Neofin Ventures Ltd, (trading as “Unizest”, “We”, “Us”, “Our”) is committed to protecting your personal information and respecting your privacy.
This policy applies to Your use of the Unizest Services (“Services”) accessed through the Unizest website (unizest.co.uk), its mobile and web applications, and all communication made to and from Unizest customer service representatives, including but not limited to communication via phone call, email, SMS, WhatsApp, and push notification, including, for the avoidance of doubt, an application for an e-current account and debit card- (together the “Platform”).
This policy sets out the basis on which any personal data We collect from you, or that you provide to Us, will be processed by Us. Please read the following carefully to understand Our views and practices regarding your personal data and how We will treat it.
For the purposes of applicable data protection laws (including the Data Protection Act 2018 and UK General Data Protection Regulation and the Privacy and Electronic Communication Regulations – PECR) (“Data Protection Laws”), the data controller is Neofin Ventures Ltd trading as Unizest. We are registered in England and Wales under company number 12632726 and have Our registered office at 20-22 Wenlock Road, London, England, N1 7GU.
We are registered with the Information Commissioner’s Office (ICO) under registration number: ZB007938
Information we may collect from you We may collect and process the following data about you:
- Information you give Us (Submitted Information): You may give Us information about you by registering for the Services via the Platform, or by corresponding with Us (for example, by e-mail).
- Information We collect about you and your device: Each time you use the Services We may collect the following information with your consent:
- Technical information, including the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting. (Device Information);
- Details of your use of the Services including, but not limited to, traffic data and location data, (Log Information).
- If you contact Us, We may keep a record of that correspondence.
Uses made of your information: We use information held about you in the following ways:
- Submitted Information which includes Your title, full name, address(es), date of birth, passport/ID, nationality, mobile phone number, mobile device information, email address and financial transaction information: We use Submitted information to provide the Services and when you have signed an agreement with us and given us your explicit, to market Our services to you.
- We will use Device Information and Log Information for Our understanding of how you use the Services, to ensure that it is optimised for your use.
This website is not intended for children, and we do not knowingly collect data relating to under the age of 18 years.
Why We collect your personal data
Your personal data is collected primarily so that you can effectively use the Services. In using the Platform and Services you will be asked to provide your consent to the use of your personal data to provide you with marketing information.
Lawful bases for processing your personal data
We will only use your personal data when the law allows us to. Most commonly, we will process your personal data using the following legal bases:
- Performance of a contract – which means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Before we provide services to you we are legally required to carry out checks for the purposes of preventing fraud and money laundering/terrorist financing and to verify your identity.
- 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 –
- legitimate interest means the interest of our business in conducting, managing, and protecting our business to enable us to give you the best service and the best and most secure experience. One of our legitimate interests is to prevent fraud and money laundering/terrorist financing and to verify identity. 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.
- Where we need to comply with a legal obligation – this means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. This also means that the personal data that you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering/terrorist financing. We and our Banking Partner and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
- Generally, we do not rely on consent as a legal basis for processing your personal data except where we are processing special category of data such as the biometric data contained in a passport when we will require your explicit consent. We will get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
- As part of the processing of your personal data, decisions may be made by automated means. This means we or our data processors may automatically decide that you pose a fraud or money laundering/terrorist financing risk if our processing reveals your behaviour to be consistent with money laundering/terrorist financing or known fraudulent conduct, or is inconsistent with other data held, or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision making and if you want to know more, please contact us at email@example.com.
- If we, or a fraud prevention agency, determine that you pose a fraud or money laundering/terrorist financing risk, we may refuse to provide the services you have requested, or we may stop providing existing services to you. A record of any fraud or money laundering/terrorist financing risk will be retained by fraud prevention agencies and may result in others refusing to provide services and financing to you. If you have any questions about this, please contact us at firstname.lastname@example.org
Disclosure of your information
We will only disclose your personal data to Our regulated e-money issuer (“Banking Partner”), and not to any other third party. If you wish to learn more about how our Banking Partner processes your data then you can do so by visiting: https://www.railsr.com/privacy-policy
Where We store your personal data
Where We have given you (or where you have chosen) a password that enables you to access the Services, You are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although We will do Our best to protect your personal data, We cannot guarantee the security of your data when it is transmitted; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to prevent unauthorised access.
How long will you use my personal data for? We will only retain your personal data for as 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. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, and Financial Data) for six years for regulatory purposes. Please note that fraud prevention agencies are permitted to hold your personal data for different periods of time and if you are considered to pose a fraud or money laundering/terrorist financing risk your data can be held for up to six years.
In accordance with applicable Data Protection Laws, you have the right to access your personal data, the right to rectification, a right to restrict Our processing activities of your data, the right to data portability and a right of erasure (to be forgotten) .
You have the right to ask Us not to process your personal data for any marketing purposes. You will be required to provide your consent to the processing of your Submitted Information by checking certain boxes on the Platform and other systems controlled by Unizest. You have the right to withdraw your consent at any time. You can contact Us at email@example.com for further information.
Access to information
The applicable Data Protection Laws give you the right to access information held about you. Your right of access can be exercised in accordance with such Data Protection Laws. You will not have to pay a fee to access your personal data (or 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.
The Platform and Services may, from time to time, contain links to and from the websites of Our partner networks, third-party employers, advertisers and affiliates. If You follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
We may collect and store personal data on your device using application data caches and browser web storage and other technology. Please see our Cookie Declaration for more information
Last updated 16 June 2022