Privacy
Your privacy is important to us. It is Penny Technology Limited's policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including via our app, Penny, and its associated services.
Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use an app or online service.
In the event our app contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our app.
This policy is effective as of 30 March 2021.
Last updated: 24 January 2023
Information We Collect
Information we collect falls into one of two categories: 'voluntarily provided' information and 'automatically collected' information.
'Voluntarily provided' information refers to any information you knowingly and actively provide us when using our app and its associated services.
'Automatically collected' information refers to any information automatically sent by your device in the course of accessing our app and its associated services.
Log Data
When you access our servers via our app, we may automatically log the standard data provided by your device. It may include your device's Internet Protocol (IP) address, your device type and version, your activity within the app, time and date, and other details about your usage.
Additionally, when you encounter certain errors while using the app, we automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.
Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.
Device Data
Our app may access and collect data via your device's in-built tools, such as:
Your identity
Camera
Phone/SMS
Notifications
Background data refresh
Mobile data
When you install the app or use your device’s tools within the app, we request permission to access this information. The specific data we collect can depend on the individual settings of your device and the permissions you grant when you install and use the app.
Personal Information
We may ask for personal information — for example, when you register an account or when you contact us — which may include one or more of the following:
Name
Date of birth
Phone/mobile number
Home/mailing address
Address History
Employment History
National Insurance Number
Sensitive Information
'Sensitive information' or 'special categories of data' is a subset of personal information that is given a higher level of protection. Examples of sensitive information include information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation, sexual practices or sex life, criminal records, health information, or biometric information.
The types of sensitive information that we may collect about you include:
Biometric information
We will not collect sensitive information about you without first obtaining your consent, and we will only use or disclose your sensitive information as permitted, required, or authorised by law.
Legitimate Reasons for Processing Your Personal Information
We only collect and use your personal information when we have a legitimate reason for doing so. In which instance we only collect personal information that is reasonably necessary to provide our services to you.
Collection and Use of Information
We may collect personal information from you when you do any of the following on our website:
Register for an account
Use a mobile device or web browser to access our content
Contact us via email, social media, or on any similar technologies
When you mention us on social media
We may collect, hold, use and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:
to provide you with our app and platform's core features and services
to enable you to customize or personalise your experience of our website
to deliver products and/or services to you
to contact and communicate with you
for analytics, market research, and business development, including to operate and improve our app, associated applications, and associated social media platforms
to enable you to access and use our app, associated platforms, and associated social media channels
for internal record keeping and administrative purposes
to comply with our legal obligations and resolve any disputes that we may have
for security and fraud prevention, and to ensure that our sites and apps are safe, secure, and used in line with our terms of use
for technical assessment, including to operate and improve our app, associated applications, and associated social media platforms
We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, If you consent to us accessing your social media profiles, we may combine information sourced from those profiles with information received from you directly to provide you with an enhanced experience of our app and services.
Collection of additional personal information
By agreeing to this Privacy Policy, you authorise Penny to perform a "soft" credit check in order to ascertain key information, such as your former names and addresses and other information to assist Us with locating your Qualifying Pension Arrangements.
Security of Your Personal Information
When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification.
Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure and no one can guarantee absolute data security.
You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services.
For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.
How Long We Keep Your Personal Information
We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy. For example, if you have provided us with personal information as part of creating an account with us, we may retain this information for the duration your account exists on our system. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you.
However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.
Children’s Privacy
We do not aim any of our products or services directly at children under the age of 13 and we do not knowingly collect personal information about children under 13.
Disclosure of Personal Information to Third Parties
We may disclose personal information to:
a parent, subsidiary or affiliate of our company
third-party service providers for the purpose of enabling them to provide their services including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing providers, professional advisors, and payment systems operators
our employees, contractors, and/or related entities
our existing or potential agents or business partners
credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you
courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights
third parties, including agents or sub-contractors who assist us in providing information, products, services, or direct marketing to you
third parties to collect and process data
an entity that buys, or to which we transfer all or substantially all of our assets and business
Third parties we currently use include:
Google Analytics
Facebook
Twilio Inc
Amazon Web Services
Google
SendGrid
Creditsafe Business Solutions
Origo Transfer Services
Onfido
WealthKernel
Aegon
Cofunds
OpenAI
Intercom Inc
IdealPostcodes
Scraper API