Important: by accessing and/ or using our services (including our website or any of our mobile applications), you acknowledge that we may process your personal data in accordance with this Privacy Policy. If you do not accept the Privacy Policy, please do not access the Paylow app or use our services.
This Privacy Policy describes our data practices regarding personal data we collect in compliance with applicable data protection laws.
This Privacy Policy does not apply to any personal data collected by third party websites or apps not operated by Paylow.
You are not legally required to provide us with personal data, however, some parts of our services may require you to do so. In these cases, if you choose to withhold any personal data we request, it may not be possible for you to access or use certain features of your Paylow account. We recognize that privacy is important. This Privacy Policy applies to all of the services, information, tools, features and functionality offered byPaylow or its subsidiaries or affiliated companies and covers how we treat personal data.
If you have any questions about this Privacy Policy, please feel free to contact us at office@paylow.app.
Please also read our terms of use at www.paylow.app/terms-of-use, which describe the general terms that apply to your Paylow account
The controller of your personal data isPaylow Systems UK Limited (14599130), a registered company in England, having its registered place of business at 7 Savoy Court, London WC2R 0EX; registered with the Information Commissioner's Office (ICO) reference number ZB503371.
To provide our services, we require you to grant us a read-only access to your bank account for purposes of providing your transaction history information, specifically information relating to transactions, direct debits and standing orders. We refer to this kind of data as account information.
We use a tool provided by TrueLayer Limited(www.truelayer.com) (“TrueLayer”) to gain access to your bank account information, subject to your acceptance of TrueLayer’s terms and conditions. We explain our relationship with TrueLayer in more detail, as well as your relationship with TrueLayer when you sign up for a Paylow account, in our general terms and conditions.
We will use your account information to:
(a) collect and track financial information on all your transactions and payments for the purpose of identifying your subscriptions;
(b) conduct comparisons of subscription pricing and value which is offered by third party vendors as generally available in the market; and
(c) switch your subscription to alternative providers or offerings with your current providers (at your discretion) to get better value for your subscriptions.
We sometimes need to use tools provided by third parties to access your personal data. If you do not enable these providers (including TrueLayer) to provide us with your personal data, we may not be able to provide you with some or all of our services.
We need to process your personal data to provide our services and to enter into and perform a contract with you describing how these services will be provided.
In order to provide and improve our services, and for marketing and customer relations purposes, we may collect and process the following categories of your personal data, for the following purposes and on the following legal bases:
(a) Data: When creating an account, we ask you to provide your full name and email address.
(b) Purpose: We process this information for the purpose of allowing you to create a Paylow account.
(c) Legal basis: This processing is necessary for conclusion and performance of a contract between you and us.
Once you successfully register for aPaylow account, you will be redirected to TrueLayer to enable TrueLayer to collect account information from your bank account and to transfer that information to us.
(a) Data: When you use Paylow, we may ask you to provide information such as your location, age, family status, preferences or other information relating to the way in which you spend money.
(b) Purpose: We process this information to personalise and improve our services.
(c) Legal basis: This processing is necessary for the purposes of our legitimate interest to personalise and improve our services.
Where the law requires you to consent to the processing of some data such as location data, we will ask for your valid consent.
(a) Data: We may request you provide us with supporting ancillary documentation and records regarding your transaction history (i.e.invoices, receipts, or other records of payment).
(b) Purpose: We process this information to provide you with our services, where necessary.
(c) Legal basis: This processing is necessary for performance of a contract between you and us.
(a) Data: Your emails or other communications to us.
(b) Purpose: We process this information to process your inquiries and respond to your requests.
(c) Legal basis: This processing is necessary for performance of a contract between you and us (based on your request).
(a) Data: Your contact and identification information, your preferences.
(b) Purpose: We will process this data to send you newsletters and promotional communications, and offer services or products we believe you may be interested in.
(c) Legal basis: This processing is necessary for the purposes of our legitimate interest to promote our services.
If (1) you are not our customer yet, or if we (2) wish to promote services of any third parties, or (3) communicate your contact information to any third parties to enable them to send you their marketing communications, we will ask for your consent before we do this.
