Privacy Policy

Data privacy and security hold critical importance to us at Coupay. In this Policy document, Coupay will be referred to as ‘we’, ‘us’, or ‘our’. Additionally, “you” would imply a visitor to our site, or a user of our Services (“Customer” or “Provider”), or a customer of Customer (“End User”).

Coupay is registered with Companies House England and Wales (Reg no. 12328174) and regulated by FCA, UK (Firm no. 920839). We are the data controller for the purposes of the personal data we collect via our website or our software products or tools and for the performance of the services requested by you or on your behalf (together, the “Services”).

We may have third parties acting on our behalf to offer the Services and as our agents, we may elect for them to have similar rights to your Personal Data.

When you use our Services we will have access to your personal data that you may submit to us and personal data held by Account Servicing Payment Service Providers (i.e. any payment service provider, such as a bank or a credit card issuer that maintains an online payment account on your behalf) (“ASPSPs”) (“Personal Data”) for the duration of the transmission.

Such Data may include your name, gender, address, date of birth, account information, account balance, transactions, your customer information and other financial or non-financial data. The manner in which we access, use, process and store your personal data for the provision of the Services is set out below.

When you use our website (the “Site”) we will collect browser information, including your IP address. We will also store cookies (see our Cookies section for more details).

Use of your data

You may use our Services which will include the following:

If you have signed up on our website or any Software Tool or provided consent in any other form, we will use your email address or contact details to contact you in relation to products, events and service-related matters
Software tool (“Tool”) you use to transmit information back and forth relating to payment accounts (“Account Information”) that you hold with ASPSPs, for Account Information Services (AIS) or Payment Initiation Services (PIS), which you can use to consent to and authorise a payment or sharing your Account Information as specified by your Provider or us; this may require that you or Provider sends us your bank account details;
You may need to provide the same identifying information that you use to login to your online bank account to access your relevant payment accounts with your bank (“Credentials”).
The Tool may allow you to use your Credentials to retrieve such Account Information as you choose to transmit to Customer or us.

Retention

We or our third parties will not retain your information for any longer than we think it's necessary. Information that will be retained for as long as needed in order to:

fulfil the purposes outlined in the ‘Use of your personal data’ section above;
in line with our legitimate interest;
or for a period specifically required by applicable regulations or laws, such as retaining the information for regulatory reporting purposes.
our contractual obligations and rights in relation to the information involved;
legal obligation(s) under applicable law to retain data for a certain period of time;
statute of limitations under applicable law(s);
fraud and risk management;
(potential) disputes; and
guidelines issued by relevant data protection authorities.

Deletion

We will not keep your Personal Data for longer than necessary. We will delete your Personal Data:

as soon as it is no longer needed to provide the Services to you;
upon termination of the Terms of Service; and / or
if You withdraw Your consent, and Your consent is necessary for us to retain the data.

Sharing of Data with third parties

We may share your Personal Data with selected third parties, including business partners, suppliers and sub-contractors that assist us in the provision of our Service to you. The third-party providers used by us will only collect, use and disclose your information as instructed by us to provide Services to you or for their own audit, regulatory or compliance needs.

We may also disclose your Personal Data to other third parties in the event that:

We reasonably consider that we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or
in order to enforce or apply our Terms of Service and other agreements; or
to protect the rights, property, or safety of Coupay, our customers, or others.

Below are our legal reasons for processing your personal data:

For the performance of a contract with You or Your Provider;
For the purpose of furthering Coupay’s legitimate interests including providing better products, services, websites and applications, to operate our websites and applications.
With your consent to provide you with updates of our products, events and service-related matters.

Consent

When you use our services you may provide us with your Credentials and we require your consent to use those Credentials to:

retrieve your Account Information (including any Personal Data);
to provide such Account Information to the Providers which referred you to us;
improve the Services or the Tool.
temporarily access your payment account to debug any issues and to improve our automated processes for retrieving data.

The Personal Data we collect about You may be stored and processed to provide, maintain and improve our Services and Tool.

Your Personal Data may be anonymised, to be part of a market study or analytics by us or a third party. On our website, we may use tool to process data in an anonymous form to provide us information about the use of our Site.

When you have signed up on our website for marketing purposes you provide your personal information voluntarily and we can only send you updates with your consent.

Security

We use industry-standard encryption methods to ensure the security of your Personal Data in accordance with applicable law and regulation but cannot guarantee the security of any data transmitted to a Provider using our Tool. Once we have received your information, we take reasonable precautions to ensure that it is not lost, misused, accessed, disclosed, altered or destroyed. If you have reason to believe that your Personal Data is no longer secure (for example if you feel that the security of your Personal Data has been compromised then please contact us immediately).

Cookies

When you browse the Site, we automatically receive your computer’s internet protocol (IP) address. We collect data about how you interact with our website through the use of cookies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer, if you agree. Cookies contain information that is transferred to your computer's hard drive.

Our Site uses cookies to distinguish you from other users of our website. It helps us to remember your preferences. When you visit our Site, Cookies allow us to keep track of how many times you’ve visited us, how long you’ve visited us for and what you’ve done whilst you’ve been on our Site.

We use cookies to enhance your online experience of our Site and to better understand how our Site is used. Cookies help to ensure that what you see online is more relevant to you and your interests, based on information you’ve previously entered on our Site. The length of time the cookie is stored depends on that cookie, but this can vary from between a few minutes to up to two years.

Cookies never store any of your banking details.

We use the following types of cookies:

‘Session cookies’ which exist only while your browser is open. These cookies let us see where you’ve spent time on our Site and which part of the Site is the most or least effective. These are deleted automatically once you close your browser; and
‘Persistent cookies’ which survive after your browser is closed. They can be used by the site to recognise your computer or mobile device when you open your browser and browse the Internet again.
‘Third Party cookies’ these are cookies set by a domain other than our Site or a third party. These work by sharing your browser identification with that third party (like Facebook, Google), so that they can show you ads on their sites.

Here is a list of cookies that we may use; the list is not exhaustive and we’ve listed them here so that you could opt out of the cookies if you choose to.

Cookie name	Purpose	Source	Session/Persistent
coupay_session,termsAccepted	Controls user session	coupay.co.uk	Session
__utm*,__utma, __utmb, __utmc, __utmz, _ga, _gat, __utmz	Anonymous performance monitoring. To opt out of these cookies, please click here.	Google	Persistent

Minors

Our Services are not intended for use by anyone younger than 18 years old. Please do not use our Services if you are under 18.

Your Rights Subject Access Requests

You have the right to ask us to provide any personal data we have collected about You, to You. Should You wish to do so, please email us at privacy@coupay.co.uk to make a subject access request detailing:

your name,
your address,
the details of your Provider, and
the period of data you’d like access to.

Making a complaint to a supervisory authority

Should you be dissatisfied with the service we provide, You have the right to file a formal complaint to the Information Commissioner's Office at www.ico.org.uk.

Object to Direct Marketing

You have the right to ask us at any time to stop processing your Personal Data for direct marketing at any time. We provide for the right for you to unsubscribe from any of our marketing material at any time.

The Right to be Forgotten

If after you provided your consent, you change your mind, you may withdraw your consent by contacting us at our address or at the email address set out in the contact information above.

Changes to this Privacy Policy

Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Questions and Contact Information

If you would like to access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information about how we process your Personal Data, you can contact us at privacy@coupay.co.uk