Who we are
Munnypot Limited (‘We’) is a company registered in England (Company no. 09822431). We are committed to protecting your privacy and complying with applicable data protection and privacy laws. This privacy notice (‘Notice’) is designed to help you understand what kind of personal data we collect and how we process and use such data: it also sets out your rights in relation to how we look after your personal data.
We act as a data controller for the personal data we hold about you. We are an Appointed Representative of Resolution Compliance Limited and, in relation to our regulated activities, we and Resolution Compliance Limited will act as joint controllers of your personal data.
Our products or services may contain links to a third party’s website or service. Unless that third party is processing your personal data on our behalf, we are not responsible for the privacy policies or practices of such a third party. We recommend that you carefully read the privacy notice for such third parties.
Personal data we collect
In most instances, we collect your personal data when you register for our services, make a purchase, enter a sales promotion or otherwise interact with us. Below are examples of the categories of the data we collect about you.
For the most part, you can visit our websites without having to identify yourself. However, certain technical information is normally collected by us as a standard part of our services. This information relates to your IP-address, information about your device and other technical information your browser provides us with. We also collect data about your use of our websites (such as when you use the website and interact with the content). If you call us, information such as your telephone number may be saved as a standard part of that process. All inbound and outbound telephone calls are recorded for monitoring purposes.
Information you provide us
To provide the products and services you have requested, or to communicate with you, we may ask you to provide information such as your name, date of birth (or your age), national insurance number, email address, home or postal address, or details of your financial situation. In registering for our services, you create user names, passwords and other credentials which we use to authenticate your identity and to validate your actions. You may send us copies of your personal identity documents or details about other financial products you may own.
We may also ask you to submit information about other people, such as members of your family or household or a beneficiary of a product you own, for example.
You may also indirectly provide us with information through your consents, preferences and feedback
Your transactions with us
We collect details of the queries or requests you have made, the products and services provided (including delivery details), purchasing details (including payments made, nominated bank account details, billing address, credit checks and other such financial information), details of agreements between us, records of contacts and communications, information and details relating to the content you have provided us with and other such transactional information. We may, in accordance with applicable law, record your calls to our customer services team or with other similar contact points.
Personal data obtained from third parties
We may obtain personal data about you from third party sources such as social media analytics and from the following partners:
Equifax: which we use to carry out identity verification checks on our customers
SEI Investments (Europe) Ltd: which acts as our custodian and investment platform
Why we need your personal data
We collect and process your data for one or more of the following reasons:
To fulfil our contract with you
Where necessary, we use your personal data to provide you with our products and services in line with our overall contract. We process and use your personal data to provide you with a personalised service and/or the product or service you have requested, to fulfil your other requests, process your order(s) and as otherwise may be necessary to perform or enforce the contract between us.
We are required to do so by law or regulation
We, and Resolution Compliance Limited, are required to process and store some of your data in order to fulfil our regulatory obligations. This may include the information we need to establish your needs and requirements and/or to provide you with a personalised recommendation or advice. We may capture and share your personal data with organisations who can confirm your identity and provide information which helps prevent fraud or other financial crimes. We may also be required to share your personal details where requested by legal authorities or with the Financial Ombudsman.
You have provided us with your consent
Where you have given your informed consent, we will process your data in accordance with the permission you have given us and this Notice. You may withdraw your consent at any time.
Our other legitimate interests in using your data
Taking into account your interests, we process your personal data for the following purposes:
To verify your identity and administer your account
We process and use your personal data to facilitate the functionality and security of our products and services, to identify you and the instructions you give us and to prevent and detect fraud and other misuses.
Development of products and services
We process and use your personal data to develop our products and/or services. However, for the most part we only use aggregated and statistical information in the development of our products and services and not data directly identifiable to you. We may also process and use your personal data to personalise our offerings and to provide you with a more relevant service, such as making recommendations and displaying customised content and advertising. We may amalgamate personal data collected in connection with your use of a particular product and/or service with other personal data we hold about you, unless the purpose for which we collected that data is not suitable for amalgamation.
Communicating with you and marketing
Our products and services:
We process and use your personal data to communicate with you, for example, to provide information relating to our products and/or services you are using, or to contact you for customer satisfaction checking purposes.
We may process and use your personal data for marketing purposes. Those purposes may include using your personal data for personalised marketing or research activities (in accordance with applicable laws), or, for example, to communicate with you about new products or promotions via our own or third parties’ services. When contacting you for marketing purposes, we will respect any preferences you have expressed to us, including any instructions you may have given us not to receive marketing communications.
