Privacy Policy

1. Our Privacy Policy

1.1. At Oval Money, we are committed to respecting and protecting your privacy. This Privacy Policy sets out the type of information we collect from you and what we do with that information. The terms set out should be read together with our Terms and Conditions.

1.2. By using the service offered by Oval Money you confirm that you accept the terms of this Privacy Policy and that you agree to be bound by them in your use of the service. If you do not agree, please do not use the service.


2. Data Controller (or Owner)

2.1. For the purposes of this Privacy Policy, the Data Controller is Oval Money LTD ("Oval", the "App" or "us") of 183 - 185 Bermondsey Street, London, England, SE1 3UW.

2.2. We are also registered with the Information Commissioner under registration number: ZA219393.

2.3. You may contact us at: privacy@ovalmoney.com


3. Data Processor

3.1.Amazon Web Services (AWS). Amazon Web Services (AWS). AWS is an appointed Data Processor by Oval. AWS provides the processing service of the Data collected through the use of the App. The processing of Data is carried out in respect of AWS Security Standards at all times. If personal data is transferred outside of the EEA, we always require that appropriate safeguards are in place to protect the information when it is processed.

3.2. Additionally, the Data may be accessible to certain types of persons in charge, involved with the operation of the App (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies). Apple Health Kit data and Google Fit data will not be used for any marketing purposes. The updated list of these parties may be requested from the Data Controller at any time.


4. Personal Data you give us

4.1. Oval collects the information you provide when you: correspond with us; fill in any forms; register to use the Oval app; take part in online discussions, surveys or promotions; open an account or use any of our services; enter a competition; speak with a member of our customer support team; or contact us for other reasons.

4.2. Oval will, by itself or through third parties, collect the following information: your name, address, and date of birth; your username, password and other registration information; your email address, phone number and details of the device you use (for example, your phone, computer or tablet); details of your bank account, including the account number, sort code and IBAN; records of our discussions, if you contact us or we contact you; and identification documents (such as your passport or driving licence number), copies of any documents you have provided for identification purposes, and any other information you provide to prove you are eligible to use our services.

4.3. Other types of Personal Data collected may be described in other sections of this Privacy Policy.

4.4. Failure to provide Personal Data may make it impossible for the App to provide its Service.


5. Information we collect from other sources

5.1. If you have location services in the Oval app switched on, we track your location using GPS technology and your IP address. This information may be used to improve and personalise our service.

5.2. Whenever you use our website or the Oval app, we collect the following information: information about your visit, including the links you have clicked on, 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 and clicks), and methods used to browse away from the page; technical information, including the internet protocol (IP) address used to connect your computer to the internet, your log-in information, the browser type and version, the time-zone setting, the operating system and platform, the type of device you use, a unique device identifier (for example, your device identifier, number, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use and so on; information stored on your device, including if you give us access to contact information from your address book, log-in information, photos, videos or other digital content, check-ins. The Oval app will regularly collect this information in order to stay up to date; and information on transactions (for example, payments into and out of your account), including the date, time, amount, currencies, exchange rate, beneficiary details, details 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, details of device used to arrange the payment and the payment method used.

5.3. We collect information from third parties, such as credit reference agencies, fraud-prevention agencies and partners who help us to provide our services. This includes your credit record, information to help us check your identity, and information relating to your transactions.

5.4. In cases where, in order to provide our service, personal data is to be collected from third parties who can be considered as autonomous data controllers, such as, for instance, likes on Facebook, Instagram or Twitter put by the Users, we guarantee to process this data exclusively for the fulfilment of contractual obligations related to our service.

5.5 Depending on your use of the service, we may also collect fitness data through Apple Health Kit or Google Fit. This data will be limited to activity data and will be used only to provide additional savings step options. Please review Apple’s privacy policy or Google’s privacy policy (depending on your device) for information on how Apple Health Kit or Google Fit uses and shares your personal information. This Privacy Policy does not apply to the collection and use of your information by Apple Health Kit or Google Fit.


6. Bank Account and Financial Details

6.1. The Service requires the processing in read only mode of your bank account details and financial data such as your transaction history and balance. To ensure the maximum level of protection of your Data, Oval collaborates with the following service providers that store and process User’s Data:

6.2. Salt Edge Inc. is an account aggregation service that allows the User to store its credit card and bank accounts’ credentials. Oval has signed up for the Global Data Aggregation API offered by Salt Edge Inc. and to get the most out of the App you may link your bank account(s) to the App by using Salt Edge’s platform service. Salt Edge will allow you to connect with your bank account(s) using your online login credentials and will store them through a bank-level security system. Oval will never store User’s personal online login credentials and will receive from Salt Edge only the information required to provide the service.

