Date amended: 24th January 2024

Contents

1. Who we are and important information
2. The data we collect about you
3. How is your personal data collected?
4. How we use your personal data 
5. Purposes for which we will use your personal data
6. Third parties
7. Cookies
8. Disclosure of your personal data
9. Transfer of data
10. How we keep your data secure
11. How long we store your data for
12. Our legitimate business interests
13. Your rights
14. Process for changing this policy and your duty to inform us of any changes

Who we are and important information

We are Mintago Limited (collectively referred to as “Mintago”, “we”, “our” or “us” in this privacy policy).

At Mintago we take the issue of your privacy very seriously. Which is why we work hard to ensure we have policies and procedures in place. Mintago respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data as a business, when you visit our website (www.mintago.com) (regardless of where you visit it from) and/or the Mintago Platform and tell you your privacy rights and how the law protects you.

This privacy policy is governed by the UK General Data Protection Regulation (GDPR) which has the meaning given to it in section 3(10) (as supplemented by section 205(4)) of the Data Protection Act 2018.  We act as the data controller, and in specific situations where we engage with our clients through the financial wellbeing platform (accessed via both the web and mobile application) that enables users to access financial wellbeing tools (Mintago Platform) we act as the data processor. We are registered with the Information Commissioner’s Office under number ZA555904.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the following details:

DPO: DataCo International UK Limited (DataGuard)

Email address: dataprotection@mintago.com

Postal address: Mintago Limited, Finchley Park, Emmet Hill Lane, Laddingford, Kent, ME18 6BG

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Mintago provides you with regulated account information services as an agent of Plaid Financial Ltd., an authorised payment institution regulated by the Financial Conduct Authority under the Payment Services Regulations 2017 (Firm Registration Number: 804718) for the provision of payment services, including account information services.

This privacy policy aims to give you information on how Mintago collects and processes your personal data through your use of this website and/or Mintago Platform, including any data you may provide  when you login or sign up to our services.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. 

Please ensure you also read our terms and conditions relevant to the service that we provide you alongside this policy. By registering with the Mintago Platform, you agree to us collecting and utilising your data in accordance with this policy.

We would like to highlight that:

• Through the use of the Mintago Platform you will be able to provide us with your financial information in various ways, all of which will be at your full discretion and can be deleted at your request.
• Mintago does not store any bank account details or any account details associated with any financial institution that you choose to add to the Mintago Platform.
• No personal identifiable data is shared with third parties (including your employer) without your consent.
• All critical data are encrypted with a 2 key base64 AES encryption methodology and not accessible over a public network.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first and last name, username or similar identifier, national insurance number, date of birth and gender.
• Employment Data includes historic employment details.
• Contact Data includes home address, email address and telephone numbers.
• Financial Data includes bank account and pension details.
• Open Banking Data includes users’ financial details and transactions. By opting for our open banking feature, users grant consent for us to retrieve this information, enhancing the platform’s financial services. 
• Technical Data includes 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 this website and/or Mintago Platform.
• Profile Data includes your username and password, your preferences and feedback responses.
• Usage Data includes information about how you use our website, Mintago Platform and any other services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website or Mintago Platform feature. However, if we combine or connect Aggregated Data with your personal data so that it can be directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions or offences.

In addition to the personal data that we collect directly from you (as described above), we may also collect personal data from third party sources and combine that with information we collect through our website and the Mintago platform.  We do not control, manage, or assume responsibility for how third parties handling your information process your personal data., Any inquiries about the disclosure of your personal information to us should be directed to those third parties.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our services;
• create an account on our website and/or the Mintago Platform;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website and the Mintago Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our the cookie section for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• Technical Data from analytics providers, advertising networks and search information providers.
• Contact, Financial and Open Banking Data from providers of technical, banking, payment, and delivery services.
• Employment Data from previous employers.
• Identity and Contact Data from data brokers or aggregators.
• Identity and Contact Data from publicly available sources and other third-party profiles.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract that we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via the Mintago Platform, orally, email or by an online process for the specific activity we require consent for and record your response on our system.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which product, services and offers may be relevant for you.

