For the Data Protection Act 1998, the data controller is Budd inc. of [your company address with commissioner reference number].
In this policy, “Buddtoken,” “we,” “us,” “our” means, collectively, Budd inc. “You,” “your” or “yours” means the persons to whom this policy applies.
The security of your personal data is important to us.
1.1 What personal data we collect
“Personal data” is data that can be used to identify a natural person. Some examples of personal data that we may collect are:
- Personal particulars (e.g., Name, contact detail,s, residential address, date of birth, identity card/passport details, and education details)
- Financial information (e.g., Income, expenses, and/or credit history);
- Images and voice recordings of our conversations with you;
- Employment details (e.g., Occupation, directorships and other positions held, employment history, salary, and/or benefits);
- Tax and insurance information;
- Information about your risk profile, investments, investment objectives, knowledge and experience and/or business interests and assets;
- Banking information (e.g., Account numbers and banking transactions); and/or
- Personal opinions made known to us (e.g., Feedback or responses to surveys);
Data we collect
We will collect and process the following data about you:
- The information you give us (Submitteinfoon): This is information you give us about you by filling in forms on the App and/or the Site, or by corresponding with us (for example, by e-mail or via the chat functions on the App and/or the Site). It includes information you provide when you register to use the App, download or register the App, subscribe to any of our services; enter into any transaction on the App or the Site, participate in discussion boards or other social media functions on the App or the Site, enter a competition, promotion or survey, and when you report a problem with an App, the Services, or the Site. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, address, date of birth, e-mail address, phone number, the Device’s phone number, username, password and other registration information, financial, details of your bank account including the bank account number, bank sort code, IBAN, details of your debit and credit cards including the long number, relevant expiry dates and CVC, identification document numbers, copies of identification documents (for example, passport, driving licence and utility bill) personal description and photograph and any other information you provide us in order to prove your eligibility to use our services.
- Information we collect about you and your device. Each time you visit the App or our Site we will automatically collect the following information:
- Technical information, including the internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information and 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, time zone setting (Device Information);
- Information about your visit, including the full uniform resource locators (URL), clickstream to, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, device information and any phone number used to call our customer service number;
- Transaction information including date, time, amount, currencies used, exchange rate, beneficiary details, details and location of the merchant or ATMs associated with the transaction, IP address of sender and receiver, sender’s and receiver’s name and registration information, messages sent or received with the payment, device information used to facilitate the payment and the payment instrument used.
- Information stored on your Device, including if you allow Buddtoken access contact information from your address book, login information, photos, videos or other digital content, check ins (Content Information). The App will periodically recollect this information in order to stay up-to-date;
- Details of your use of our App or your visits to our Site including transaction details relating to your use of our services, including who you have sent money or electronic money to, foreign exchange transactions you have entered into, the time, date and location of the place the transaction was entered into.
- Location information. We use GPS technology and your IP address to determine your location – this may be used when the App is running in the foreground and the background of your Device. This is used to prevent fraud, for instance if your mobile phone is saying that you are based in Canada but your card is being used to enter into an ATM Withdrawal or point of sale purchase in Spain, we may not allow that transaction to be processed. Our card protection and fraud-prevention measures require this personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by de-selecting “location based security” on the Card Security part of the App
- Information we receive from other sources (Third Party Information). We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, fraud prevention agencies, customer service providers, developers, social media organisations such as Facebook, Twitter and/or Google).
You are entitled to access your personal records held by credit and fraud prevention agencies. If you would like details of the credit reference and fraud prevention agencies from which we have obtained or may obtain information about you, please contact us [official email address]. If you allow us to, we will collect friends lists from Facebook and similar information from other third parties such as Twitter and Google – the App will periodically re-collect this information in order to stay up-to-date. We will also receive information about you from third parties we use to verify your identity.