  • Collected Data: Full name, Email, Mobile Phone Number, Date of Birth, Nationality, Country of Residence and Address, Bank Account and other Financial Details, as specified in Salt Edge’s Privacy Policy.

6.3.Mangopay. Mangopay is the Application Programming Interface (‘API’) provided by Mangopay SA to issue and manage the distribution of e-money (as defined by Directive 2009/110/EC ‘E-Money Directive’) directly to the User. Through Mangopay’s service, Oval, as an e-money distributor, offers a payment solution for all transactions made by Users within the App. The payment solution is based on the e-money issued by Mangopay upon the demand and for the accounts of Users. The e-money is stored in a Mangopay electronic wallet (‘e-wallet’) specifically opened for the User. Mangopay is an autonomous Data Controller as to the service it provides and by having a Mangopay account opened for them, Users agree to be bound by Mangopay’s Terms and Conditions and Privacy Policy.

  • Collected Data: Full name, Email, Mobile Phone Number, Date of Birth, Nationality, Country of Residence and Address, Bank Account and other Financial Details as specified in Mangopay’s Privacy Policy.

6.4 Banca 5. Banca 5 is an Italian bank registered at the Italian Bank registry with number 5692. Oval allows you to open a payment account with Banca 5 and deposit money into it, using funds from your Connected Accounts, and withdraw money back to your Connected Accounts. Oval has no direct control over these funds. Banca 5 is an autonomous Data Controller as to the service it provides and by having a Banca 5 account opened for them, Users agree to be bound by Banca 5’s Terms and Conditions and Privacy Policy. Banca 5 also acts as a Data Processor for Oval and/or Issuers when you use the Platform Products.


7. Platform Services

7.1. The Platform Services requires us to collaborate with various service providers (Issuers) in order to offer a variety of options (Platform Products) for users to choose from. For each Platform Product offered on the Platform, the Issuer of each product is the Data Controller, and AWS is our appointed Data Processor.

7.2. For each Platform Product you will be provided with the Issuer’s Terms and Conditions, and Privacy Policy, before you are required to purchase any such products, and each Issuer will state the data they require us to process if you purchase any such products, in their Privacy Policy.


8. Fraud prevention, transaction monitoring, and account monitoring

8.1. Depending on your use of the service, we may also use your data to make certain automated decisions; this is called automated decision-making. We may use your personal data, including financial transaction data, to make automated decisions on the likelihood of you committing fraud on our platform. As a result of this automated decision making we may suspend your use of the services, either temporarily or permanently. You agree and acknowledge that you have understood this, and by accepting this Privacy Policy you agree and confirm that you give your explicit consent for this automated decision making to happen.

8.2. If you have been affected by the automated decision making, you may request human intervention or challenge the decision of the algorithm which results in the automated decision making by sending an email to privacy@ovalmoney.com with the words ‘automated decision making’ in the subject.

8.3. In addition to this we will use your personal information to help prevent fraud in a more general manner, by: trying to stop you from becoming a victim of fraud; confirming you are eligible to use our services; and complying with financial crime laws. The data we will use for these purposes comes from the information you have provided us, the information from your device, and/or the information from third parties. Our legal basis for this activity is in complying with our legal obligations, complying with agreements between you and us, and/or legitimate interests (to develop and improve how we deal with financial crime and meet our legal responsibilities).


9. Other uses of the Data collected

The Data we collect from Users are also used for the following purposes:

  • Registration. Through User registration or authentication, you give Oval your consent to be identified and to access the App’s services.
    • Facebook Authentication (Facebook, Inc.). Facebook Authentication is a registration and authentication service provided by Facebook, Inc., related to the social network Facebook.
      Collected Data: Public Profile, Email, Friends, Date of Birth, Events, Location, likes and pictures, as specified in the Privacy Policy of Facebook.

  • Analytics. The services described in this section allow the Data Controller to control and analyse traffic data. The services also allow the tracking of the User’s behavior.
    • Google Analytics is an analytics service provided by Google, Inc.
      Data collected: different types of Personal Data, such as Usage Data, as specified in the Privacy Policy of Google.

  • Email and Contact Management. These services allow the managing of email contacts and other contacts used to communicate with the User. The services may also allow the collection of Data concerning the date and time of display of the message by the User.
    • Sendgrid is an email management and storage service provided by Sendgrid.
      Data collected: Email, as specified in the Privacy Policy of Sendgrid.

    • Typeform is an online survey tool provided by Typeform S.L.
      Data collected: Email, as specified in the Privacy Policy of Typeform.