You may receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third Parties

We may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your personal data, but not before you are asked to give your consent. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Mintago Platform, we encourage you to read the privacy policy of every site you visit.

Through Mintago you are able to access third party financial advisers and experts. Mintago does not have any control over or responsibility for how these professionals will use the data you provide to them and the advisory services they will be conducting for you.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out 

You can ask us or third parties to stop sending you marketing messages at any time by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, experience of other transactions.

Cookies

Our website and the Mintago Platform uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse and also allows us to improve our sites.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

You can find more information about cookies at www.allaboutcookies.org

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website and Mintago Platform. These essential cookies are always enabled because our website or Mintago Platform won’t work properly without them. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website or Mintago Platform.   
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website and Mintago Platform when they are using it. This helps us to improve the way our website and Mintago Platform works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website and/or Mintago Platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website and/or Mintago Platform, the pages you have visited and the links you have followed. We will use this information to make our website, Mintago Platform, and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose so that they can serve you with relevant advertising on their websites.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

If you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website and/or Mintago Platform.

Upon entering our website and/or Mintago Platform, you will encounter a cookie banner. Through the banner, you have the explicit choice to:

• Accept cookies: By clicking “Accept,” you consent to the use of all cookies as outlined in this policy.
• Deny cookies: If you prefer not to allow cookies, you can click “Deny.” Please note that certain features of the site may not function properly without the use of cookies.

Disclosure of your personal data

To provide you with a better user experience when using the Mintago Platform, we may share your personal data with the various parties identified below for the purposes set out in the purposes table above: 

• Internal Mintago employees and advisers who need to know. All such people are subject to a contractual duty of confidentiality.
• External third parties such as service providers, professional advisers, HM Revenue & Customs, regulators and other authorities.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Transfer of data

We host our data in the UK and on servers in the UK.  To the extent that any of your personal data  is transferred outside of the UK then we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to counties that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

We will always ensure that there is a proper legal agreement that covers the data transfer.

If a country is not considered to have laws that are equivalent to UK data protection standards, we will ask the third-party service provider to enter into a legal agreement that reflects those standards. 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

How we keep your data secure

We have put in place appropriate security measures  to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Accounts will be password protected and this will be required each time the user logs in.  

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any actual or suspected personal data breach and will notify you and any applicable regulators of a breach where we are legally required to do so.

How long we store your data for

We will only retain your personal data for so long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. 

By law we have to keep basic information about our customers (including Contact, Identity and Financial Data) for six years after they cease being customers for tax purposes.

We may also retain your personal data to enable for a longer period in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect to our relationship with you, or to share information with the Financial Conduct Authority who regulate us. Once the relevant time-period has expired then we will delete your personal data safely and securely.

In some circumstances you can ask us to delete your data.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Our legitimate business interests

We have a number of lawful reasons that mean we can use your personal information, including a legitimate interest which means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of your personal data. This enables you to have any inaccurate or incomplete data we hold about you corrected. We may need to verify the accuracy of the new data you provide.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. you also have the right to ask us to delete or remove your personal data where we may have processed your information unlawfully or where we are required to delete your personal data to comply with local laws. We may not always be able to comply with your request of deletion for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data.  This enables you to object to the processing of your personal data on the grounds that we are relying on a legitimate interest (or those of a third party) and there is something that you feel impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some circumstances, there may be compelling legitimate grounds to process your information which override your rights.
• Right to withdraw consent.  This enables you to withdraw your consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services. However, we will advise you if this is the case when you wish to withdraw your consent.
• Request transfer of your personal data.  We will provide to you, or a third party, your personal data in a structured, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data:
• If you want us to establish the accuracy of the data;
• Where our use of the data is unlawful but you do not want us to delete it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. we may also contact you to ask for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Process for changing this policy and your duty to inform us of any changes 

We keep our privacy policy under regular review therefore, we may change this policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We will update the date at the top of the policy accordingly. We encourage you to check this policy for changes when you revisit the Mintago website and/or Mintago Platform.

It is important that the person data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.