personally identifiable form for a period of 7 years after you have made a payment onto the App, for financial auditing purposes (following which we fully anonymise the information).
We will not transfer any of your personal information outside of the United Kingdom – it will be hosted on Google’s servers in London. However, please also refer to the privacy policies of the relevant third party providers, available via the links at paragraph 2 above. For instance, Stripe may transfer personal data to the United States and other countries outside of the United Kingdom.
Every use that we make of your personal information must meet a lawful basis, set out under data protection law. For the uses set out in this policy, the lawful bases that we rely on are as follows:
Name, password and email – managing your account, providing support services
For the purposes of performing our contract with you. We need to receive and use your personal information in order to register your account and for you to use the App and receive support from us from time to time – therefore, if you do not wish to share such personal information with us, you will not be able to use our App and/or receive support services from us.
Date of birth – verifying your age
Legitimate interests – specifically to be able to determine that you are old enough to use the App.
Transaction details and part of your card number – audit purposes, managing use of our app
Legal obligations – specifically for audit purposes as required under the Companies Act 2006;
Name and email - marketing
Legitimate interests – particularly, the need to promote new features of the app and similar products and services which we introduce to existing users of the App.
Name, ID documents and date of birth – for anti-money laundering checks. Required by anti-money laundering laws.
Name, email address, transaction details and part of your card number – audit purposes and recording transactions on the App
Legal obligations - specifically for audit purposes as required under the Companies Act 2006;
Legitimate interest - specifically for other uses of transaction data – which is about ensuring that our App is used lawfully.
If you have any questions in relation to our use of your personal information, you should first contact us, using the contact details in paragraph 10 below. Under certain conditions, you may have the right to:
Your exercise of these rights is subject to certain conditions and exemptions, for example to safeguard the public interest in investigating crimes, or protecting legal privilege. If you exercise any of these rights, we will check your entitlement and respond in most cases within a month. As mentioned above, it may be that we will need to refer you to one of our third party providers, for instance if it relates to personal information concerning the card payment feature or other third party service.
If you are not satisfied with our use of your personal information or our response to you, you can complain to us, using the details set out at paragraph 10 below.
We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to your personal information, by contacting us, using the email address below.
We are required to employ adequate technical and organisational security measures to protect your personal information from any loss, destruction, damage or unlawful disclosure. However, no transmission of personal information over the internet or via the App can ever be guaranteed as secure. Consequently, please note that we cannot guarantee the security of any personal information which you transfer to us or which we transfer to you or a third party over the App.
If you would like further information about the matters set out in this policy, please contact us at: firstname.lastname@example.org