You may opt-out of this service, including participation in mailing list, at any time, by submitting a request at the following link: office@paylow.app.
Please note that even if you opt-out of receiving marketing communications, we may still send you a response to any“Contact Us” request as well as administrative e-mails necessary to facilitate your use of our services.
(a) Data: When you use our services, we may automatically receive and record technical information from your browser or device, including information and statistics about your online/offline status, your IP address, internet service provider, search history, pages visited, impressions, links clicked, language preferences, the website visited before visiting Paylow, the date and duration of the visit per page or other item, type of browser or device, unique device identifiers, your regional and language settings and software and hardware attributes. Our systems may automatically record and store technical information regarding the method and nature of your use of our services.
(b) Purpose: We use all technical personal data that we collect to understand the usage trends and preferences of our users, to develop, improve, support, and operate our services, further develop our service offerings and/or for statistical purposes.
(c) Legal basis: This processing is necessary for the purposes of our legitimate interest to understand your use of our services and to improve our services for you and other users.
Where the processing of such technical data involves the use of cookies or other trackers that are subject to consent, we will ask for your valid consent.
(a) Data: Your contact and identification information, your employer’s name, other information that may be available in your LinkedIn profile.
(b) Purpose: We will process this data to provide you with a service you requested, establish your interests profile, and offer you our services that we believe may be relevant for you.
(c) Legal basis: This processing is necessary for the purposes of our legitimate interest to promote our services.
This processing may be based on your consent where required under applicable law.
We may process your personal data to protect the integrity of our services; to prevent, detect, mitigate, investigate, and protect against misuse of our systems, fraud, crime, security breaches, and potentially prohibited or illegal activities such as money laundering, or otherwise to protect our or third-party rights or interests.
This processing is based on our legitimate interests to ensure security of our services.
We may process your personal data to comply with the law; to resolve disputes; to cooperate with government or other legal inquiries, and to respond to subpoenas, court orders, or legal process; fulfill regulatory reporting obligations; to establish or exercise our legal rights or defend against legal claims and otherwise protect our or others’ rights/assets.
This processing is based on our legal obligations, and/or, where non-applicable, our legitimate interests to comply with applicable regulations and defend our interests in court.
We may process your personal data in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence.
This processing is based on our legitimate interests to enter into business transactions.
In order to collect the data described herein we may use temporary cookies that remain on your browser or device for a limited period of time. We may also use persistent cookies that remain on your browser or device until the services are no longer accessed, in order to manage and maintain our services and record your use thereof.
A cookie is a small piece of information which is sent to and stored on your browser or device. Cookies do not damage your browser or device. You may not be able to use some Paylow features if you block them.
We may also use web beacons to collect information. Web beacons, or "gifs", are electronic images that maybe used in the Paylow app or in our emails. We use web beacons to deliver cookies, count visits and to tell if an email has been opened and acted upon.
We may use remarketing services to inform you of new programmes, blogs, and opportunities by placing ads on third party websites to you. We and our third party vendors, use cookies to inform, optimize and serve ads based on your past visits to our website or app.
To opt in or opt out of certain cookies, please modify your cookie settings through the “Learn more and customize” link. You can find more information about cookies used on our services in our Cookies policy (available at www.iubenda.com/privacy-policy/82216642/cookie-policy).
We may display links to other services, sites, and applications on our services for your convenience. We are not responsible for the privacy practices or the content of other sites and applications, and you visit them at your own risk. This Privacy Policy applies only to personal data collected by us through your use of our services .
For us to be able to provide our services, our affiliates, agents, and representatives may need to have access to your personal data.
We may also need to contract with partners and third party service providers to perform certain functions on our behalf. To this end, we limit these parties’ access i to the personal data they need to perform the functions they carry out on our behalf. We require these parties to process your personal data in compliance with this Privacy Policy and subject to security and other appropriate confidentiality safeguards.Examples include service providers who enable switching services for your subscriptions with various suppliers (such as gas, electricity, broadband etc.).
