At Roqqett we take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
This privacy policy is divided into the following sections:
- Who we are
- Our collection and use of your personal information
- Transfer of your information out of the UK and EEA
- Cookies and similar technologies
- Marketing
- Your rights
- How long your personal information will be kept
- Keeping your personal information secure
- How to complain
- Changes to this privacy policy
Who we are 👋
This App is operated by Roqqett Ltd (“we”, “us”, “our” or “Roqqett”).
We collect, use and are responsible for certain personal information about you as a “data controller” and when we do so we are responsible for that personal information for the purposes of applicable data protection laws.
How to contact Us 💬
Please contact us if you have any questions about this privacy policy or the information we hold about you, using the following contact details:
Our collection and use of your personal information 🤝
Personal information we collect about you
We collect personal information about you when you access our App or website, register with us, use our services (either via our App or website), contact us, send us feedback or complete customer surveys.
We collect this personal information from you either directly, such as when you register with us and use our services, or indirectly, such as your browsing activity while on our App and website (see “Cookies” below).
We also collect personal information about you from other sources as follows:
- directly from third parties such as:
- ~our merchant customers;
- ~third parties that we engage to monitor visits to our website;
- ~identity verification and anti-money laundering check providers; and
- ~our data service providers, which we engaged to aggregate your Transaction Data
- from third parties when you have authorised this, such as
- ~your banks or building societies; and
- from publicly available sources such as Companies House.
The personal information we collect about you depends on the purpose for which you engage with us. This information includes the following:
- Identity Data - full name, title, date of birth and gender.
- Contact Data - address, email address and telephone numbers.
- Financial Data - bank account details.
- Transaction Data - details about payments to and from you
- Technical Data – mobile device ID, internet protocol(IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our App or website
- Profile Data - your username and password, your interests and preferences.
- Usage Data - information about how you use our App, website and services, including survey responses.
- Marketing and Communications Data - your preferences in receiving marketing from us and our marketing partners and your communication preferences.
This personal information is required to provide our services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.
In addition, we do not envisage that we will collect or process any special categories of personal data about you.
How and why we use your personal information 👨👩
Under data protection law, we can only use your personal information if we have a legal basis for doing so for example:
- Consent: where you have given us clear consent for us to process your personal information for a specific purpose
- Contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
- Legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)
- Legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests)
Purposes for which we will use your personal data
Purpose/ Activity
Type of data
Type of dataLegal basis for processing including basis of legitimate interest
To register you as a new user of our services
(a) Identity
(b) Contact
Performance of a contract with you
To provide our services to you, including:
(a) Aggregating transaction information relating to your accounts held with third party banks or building societies
(b) Making transactions between your third party bank accounts and from your accounts to those of other Roqqett users or generating an invitation to join Roqqett in order for you to make and receive payments from third parties which are not already Roqqett users
(c) Tracking your rewards with our affiliated merchants
(d) Managing any payments,fees and charges
(e) Collecting and recovering money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contractwith you
(b) Necessary for our legitimate interests (to recover debts due to us and prevent fraudulent transactions)
To manage our relationship with you which will include:
(a) Notifying you about changes to our services, terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To enable you to complete a survey or provide us with feedback
(a) Identity
(b) Contact
c) Profile
(d) Usage
(e) Marketing and Communications
(a) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)
To administer and protect our business and this App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant content and marketing materials to you (including advertising which relates to our affiliated merchants and your rewards) and measure or understand the effectiveness of the marketing we send to you
(a) Identity
(b) Contact
c) Profile
(d) Usage
(e) Marketing and Communications
Necessary for our legitimate interests (to define types of customers for our services, to keep our App and website updated and relevant, to develop our business and to inform our marketing strategy)
To use data analytics to improve our App, website, services, marketing, customer relationships and experiences
(a) Technical (b) Usage
Necessary for our legitimate interests (to define types of customers for our services, to keep our App and website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop our services and grow our business)
Who we share your personal information with
We routinely share personal information with:
- third parties we use to help deliver our services to you, such as:
- ~identity verification and anti-money laundering check providers;
- ~our data service providers, which we engaged to aggregate your Transaction Data; and
- ~your banks or building societies, with which you hold accounts that you have authorised us to aggregate via our services.
- other third parties we use to help us run our business, such as:
- ~our CRM provider;
- ~marketing agencies; and
- ~App and website hosting providers.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.
We may also share personal information with external auditors, e.g. in relation to the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Transferring your personal information out of the UK and EEA 🌍
To deliver services to you, it may sometimes be necessary for us to share your personal information outside the UK and/or EuropeanEconomic Area (EEA), however we do not envisage that we will need to do so as all of our third parties hold our data within either the UK or EEA.
That said, if we are ever required to transfer your personal data outside of the UK or EEA we will always ensure the transfer complies with data protection law and all personal information will be secure.
If you would like further information please contact us (see the contact details at the start of this policy).
Cookies and other tracking technologies 🍪
A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our App or website. These help us recognise you and your device and store some information about your preferences or past actions.
For further information on cookies, our use of cookies, when we will request your consent before placing them and how to disable them, please see our Cookie Policy.
Marketing 🛒
We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, text message (SMS) or automated call.
We will help third party merchants to deliver relevant advertising content to you where you have agreed to receive this, however we will always treat your personal information with the utmost respect and never sell or share it with other organisations for marketing purposes.
If you have given your consent to receive marketing communications, or it is in our legitimate interests to send them because you are not a consumer or you are a consumer that has previously purchased similar services from us, you always have the right to opt out of receiving further promotional communications by:
- contacting us at support@roqqett.com; or
- updating your marketing preferences in the app; or
- using the ‘unsubscribe’ link in emails.
We may ask you to confirm or update your marketing preferences if there are changes in the law, regulation, or the structure of our business.
Please note that we may also send you other communications in relation to your use of the services or in order to respond to queries you have raised, such communications are service communications and are not a form of marketing.
Your rights 📜
You have the following rights, which you can exercise free of charge:
Access
The right to be provided with a copy of your personal information (the right of access)
Rectification
The right to require us to correct any mistakes in your personal information
To be forgotten
The right to require us to delete your personal information—in certain situations
Restriction of processing
The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Data portability
The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object
The right to object:—at any time to your personal information being processed for direct marketing (including profiling);—in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the guidance provided by the UK Information Commissioner’sOffice (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
- email, call or write to us — see contact details at the start of this policy;
- let us have enough information to identify you e.g. your full name, email address and account information;
- let us have proof of your identity (i.e a copy of your driving licence or passport); and
- let us know what right you want to exercise and the information to which your request relates.
How long your personal information will be kept ⌛️
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
As an indication, if you purchase services from us, we will keep your personal information while we are providing such services. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly; and
- to keep records required by law.
Keeping your personal information secure 🔐
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
All data that we receive from your banks or building societies will be stored in encrypted databases using encrypted tokens.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain ✉️
We hope that we can resolve any queries or concerns you may raise about our use of your personal information.
Applicable data protection laws also give you the right to lodge a complaint with a supervisory authority, in particular in the EuropeanUnion (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/make-a-complaint/your-personal-information-concerns/ or telephone: + 44 303 1231113.
Changes to this privacy policy
This privacy policy was last updated in August 2020. We keep our privacy policy under regular review to make sure it is up to date and accurate. If we change our privacy policy from time to time, we will post the details of any changes here. We may also take reasonable steps to notify you if such changes affect how your personal data is processed.