    • Intercom is a communication platform developed by Intercom Inc. focused on communication with the User.
      Collected Data: Email and Name, as specified in the Privacy Policy of Intercom.

    • Newsletter By registering to the newsletter service, the User’s email address is inserted in a mailing list. They will receive emails containing information, also of commercial and promotional nature, regarding Oval.
      Data collected: Email and Name.

  • Advertising. This type of services allows User Data to be utilised for advertising communication purposes displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
    • AdWords is a remarketing and behavioral targeting tool to advertise across websites provided by Google, Inc.
      Collected Data: Usage Data and various types of Data, as specified in the Privacy Policy of Google.

    • Facebook Conversion is a tracking tool for ads on the social network Facebook provided by Facebook, Inc.
      Collected Data: Usage Data and various types of Data, as specified in the Privacy Policy of Facebook.

10. Mode and Place of Processing the Data

10.1. Security Measures

10.1.1 Oval processes Users’ Personal Data in a proper manner and shall adopt appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data. Even where all precautions are adopted we cannot guarantee complete security in all events.

10.1.2. The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated.

10.2. Place of processing

10.2.1. The Data is processed at the Data Controller's operating offices and where the Data Processor’s operating offices or other parties involved with the processing are located. If we or our service providers transfer personal data outside of the EEA, we always require that appropriate safeguards are in place to protect the information when it is processed.

10.3. Retention time

10.3.1. The Data is kept strictly for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this Privacy Policy.

10.3.2 The User may always request that the Data Controller suspend or remove the Data.


11. Data Transfer

11.1. The User consents to the transfer of the collected Data through the Service in the event of rearrangement, merger, sale, joint venture, transfer or any other arrangement method of the whole or part of the Company, of its goods and shares, according to the purpose and the limits of this document.


12. Legal Action

12.1. Your Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this App or related services.

12.2. You acknowledge to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.


13. Rights of Users

You have the right, at any time, to:

13.1. Know whether your Personal Data has been stored and may consult the Data Controller to learn about their contents and origin (right of access);

13.2. Verify your Personal Data accuracy or ask for them to be supplemented, updated or corrected (right to rectification);

13.3. Request the erasure of your Personal Data or their transformation into anonymous format (right to erasure);

13.4. Request the restriction of processing of your Personal Data for any and all legitimate reasons (right to restriction of processing);

13.5. Receive your Personal Data in a structured, commonly used and machine-readable format and to transmit those data to another controller (right to data portability);

13.6. Withdraw the consent to the processing of your Personal Data at any time, without prejudice to the lawfulness of the processing based on consent before its withdrawal;

13.7. Object to the direct marketing activities carried out by Oval Money, including any segmentation for marketing purposes.

Requests should be sent to the Data Controller at: privacy@ovalmoney.com


14. Changes to the present Privacy Policy

14.1. The Data Controller reserves the right to change this Privacy Policy at any time by giving notice to its Users through this page. It is recommended, therefore, to check this page often and refer to the latest update date at the bottom of the page. If a User objects to all or any of the changes to the Policy, you must cease using the App and may request that the Data Controller remove your Personal Data. Unless stated otherwise, the then-current Privacy Policy applies to all your Personal Data processed by the Data Controller at the time.


Definitions

Personal Data (or Data)

Any information regarding a natural person, which is, or may be, identified or identifiable, even indirectly, by reference to any other information, including a personal identification number.

Usage Data

Information collected automatically from this App (or Third Party services employed in this App), which may include: IP addresses or domain names of the computers used by the Users, URI addresses (Uniform Resource Identifier), time of the request, method of request submission to the server, size of the file received in response, numerical code indicating the status of the server's answer (successful outcome, error, etc.), Country of origin, features of the browser and the operating system utilised by the User, various time details per visit (e.g., time spent on each page within the App) and details about the process followed within the App, specifically the visited pages sequence and other parameters about the device operating system and/or the User's IT environment.

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or organisation, also jointly with another Data Controller, having the right to make decisions regarding the purposes and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this App. The Data Controller, unless otherwise specified, is the Owner of this App.

User

The individual using this App, which must coincide with or be authorised by the Data Subject, to whom the Personal Data refers.

Data Processor

The natural person, legal person, public administration or any other body, association or organisation authorised by the Data Controller to process the Personal Data in compliance with this Privacy Policy.

Platform Services

As defined in Paragraph 1 of Section 2 (Platform Terms) of our Terms and Conditions.

Issuer

Entities which provide the Platform Products.

Platform Products

The products offered and provided by the Platform and which are made available through the Oval Services.

Last updated: 01/07/2019

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