1.2 Usage of your personal data
We may use your personal data for our core business purposes, such as:
- Developing and providing facilities, products or services (whether made available by us or through us), including but not limited to:
- Transactions and clearing or reporting on these transactions;
- Carrying out research, planning and statistical analysis; or
- Analytics for the purposes of developing or improving our products, services, security, service quality, and advertising strategies;
- Assessing and processing applications, instructions or requests from you or our customers;
- Communicating with you, including providing you with updates on changes to products, services and banking facilities (whether made available by us or through us) including any additions, expansions, suspensions and replacements of or to such products, services and banking facilities and their terms and conditions;
- Managing our infrastructure and business operations and complying with internal policies and procedures;
- Responding to queries or feedback;
- Addressing or investigating any complaints, claims or disputes;
- Verifying your identity for the purposes of providing facilities, products or services;
- Conducting credit checks, screenings or due diligence checks as may be required under applicable law, regulation or directive;
- Complying with all applicable laws, regulations, rules, directives, orders, instructions and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities;
- Enforcing obligations owed to us;
- Monitoring products and services provided by or made available through us;
- Complying with obligations and requirements imposed by us from time to time by any credit bureau or credit information sharing services of which we are a member or subscriber;
- Creating and maintaining credit and risk related models;
- Financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
- Enabling any actual or proposed assignee or transferee, participant or sub-participant of Buddtoken’s rights or obligations to evaluate any proposed transaction;
- Enforcing obligations owed to us; and/or
- Seeking professional advice, including legal counsel.
We may also use personal data for purposes set out in the terms and conditions that govern our relationship with you or our customer.
1.3 Use of personal data for marketing purposes
We may use your data to offer you products or services, including special offers, promotions, contests or entitlements that may be of interest to you or for which you may be eligible. Such marketing messages may be sent to you in various modes including but not limited to electronic mail, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services. In doing so, we will comply with applicable data protection and privacy laws.
In respect of sending telemarketing messages to your telephone number via short message service, telephone calls, facsimile, and other mobile messaging services. Please be assured that we shall only do so if we have your explicit and unambiguous consent in writing or other recorded form to do so or if you have not otherwise made the appropriate registration of that number with the Do Not Call Registry.
If we have an ongoing relationship with you, and you have not indicated to us that you do not wish to receive telemarketing messages sent to your telephone number, we may send you telemarketing messages to that number related to the subject of our ongoing relationship via short message service, facsimile and other mobile messaging services (other than a voice or video call).
You may at any time request that we stop contacting you for marketing purposes via selected or all modes. To find out more about how you can change the way we use your data for marketing purposes, please contact us at [official email address].
Nothing in this section shall vary or supersede the terms and conditions that govern our relationship with you.
1.4 Disclosure and sharing of personal data
We may from time to time and in compliance with all applicable laws on data privacy, disclose your data to any personnel of Budd inc. or to third parties, whether located London or elsewhere, to carry out the purposes set out above. Please be assured that when we disclose your data to such parties, we require them to ensure that any personal data communicated to them are kept confidential and secure.
For more information about the third parties with whom we share your data, you may, where appropriate, wish to refer to the agreement(s) and terms and conditions that govern our relationship with you or our customer. You may also contact us for more information (please see the “How to contact us” section below).
We wish to emphasize that Buddtoken does not sell personal data to any third parties and we shall remain fully compliant of any duty or obligation of confidentiality imposed on us under the applicable agreement(s) and/or terms and conditions that govern our relationship with you or our customer or any applicable law.
We may transfer, store, process and/or deal with your data outside of Canada. In doing so, we will comply with applicable data protection and privacy laws.
1.5 Cookies and related technologies
You may set up your web browser to block cookies from monitoring your website visitors. You may also remove cookies stored on your computer or mobile device. However, if you do block cookies, you may not be able to use specific features and functions of our websites.
1.6 Other web sites
1.7 Retention of personal data
Your data is retained as long as the purpose for which it was collected remains and until it is no longer necessary for any other legal or business purposes.
1.8 Access and correction
You may request access or make corrections to your data held by Buddtoken. Buddtoken may charge a fee for processing your request for access. Such a price depends on the nature and complexity of your access request. Information on the processing fee will be made available to you.
Please contact us at [official email address] for details on how you may request such access or corrections.
We may amend this policy from time to time to ensure that this policy is consistent with any developments in the way Buddtoken uses your data or any changes to the laws and regulations applicable to Buddtoken. We will make available the updated policy on our website. All communications, transactions, and dealings with us shall be subject to the latest version of this policy in force at the time.