We may process and use your personal data for profiling for such purposes as targeted direct marketing and improvement of our products or services. We may also create aggregate and statistical information based on your personal data. Our profiling activity includes the automated processing of your personal data to analyse, evaluate or help predict your personal preferences or interests. Profiling helps us refine any marketing messages we send you about our products or services, so those suggestions are appropriate to you.
Tracking remuneration due to us or our partners
We use your personal data to ensure that we receive any remuneration or commission that’s due to us from, or payable by us to, third-party product providers or distributors.
On occasions we will process personal data so that we can obtain insurance cover for our business and to notify and process claims with our insurers.
In the event of an interruption or the cessation of our business, we need to ensure that we can implement our business continuity procedures (for example, we may need to rebuild our IT systems) or wind down planning to protect your interests. This may involve a transfer of your personal data to a third party (see below).
Transfers of your personal data
We will transfer your personal data to the third parties noted below, or as obligated by law
Resolution Compliance Limited
Resolution Compliance Limited is a joint controller of your personal data in relation to our regulated activities.
Material service providers
We will transfer your personal data to the following third parties who provide us with a material service:
Equifax: which we use to carry out identity verification checks on our customers
Generic service providers
To ensure the efficient technical and logistical provision of our services, we may transfer your personal data to third parties who control or process personal data on our behalf. Those third parties are usually service providers that supply us with cloud data storage, data security services, customer relationship management software and support ticketing services. We may change technical or logistical service providers from time to time. Such parties are generally not permitted to use your personal data for any other purposes than the purpose it was collected for, and we require them to comply with the applicable laws and use appropriate security measures to protect your personal data.
Event driven transfers
To protect your, or our, legitimate interests, certain events—such as the cessation, sale or transfer of our business; civil, criminal, legal or regulatory proceedings; or insurance claims—may require us to transfer your personal data to third parties.
Our products and services may be provided using resources and servers located in countries around the world. Therefore, your personal data may be transferred outside the country where you use our services, which includes countries outside the European Economic Area (EEA). Data will only be transferred if the level of data protection in that jurisdiction is deemed adequate, or if there are appropriate safeguards in place which will protect your privacy.
How long do we keep personal data?
Your personal data is kept only for as long as it is reasonable for us to do so, depending on the nature of the data, our processing requirements and the grounds on which we collected it. However, we are obliged to store certain records of our relationship to comply with the FCA’s rules, in which case we will instead restrict access through our archiving processes. Subject to any actual or potential legal claim, the maximum time that we envisage retaining your information is five years after our relationship has ended: it will then be destroyed.
Information we use for marketing purposes will be kept by us until you notify us that you no longer wish to receive marketing information. Once you have notified us that you no longer wish to receive marketing information, we will not keep any information that would have been used for marketing purposes.
What are your rights?
You have the right to request information and have access to the personal data we hold about you. You also have the right to request that we correct or delete any incomplete, incorrect, unnecessary or outdated personal data we hold on you. However, we cannot delete personal data that is necessary for compliance, our binding legal obligations or if the personal data must be retained according to applicable laws or is required for the exercise or defence of a legal claim.
You may request restriction of processing of your personal data if:
- you consider your personal data collected by us to be inaccurate, but you do not wish your personal data to be deleted
- we have used your personal data unlawfully
- you have objected to the processing and the existence of legitimate grounds for processing is still under consideration
You may also, at any time, object to your personal data being processed for direct marketing purposes, sending promotional materials, profiling, or for the performance of market research. Furthermore, where your personal data is processed based on your consent, you have the right to withdraw your consent for such processing at any time.
Should you wish to exercise the rights mentioned above, you may, as appropriate and in accordance with applicable laws, do so by contacting us through the contact points referred to in the marketing materials or below in this Notice. In some cases, especially if you wish us to delete or cease the processing of your personal data, this might mean that we are unable to continue providing our services to you.
Please note that we may need to identify you and to ask for additional information to meet the above requests. Please also note that applicable law may contain restrictions and other provisions that relate to your above rights.
How to contact us
If you wish to contact us, please email firstname.lastname@example.org or write to us at 3 Churchill Court, Manor Royal, Crawley, RH10 9LU.
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Changes to this Notice
We may change this Notice from time to time. You should check this Notice occasionally to ensure you are aware of the most recent version.
This Notice was last updated on 12 June 2019.