We may also share your personal data in the following circumstances:
· With our potential business partners or advisors if we become involved in are organisation, merger, consolidation, acquisition, or any form of sale of some or all of our assets;
· With our service providers or consultants to ensure security and for purposes of debugging;
· With competent authorities, public bodies, officers of the law, ministerial officers, debt collection bodies, lawyers, and consultants, to satisfy applicable law or prevention of fraud or harm or to enforce applicable agreements and/or their terms, including investigation of potential violations;
· The ads appearing on our services, if any, may be delivered to you by third-party network advertisers, ad agencies, analytics service providers, and other vendors to provide us with data regarding use of and traffic (including without limitation the pages viewed and the actions users take when visiting) and the effectiveness of our advertisements. These third parties may set and access their own tracking technologies on your device (including without limitation cookies and web beacons) and may otherwise collect or have access to data about you (such as device identifier). Some of these parties may collect personal data over time when you visit our services;
· If you have an account on social network sites and access our services, we may receive information from such social networks, and the social network services may receive information relating to your use of our services. For example, such data sharing is in place for LinkedIn Lead Generation.
We follow generally accepted industry standards to protect against the unauthorised access to or unauthorised alteration, disclosure or destruction of your personal data. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we strive to protect your personal data, we cannot guarantee its absolute security.
We only keep your personal data for as long as reasonably necessary for the purposes for which it was collected or to allow us to comply with any legal obligations.
Our criteria for determining the period during which we keep your personal data include considering the time period reasonably necessary to provide our services to you, exercise the choices and rights you have requested, comply with our contractual obligations, enforce our terms for use of our services, and comply with legal and regulatory requirements.
For specific details regarding our retention practices, please refer to our Data Retention Policy.
The following rights are extended to you with respect of any personal data collected or processed by the Company, as required of the Company under applicable law. We have summarised below your rights in relation to the personal data we collect and process:
(a) Right of Access and Rectification. You have the right to know what personal data we collect about you and to ensure that this data is accurate and relevant for the purposes for which we collected it. We allow our users the option to access and obtain a copy of their personal data and to rectify such personal data if it is not accurate, complete, or updated. However, if we can’t confirm your identity when you request this copy, we may need to ask you for further information or documents to identify you.
(b) Right to Delete personal data or Restrict Processing. You have the right to request us to delete your personal data or restrict its processing. We may postpone or deny your request if your personal data is in current use for the purposes for which it was collected or for other legitimate purposes such as where we are legally required to retain or process this data.
(c) Right to Withdraw Consent. You have the right to withdraw your consent to the processing of your personal data that is based on your consent. This will not affect any data we process before you withdraw your consent.
(d) Right to Object. You have the right to object to our processing if we are processing your personal data based on legitimate interests, using your personal data for direct marketing (including profiling),or processing your personal data for purposes of scientific or historical research and statistics.
(e) Right of Data Portability. Where applicable, you have the right to ask to transfer your personal data to a third party service provider in accordance with your right to data portability.
You may exercise the above rights by sending a request to office@paylow.app.
(f) Right to Lodge Complaint. You also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of your personal data. In the UK, this is the Information Commissioner’s Office.
We may update this Privacy Policy from time to time. We will notify you about significant changes in the way we treat your personal data by sending a notice to the email address linked to your Paylow account or by placing a prominent notice on our website or app. We encourage you to periodically review this Privacy Policy for the latest information about our privacy practices.
Any changes will be effective immediately once the revised Privacy Policy is made available on our website unless otherwise specified. If you continue to use our services after the changes become effective, we will assume you agree to these changes.
The server on which our services are hosted and/or through which our services are processed may be outside the country from which you access our services. .
Some of the data uses and disclosures mentioned in this Privacy Policy may involve the transfer of your personal data to various countries around the world that may have different levels of privacy protection than your country and may be transferred outside of the UK or the European Economic Area.
If there is a transfer of your personal data outside the UK or EEA we will, in the absence of an applicable adequacy decision relevant to the destination country or to the transfer, rely on appropriate safeguards such as the UK International DataTransfer Agreement, or UK International Data Transfer Addendum to the EUStandard Contractual Clauses (see https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/international-data-transfer-agreement-and-guidance/). .
Last updated: 17 September 2023
