Privacy Policy
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of
Your information when you use the Service and tells you about your privacy rights and how the law
protects you. We use your Personal data to provide and improve the Service. By using the service,
you agree to
the collection and use of information in accordance with this privacy policy.
Contents:
Who we are?
Why do I need to read this notice?
What personal data do you collect about me?
What is your legal basis for using my personal data?
How do you use my personal data?
What are my rights?
How do I exercise my rights?
Will my personal data go outside the United Kingdom or Europe?
How do you protect my personal data?
How long do you store my data for? Retention
Will you disclose my personal data?
How will you keep me updated bout how you use my personal data?
Who we are?
We are Zeepay JV UK Limited (‘we’, ‘our’, ‘us’) and for the purposes of our app operate under the name Instntmny Transfer
We’re registered with the UK data protection authority (the Information Commissioner’s Office or ICO)
under number ZA663267.
We will be responsible for processing your personal data when using our services, and as such we are
known as the ‘controller’ of your personal data.
Why do I need to read this notice?
We collect your personal data when you use:
The Instntmny Transfer app
Any of the services available to you through the Instntmny Transfer app
This notice explains what information we collect, how we use it, and your rights if you want to
change how we use your personal data.
We may provide this notice in languages other than English. If there are any discrepancies between
other language versions and the English language version, the English language version is
authoritative.
If you have concerns about how we use your personal data, you can contact info@myzeepay.com .
What personal data do you collect about me?
We collect the following type of data:
Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable
information that can be used to contact or identify you. Personally identifiable information may
include, but is not limited to:
First name and last name
Phone number
Usage Data
Such information may be collected when you:
Register to use our Transfer app
Correspond with us
Respond to any of our surveys
Speak with a member of our social media or customer support team
Take part in online discussions of promotions
Contact us for other reasons
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as your device's internet protocol address (e.g. IP
address), browser type, browser version, the pages of our service that you visit, the time and date
of
your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the service by or through a mobile device, we may collect certain information
automatically, including, but not limited to, the type of mobile device you use, your mobile device
unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile
internet browser you use, unique device identifiers and other diagnostic data.
We may also collect information that your browser sends whenever you visit our service or when
you access the service by or through a mobile device.
Information Collected while Using the Application
While using our application, in order to provide features of our application, we may collect, with
your prior permission:
Information regarding your location
Information from your Device's phone book (contacts list)
We will use this information to provide features of our Service, to improve and customize our
Service. The information may be uploaded to the Company's servers and/or a Service
Provider's
server or it may be simply stored on your device.
You can enable or disable access to this information at any time, through your Device settings.
What is your legal basis for using my personal data?
We must have a legal basis (a valid legal reason) for using your personal data. Our legal basis will
be
one of the following:
Keeping to our contracts and agreements with you
We need certain personal data to provide our services and cannot provide them without this
personal data.
Legal obligations
In some cases, we have a legal responsibility to collect and store your personal data (for example,
under anti-money laundering laws we must hold certain information about our customers).
Legitimate interests
We sometimes collect and use your personal data because we have a legitimate reason to use it and
this is reasonable when balanced against your human rights and freedoms.
Substantial public interest
Where we process your personal data, or your sensitive personal data (sometimes known as special
category personal data), to adhere to government regulations or guidance, such as our obligation to
support you if you are or become a vulnerable customer.
Consent
Where you've agreed to us collecting your personal data, or sensitive personal data, for example
when you tick a box to indicate you’re happy for us to use your personal data in a certain way.
How do you use my personal data?
We may use Personal Data for the following purposes:
To provide and maintain our Service
including to monitor the usage of our Service.
To manage your Account:
to manage Your registration as a user of the Service. The Personal Data
you provide can give you access to different functionalities of the Service that are available to
you as
a registered user.
To contact you:
the development, compliance and undertaking of the purchase
contract for the products, items, or services you have purchased or of any other contract with us
through the Service.
For the performance of a contract:
To contact you by telephone calls, SMS, or other equivalent forms of electronic
communication, such as a mobile application's push notifications regarding updates or
informative
communications related to the functionalities, products, or contracted services, including the
security updates, when necessary or reasonable for their implementation.
To manage your requests:
To attend and manage your requests to us.
For business transfers:
We may use your information to evaluate or conduct a merger, divestiture,
restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets,
whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which
Personal Data held by us about our Service users is among the assets transferred.
For other purposes:
We may use your information for other purposes, such as data analysis,
identifying usage trends, determining the effectiveness of our promotional campaigns and to
evaluate and improve our Service, products, services, marketing and your experience.
We may share Your personal information in the following situations:
With Service Providers:We may share your personal information with Service
Providers to
monitor and analyze the use of our Service, to contact you.
For business transfers:We may share or transfer your personal information in
connection with,
or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a
portion of our business to another company.
With Affiliates:We may share your information with our affiliates, in which case we
will require
those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other
subsidiaries, joint venture partners or other companies that we control or that are under
common control with us.
