Privacy Notice of Banked Ltd.

Banked Ltd collects some Personal Data from its Users.

Data Controller

Banked Ltd
151 Wardour St,
Unit 5.01,
London,
W1F 8WE
UK

Controller contact email: support@banked.com

Types of Data collected

Among the types of Personal Data that Banked Ltd collects, by itself or through third parties, there are: Cookies; Usage Data; email address; name; account number, sort code, IBAN, Universally unique identifier (UUID); Data communicated while using the Service.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy notice or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Banked Ltd.

Unless specified otherwise, all Data requested by Banked Ltd is mandatory and failure to provide this Data may make it impossible for Banked Ltd to provide its Services. In cases where Banked Ltd specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Controller.

Any use of Cookies – or of other tracking tools – by Banked Ltd or by third-party services used by Banked Ltd serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through Banked Ltd and confirm that they have the third party's consent to provide the Data to the Controller.

Mode and place of processing the Data

Methods of processing

The Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Banked Ltd (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Controller. The updated list of these parties may be requested from the Controller at any time.

Legal basis of processing

The Controller may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Users may withdraw their consent at any time.

• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

• processing is necessary for compliance with a legal obligation to which the Controller is subject;

• processing is related to a task that is carried out in the public interest;

• processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party.

In any case, the Controller will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Controller's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the United Kingdom or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Controller to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Controller using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Controller and the User shall be retained until such contract has been fully performed. Please note that, when applicable, this may include retaining your data for refund purposes or until your right to be issued a refund expires.

• Personal Data collected for the purposes of the Controller’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Controller within the relevant sections of this document or by contacting the Controller.

The Controller may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Controller may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Controller to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Tag Management, Managing contacts and sending messages, Contacting the User, User database management and Interaction with live chat platforms.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following third parties:

Services

Banked Ltd will provide the Services including initiating payments and, where relevant, processing refunds.

Rapyd (Cashdash UK Limited)

Rapyd will be enabling Banked Ltd to process refunds for payments initiated by the User. Personal Data processed: Name, account number, sort code, IBAN. Place of processing: United Kingdom – Privacy Policy

Analytics

The services contained in this section enable the Controller to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google Ireland Limited)

Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of Banked Ltd, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. Personal Data processed: Cookies; Usage Data. Place of processing: Ireland – Privacy Policy 

Contacting the User

Mailing list or newsletter (Banked Ltd)

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Banked Ltd. Personal Data processed: email address; first name; last name.

Interaction with live chat platforms

This type of service allows Users to interact with third-party live chat platforms directly from the pages of Banked Ltd, in order to contact and be contacted by Banked Ltd‘s support service.

If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

Zendesk Chat (Zendesk, Inc.)

Zendesk Chat is a service for interacting with the Zendesk live chat platform provided by Zendesk, Inc. Personal Data processed: Data communicated while using the service; email address; Usage Data. Place of processing: United States – Privacy Policy.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Mailchimp (Intuit Inc.)

Mailchimp is an email address management and message sending service provided by Intuit Inc. Personal Data processed: email address; first name; last name. Place of processing: United States – Privacy Policy.

Tag Management

This type of service helps the Controller to manage the tags or scripts needed on Banked Ltd in a centralized fashion.

This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

Segment (Segment Inc.)

Segment is a tag management service provided by Segment.io, Inc. Personal Data processed: Cookies; Usage Data. Place of processing: United States – Privacy Policy.

Google Tag Manager (Google Ireland Limited)

Google Tag Manager is a tag management service provided by Google Ireland Limited. Personal Data processed: Usage Data. Place of processing: Ireland – Privacy Policy.

User database management

This type of service allows the Controller to build user profiles by starting from an email address, a personal name, or other information that the User provides to Banked Ltd, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Controller can display and use for improving Banked Ltd.

Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Banked Ltd.

Intercom (Intercom Inc.)

Intercom is a User database management service provided by Intercom Inc.

Intercom can also be used as a medium for communications, either through email, or through messages within Banked Ltd. Intercom Messenger may use Trackers to recognize and track Users behavior. Personal Data processed: Data communicated while using the service; email address; Trackers; Universally unique identifier (UUID); Usage Data; various types of Data as specified in the privacy notice of the service. Place of processing: United States – Privacy Policy.

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Controller.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out based on legitimate interests or for the purpose of direct marketing. Further details are provided in the dedicated section below.

• Access their Data. Users have the right to learn if Data is being processed by the Controller, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Controller will not process their Data for any purpose other than storing it.

• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Controller.

• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

• Lodge a complaint. Should Users be dissatisfied with the service we provide, Users have the right to file a formal complaint to the Information Commissioner's Office at www.ico.org.uk, or to the relevant data protection supervisory authority in their country of residence.

Details about the right to object to processing

Where Personal Data is processed Controllerfor the purposes of the legitimate interests pursued by the Controller, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Controller is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Controller through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Controller as early as possible and always within one month.

Cookie Policy

Banked Ltd uses Trackers. To learn more, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Controller in Court or in the stages leading to possible legal action arising from improper use of Banked Ltd or the related Services.

The User declares to be aware that the Controller may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy notice, Banked Ltd may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Banked Ltd and any third-party services may collect files that record interaction with Banked Ltd (system logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this notice

More details concerning the collection or processing of Personal Data may be requested from the Controller at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

Banked Ltd does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy notice

The Controller reserves the right to make changes to this privacy notice at any time by notifying its Users on this page and possibly within Banked Ltd and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Controller. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Controller shall collect new consent from the User, where required.