Squirrel Privacy and Cookies Policy

Squirrel is committed to protecting your privacy. This Privacy Policy sets out the details of the information that we may collect from you and how we may use that information when you use any of our products and services, our app and our websites. Please take your time to read this Privacy Policy carefully. This Privacy Policy should be read alongside, and in addition to all product and service specific terms and conditions.

  1. About us
  2. What personal information do we collect and use and who do we collect it from?
  3. How do we collect your information
  4. What are the purposes for which your personal information is used
  5. How will your personal information be used?
  6. Who do we share your information with?
  7. What marketing activities do we carry out?
  8. Data anonymisation and aggregation
  9. How long do we keep personal information for?
  10. What is our approach to international data transfers
  11. Your rights under applicable data protection law
  12. Keeping your information up to date
  13. Further information
  14. Cookies
  15. Updates to this Privacy Policy

1. About us

In this Privacy Policy references to “us”, “our”, “we”, or “Squirrel” are to Squirrel Financial Wellbeing Limited.

Squirrel Financial Wellbeing Limited is a company registered in England and Wales (company registration number 08621129) with its registered office at Lower Ground Floor, 10 Finsbury Square, London EC21 1AF. Squirrel Financial Wellbeing Limited is regulated by the Financial Conduct Authority under registration numbers 619488 & 9000036.

Squirrel acts as data controller in respect of your personal information that we process.

If you have any questions about how we collect, store or use your information, please contact us on support@squirrel.me.

2. What personal information do we collect and use and who do we collect it from?

We will collect personal information like your name, address and date of birth when you apply for, or use any of our products or services. We will also collect data from your use of our website and app. The type of information that we collect from you will depend on your relationship with us:

Please note that your external security details will be stored on a third party secure server and not on your mobile phone. Your external security details will be encrypted when stored and encrypted when data is transmitted – we will never see or have access to your external security details.

3. How do we collect your information

We collect information from you:

4. What are the purposes for which your personal information is used

Data protection law says that we are allowed to use personal information only if we have a proper reason to do so. We’ll process your personal data on the following legal basis and for the following purposes:

5. How will your personal information be used?

We will use the personal information we hold about you, and data from the technology/devices you use to access your account(s) to: • Provide, manage and develop our products and services • Understand your preferences and advise you about our other products and services • Undertake market research, transactional analysis, statistical analysis and system testing • Update our records • Recover debt • Confirm your location • Assess whether you can afford any credit you’ve applied for • Prevent and investigate fraud, money laundering and other crimes If we believe that you have tax obligations in another country, we may disclose personal information of yours with those tax authorities, or with HM Revenue and Customs, who may share the information with the other tax authorities. We may search, use and share the records held by domestic and international credit reference agencies and fraud prevention agencies, as well as our own internal records to: • Confirm your identity and prevent fraud or money laundering

6. Who do we share your information with?

We disclose your information to the third parties listed below for the purposes described in this Privacy Policy. You can contact us for details of specific disclosures made in respect of your information:

We will make sure that anyone acting on our behalf only uses your personal information in line with our instructions and that they keep the data safe.

We won’t share or give your personal information to external companies for their own marketing purposes.

7. What marketing activities do we carry out?

We may also use your personal information to provide you with information about products or services which may be of interest to you where you have provided your consent for us to do so.

We are committed to only sending you marketing communications that you have clearly expressed an interest in receiving. If you wish to unsubscribe from emails sent by us, you may do so at any time by clicking on the “unsubscribe” link that appears in all emails. Otherwise you can always contact us at support@squirrel.me to update your contact preferences.

8. Data anonymisation and aggregation

Your personal data may be converted into statistical or aggregated data which cannot be used to identify you, then used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described above.

9. How long do we keep personal information for?

We only keep personal information for as long as reasonably necessary to fulfil the relevant purposes described in this Privacy Policy and in order to comply with our legal and regulatory obligations.

After you stop being a customer, we may keep your data for up to 7 years for one of these reasons:

We may keep your data for longer than 7 years if we cannot delete it for legal, regulatory or technical reasons.

10. What is our approach to international data transfers

Some of our suppliers who process your data in accordance with this Privacy Policy may be outside the UK and the European Economic Area (“EEA”). When they do, we will have a contract in place to make sure the recipient protects the data to the same standard as is required in the EEA.

11. Your rights under applicable data protection law

You have certain rights under applicable data protection law, these rights are:

You can find out more information about your rights at the Information Commissioner’s website: www.ico.org.uk

If you choose not to give us the personal information that we request either during an application process or during the life of an account or product, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform the services needed to manage your accounts/provide your chosen products and services. It could mean that we have to cancel a product or service you have with us.

Please let us know if you are unhappy with how we have used your personal information. You can contact us at support@squirrel.me. You also have the right to complain to the Information Commissioner’s Office who can investigate our compliance with data protection law. Find out how at www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Our ICO registration number is ZA017754.

12. Keeping your information up to date

We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, please notify us of any changes to the personal information that you have provided to us by updating your details on the Squirrel App or by contacting us at support@squirrel.me.

13. Further information

We are required to employ adequate technical and organisational security measures to protect your personal information from any loss, destruction, damage or unlawful disclosure. However, please remember that no transmission over the Squirrel App or the Squirrel Website can ever be guaranteed as secure. Consequently, please note that we cannot guarantee the security of any personal information (including external security details) which you transfer via the Squirrel App or the Squirrel Websites.

14. Cookies

When you interact with our content and services, we try to make that experience simple and meaningful. When you visit our Site or App our web server sends a cookie to your device. Cookies are small pieces of information which are issued to your device when you visit a website and which store and sometimes track information about your visit. A number of cookies we use last only for the duration of your browser session and expire when you close your browser. Other cookies are used to remember you when you return and will last for longer. Some of the cookies used by the Site or App are set by us, and some are set by third parties who are delivering services on our behalf.

We use the following types of cookies:

Strictly necessary cookies
We use a session cookie on our Site so that users can move easily from one page to another within the Site and so that page requests are loaded in smooth manner. We also use login-in session cookies for security purposes to authenticate valid users accessing the secure area of the App.
Functionality
We use functional cookies that enable the user to operate the Site or App by storing their preferences and selections. In particular we use a cookie to set the correct language in the App for the user.
Performance
We use cookies to collect statistical information about how visitors behave on our Site and App so that we can make improvements to our content and services. For example we log what pages in the Site or App are visited and what a user clicks on, as well as remember that a user has visited us before so that we can count the number of unique visitors we receive to different parts of the Site or App. This also allows us to make sure we have enough capacity for the number of users that we get and to customise elements of the promotional layout and/or content. We use Google Analytics cookies for this purpose. You can opt out from Google Analytics tracking at http://tools.google.com/dlpage/gaoptout

15. Updates to this Privacy Policy

We may update this Privacy Policy from time to time to ensure that it remains accurate. Please check back each time you provide additional personal information to us.

This Privacy Policy was last updated on: 18 May 2018