With company service providers and business partners:We provide data to vendors, consultants,
marketing partners research firms, and other third-party independent service providers or business partners. These include:
Payment processors and facilitators
Background and credit check, income and identity verification providers (as applicable)
Cloud storage providers
Call centre and customer support providers,
Marketing partners and platform providers
Data analytics providers
Research partners
Third party financial institutions that support our card services.
With permission or requirement for legal reasons:We will share your personal data where we believe it is permitted or required by applicable law,
regulation, operating license or agreement, legal process or government request or where the disclosure is otherwise appropriate due to safety or similar concerns.
With Your consent:We may disclose Your personal information for any other purpose
with Your
consent.
What are my rights?
As a data subject you have the following rights:
Access rights
You have the right to be told how we use your personal data. We have provided this privacy notice
to details how your personal data will be used. Additionally, if you ask, we will provide a copy of
the
personal data we hold about you. We are unable to give you any personal data about other people,
personal data which is linked to an ongoing criminal or fraud investigation, or personal data which
is
linked to settlement negotiations with you. We also won't provide you with any communication
we've had with our legal advisers.
Rectification rights
You can ask us to correct your personal data if you think it is wrong. This means that you can have
any inaccurate personal data corrected. Before we update your file, we may need to check for the
accuracy of the new personal data details you have provided.
Erasure rights
You can ask us to delete your personal data. We may not be able to agree to your request. As a
regulated financial service provider, we must keep certain customer personal data even when you
ask us to delete it as our regulatory responsibilities take priority. We will always let you know if
we
cannot delete your personal data.
Erasure rights
You can object to use processing other personal data (if we are using it for a legitimate interest).
If
we are using your personal data for a legitimate interest and you disagree with us using it, you can
object. This is however not an absolute right, as where there is an overriding reason why we need to
use your personal data, we will not accept your request.
You can ask us to restrict how we use your personal data. We can suspend using your personal data
if:
You want us to investigate whether it’s accurate
Our use of your personal data is unlawful, but you do not want us to delete it
We no longer need your personal data, but you want us to continue holding it for you in
connection with a legal claim
You have objected to us using your personal data, but we need to check whether we have an
overriding reason to use it.
If you have given us the consent we need to use your personal data, you can withdraw it at any time.
Please note, that it will be lawful for us to use the personal data we have collected up to the
point
you withdraw your permission.
Portability rights
You can ask us to transfer personal data to you or another company, in so long as regulatory
requirements permit us to do so.
You can object to us processing your personal data for marketing purposes
You can ask us to carry out a human review of an automated decision we make about you
How do I exercise my rights?
To exercise any of your rights as set out in the previous section, you can contact us by sending an
email to info@myzeepay.com .
For security reasons and following best practice, we may ask you for proof of ID, as we can not deal
with your request if we are not sure of your identity.
If a third-party exercise one of these rights on your behalf, we may need to ask for proof that
they’ve
been authorised to act on your behalf.
When you exercise one of your rights, it may take us up to one month to respond or implement your
changes.
If you’re unhappy with how we’ve handled your request you can complain to your local data
protection authority. In the United Kingdom, this is the ICO Information Commissioner’s Office ico.org.uk
Will my personal data go outside the United Kingdom or Europe?
Your information, including Personal Data, is processed at the Company's operating offices and in
any other places where the parties involved in the processing are located. It means that this
information may be transferred to — and maintained on — computers located outside of your state,
province, country, or other governmental jurisdiction where the data protection laws may differ
than those from your jurisdiction.
Your consent to this Privacy Policy followed by your submission of such information represents your
agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that your data is treated securely
and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an
organization or a country unless there are adequate controls in place including the security of your
data and other personal information.
How do you protect my personal data?
We recognise the significance of protecting and managing your personal data. Any personal data we
process will be treated with the utmost care and security. All electronic data and databases are
stored on secure computer systems with control over who can access information by both physical
and electronic means.
Though we use a variety of other physical and technical measures to keep your personal data secure,
it is important to remember that no method of transmission over the Internet, or method of
electronic storage is 100% secure. While we strive to use commercially acceptable means to protect
your Personal Data, we cannot guarantee its absolute security.
It is vital to keep your Zeemoney app pin confidential. Please do not share it with anyone.
How long do you store my data for?
The Company will retain your Personal Data only for as long as is necessary for the purposes set out
in this Privacy Policy. Generally, where our business relationship with you ends we will keep your
personal data for six years or for such periods as may be required to comply with our legal
obligations.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally
retained for a shorter period of time, except when this data is used to strengthen the security or to
improve the functionality of Our Service, or We are legally obligated to retain this data for longer
time periods.
Will you disclose my personal data?
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be
transferred. We will provide notice before Your Personal Data is transferred and becomes subject to
a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if
required to do so by law or in response to valid requests by public authorities (e.g. a court or a
government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary
to:
Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability
How will you keep me updated bout how you use my personal data?
If we change the way we use your personal data, we’ll update this notice and, if appropriate, let you
through the Instntmny Transfer app or through our website.