Last updated: 26 January 2018 (version 3)
Trezeo Limited ("We", “Us”, “Trezeo”) are committed to protecting and respecting your privacy.
This Notice describes the privacy practices of Trezeo, its subsidiaries and affiliated companies with respect to information relating to you that you or third parties provide to Trezeo, including information collected or provided on the Trezeo website www.trezeo.com (the Website) and Trezeo’s mobile application (the Mobile App).
Trezeo is a data controller and is registered in the UK with the Information Commissioner’s Office (the ICO) under registration number ZA286309 and in Ireland with the Office of the Data Protection Commissioner (the DPC) under registration number 17672/A.
By visiting and using our Website, you acknowledge and agree to the practices described in this Notice.
Our primary goal in collecting information about you is to provide you with your Trezeo Account and to manage your account effectively. The information we collect about you also helps us personalise and continually improve your experience at our Website through the Trezeo App and your experience of services provided by us and our affiliates.
We may collect and process the following data about you:
Information you give us: you may give us personal information such as names, email addresses, home addresses, dates of birth and other information such as bank account information, including login details, or demographic information when you complete forms, applications and/or surveys. This information may be given on our Website, via the Trezeo App or when you contact us directly, for example through our customer service department, either online or by telephone (as our calls are recorded for training and monitoring purposes)
Information we collect about you and your device: each time you visit the Website or use the Trezeo App we may automatically collect information such as:
Information we receive from other sources (Third Party Information): we work closely with third parties (such as account aggregation identify verification providers) and may receive information about you from those third parties, for example, financial information (including bank account details, balances and transactions) and information to verify your identity in line with anti-money laundering requirements.
Account Information Provider: We use account information providers, currently TrueLayer to enable us provide our services by securely accessing your bank account data.
TrueLayer is authorised by the UK Financial Conduct Authority under the Payment Services Regulations 2017 to provide account information services and payment initiation services (Firm Reference Number: 793171).
Payrnet Limited: PayrNet Limited (PayrNet) helps us to provide the Service by providing you with a Trezeo Account. We will transfer your data to PayrNet as part of the PayrNet service and PayrNet will be a data processor of your data. You also agree and grant Payrnet permission to pass your data to its own sub-contractors and partners when this data is necessary for PayrNet to fulfil its legal and regulatory obligations as an issuer of electronic money.
We do not seek or knowingly collect any personal data about children under 18 years of age.
We use your information in various ways, such as:
We may disclose your personal information to any member of the Trezeo group.
We may also share your information with selected third parties including:
We may disclose your personal information to third parties:
You will receive notice when information about you may be shared by us with third parties in circumstances not described above, and you will have an opportunity to notify us that you do not wish for such information to be disclosed.
We reserve the right to use and disclose all information that does not constitute "personal data" (i.e. that you cannot be identified from).
If you have any questions or concerns about the sharing of your information as described above, please contact us as described at the end of this Notice.
When you provide your information we will ask for your consent to contact you by telephone, SMS (Short Message Service), email or by post to assist you with your account or to provide you with information about similar products and services that we may provide. You are able to withdraw your consent in relation to us using your information for marketing purposes at any time in the following ways:
If you opt-out of our use of your information for marketing purposes, we will process your request as soon as possible. Please note that we reserve the right to take reasonable steps to authenticate your identity with respect to any such request.
We will only transfer your information to third parties for marketing purposes when we have obtained your express consent to do so.
We have measures in place to protect the security and confidentiality of your information and we strive to keep it accurate. We only keep your information for as long as is necessary and required by law. We generally keep records of any transactions that you enter into for a minimum of six years.
Some of the security measures include:
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.
If we transfer your personal data to a country outside the EEA we will ensure that the receiving party agrees to apply the same levels of protection as we are required to under applicable data protection legislation.
By providing us with your personal information on our Website or in the course of using our services, you consent to the transfer of your information in this way. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Notice.
Subject to certain exceptions, you have the right of access to information that we hold about you upon request. You can exercise this right by making a request in writing, by phone or email using the contact details in the contact section below. Where we receive a data access request, we may take steps to verify the identity of the requester.
You have the right to ask us not to process your information for marketing purposes (see above). We will usually inform you (before collecting your data) if we intend to use your data for such purposes. You can exercise your right to prevent such processing by checking certain boxes on our Website or other forms we use to collect your data. You can also exercise the right at any time by contacting us by post or email using the details in the contact section of this Notice (see below).
If you have any questions about how we treat your personal data and protect your privacy, or if you have any comments, please send them to us by email at firstname.lastname@example.org or by post to Trezeo Limited, Digital Exchange, Crane Street, Dublin 8, D08 HKR9, Ireland.
If you choose to visit our Website, your visit and any dispute over privacy, is subject to this Notice.
We reserve the right to change this Notice at any time by notifying you of the existence and location of the new or revised Notice or by posting the changes online at our Website.
Like many websites, we use "cookies" when you visit our Website. Cookies are pieces of information that are transferred to your computer's hard drive via your web browser and we use them for various purposes to improve your experience on our Website.
By visiting our Website you agree to us placing cookies on your device and accessing them when you visit the Website in the future.
Further information about cookies can be found at www.allaboutcookies.org.
A web browser is usually set to accept cookies automatically but can be changed to decline them. If you do not want to receive cookies from us, please follow the procedures below. These procedures do not apply to cookies that may be set by our business partners.
Please note that by deleting or disabling future cookies your user experience of our Website may be affected and you might not be able to take advantage of certain functions on the Website.
The “help” section in your browser should provide instructions on how to locate the file that stores cookies. We have set out some further information below that you may also find useful.