Our privacy notice, incorporating our use of cookies.

Who we are

Wink Money Ltd T/A Switcheze, is the data controller responsible for your personal data.

About this privacy policy

This notice sets out in clear and plain language our commitment to protecting and respecting your privacy and your data rights as required by the United Kingdom General Data Protection Regulation (the “UKGDPR”). If there is anything you do not understand after reading it please contact us using the details you will find below.

Here is where we explain:

• What information we may collect and how we may collect it
• How and why we may use it
• How we keep it secure
• Your rights in respect of your personal data

It applies whenever we collect your personal data (including when you use our website or other digital platforms), so please read it carefully.

The types of personal data we use and its sources.

In order to operate our business and provide our products to our customers we gather several different categories of personal data.

Some of this data we gather directly from you online as part of registration, some we obtain indirectly by reason of your interactions with us on our website and some from third party sources where you give us permission or it necessary to perform the contract or comply with a legal obligation such as credit references agencies, fraud prevention agencies and any third party you might seek assistance form which contacts us on your behalf.

These categories of personal data include:

• Financial and employment data that you provide or we obtain from credit reference agencies or your bank
• Personal data about you such as name, D.O.B, address, mobile number and such may include family and relationship information where you have dependents or share your home with people
• Transactional data that we obtain during the time you have a contract with us
• Technical data we capture from the devices and technology you use to interact with us such as IP addresses
• Special types of data that you specifically consent to allow us to use such as data relating to religious or ethnic origin, religious beliefs, genetic and biometric data, health data and data relating to any criminal convictions and offences
• Socio-economic data that we gather to perform analyses of you and your account
• Marketing preferences

We are required to inform you of the purposes for which we use your personal data, the legal reasons for doing so and, if we rely on a so-called “legitimate interest” as a reason, to tell you what that legitimate interest is.

A legitimate interest reason for using your data is one which is justified for a good business or commercial purpose such as marketing.

Who we share your data with?

We may also share your personal data with the following categories of third party. Any such sharing data will be under a contract requiring compliance with rules protecting your privacy:

• Business partners who we use to provide support services such as providers of postal or other data processing services.
• Agents who we use to perform our contracts.
• Collection agencies who we use to collect monies due if you fail to pay us.
• Advertisers and advertising networks.
• Analytics and search engine providers.
• Credit reference agencies.
• Fraud prevention agencies.
• The Financial Conduct Authority, other regulators and authorities.
• Third parties that you ask us to share your personal data with such as your bank or a money advisor.
• IT providers.
• Price comparison websites and other credit brokers
• Companies which we may wish to buy or which might wish to buy us.
• Business partners from which we require services such as our banks.

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment.

Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by clicking here.

How we protect your data

The security of personal information about you is our priority. We protect this information by maintaining physical, electronic, and procedural safeguards that meet or exceed applicable law. We train our employees in the proper handling of personal information. When we use other companies to provide services for us, we require them to protect the confidentiality of personal information they receive.

There has been an upsurge in email 'phishing' activity, where fraudsters send emails to customers and using an array of deceptions, encourage them to give out sensitive personal banking details. Please note, that we will never ask you to send your personal or security details or update them via email, and if you are ever asked to do so, please call us first.

IMPORTANT INFORMATION

We need to collect personal data from you for performance of a contract and for compliance with our legal obligations. You may refuse to provide us with your personal data at any time in our relationship because you object to such processing but if you do so we may have to terminate our relationship with you. If you do withdraw consent where we have asked for it this will not invalidate the use of your personal data prior to the withdrawal.

Sending Personal Data outside the EU

We may send your personal data outside the EU in order to enable us to perform the contract, comply with a legal obligation or where we have a legitimate interest in so doing. We ensure data security with this processor by means of a contract.

Before we send any personal data to an organisation outside the EU we will make sure it is protected to the same or similar standards as if it was being used within the EU by means of contracts between us and the overseas processor or in reliance on the EU Commission’s finding of that country having adequate data protection provisions in place. If the personal data is processed in the USA we will ensure that the processor is subscribed to the Privacy Shield which establishes common privacy standards between the US and EU.

Automated Decision Making and Profiling

We will use your personal data to make automated decisions. This is done in order to determine whether we, or a third party wish to enter into a contract with you and to determine your creditworthiness and affordability in the quickest, fairest and most legally compliant way using credit scoring and past payment history to predict future performance. We will also monitor your account using automated means for fraud detection and crime prevention purposes.

The automated decision may result in our partners refusing you credit.

We regularly test our decision making to ensure it is working appropriately and accurately.

If you are dissatisfied with the result of this automated processing you have the right to seek an explanation and request a person review the decision.

Sharing your data with Credit Reference and Fraud Prevention Agencies

In order to process your account, we may perform credit and identity checks on you with one or more credit reference and fraud prevention agencies (“CR/FPAs”).

To do this, we will supply your personal information to CR/FPAs and they will give us information about you. This will include information from your application and about your financial situation and financial history. CR/FPAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.

We will use this information to:

• Assess your creditworthiness and whether you can afford a partners product
• Verify the accuracy of the data you have provided to us
• Prevent criminal activity, fraud and money laundering
• Manage your account(s)
• Ensure any offers provided to you are appropriate to your circumstances 

Your Rights

You have a number of rights in respect of how we use your personal information:

• You have to right to withdraw consent at any time and require us to cease any data processing which we are undertaking relying solely on consent.
• You have the right to ask us to rectify any inaccuracies in your personal information.
• You have the right to ask us to erase or restrict processing of your personal information if it is no longer necessary for us to process in accordance with any contract or legal obligation or legitimate interest.
• You have the right to ask us to cease or not to process your personal data for marketing purposes.
• Trace and recover debts
• You can exercise the above rights by contacting us by post to Data Protection Officer, at Wink Money Ltd, 16 Littlebrook, Paulton, Bristol, BS39 7PA or email dpo@winkmoney.com

Complaints

If you are dissatisfied about how we have used your personal data you can contact us at complaints@winkmoney.com Alternatively, you also have the right to complain to the Information Commissioner’s Office although they will ask you whether you have raised the matter with us beforehand. Find out how to report a concern on their website: www.ico.org.uk/concerns

Data Retention

We will process your personal data for either as long as you have a contractual relationship with and / or an active online account . If you stop transacting with us, we will keep your personal data for no longer than 6 years. We do this because we are obliged to hold transactional data for 5 years by law and in order to answer any regulatory inquiries or respond to any complaints during this period.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Cookies Policy

Our website uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site.

What are cookies?

A cookie is a small file of letters and numbers that we store on your browser of your computer if you agree. We store corresponding information to the one we set in your browser and in this file we can track and keep information on your movements within the site and any information you may have given while visiting the site.

There are two types of cookies: session cookies and persistent cookies. Session cookies are created temporarily in your browser’s subfolder while you are visiting our site. Once you leave the site, the session cookie is deleted. Persistent cookie files remain in your browser’s subfolder for a period of time after you have visited our site. You can find out more about cookies by visiting www.allaboutcookies.org

Information about our use of cookies

We use the following session and persistent cookies:

Strictly necessary cookies.

These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to complete a loan application form on our site. 

Analytical/performance cookies.

They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies.

These are used to recognise you when you return to our site. This enables us to personalise our content for you and remember your preferences.

Targeting cookies.

These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site and any advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Blocking Cookies

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.