Curve

Curve App and Website Privacy Policy

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Curve App and Website Privacy PolicyLast updated: 16 April 2021 Who are we? We’re Curve (we, us, our). When you choose Curve, you choose a company that is committed to protecting your data. As well as bringing you financial freedom, we’re here to provide transparency about your personal information - which is just what this privacy notice is for.  We are made up of Curve OS Limited (UK),&nbsp. Curve Credit Limited (UK), Curve Europe UAB (Lithuania) and Curve US Inc. (US).&nbsp. We will let you know which Curve company you have a relationship with when you first apply for or use a Curve product or service. If you’re based in the UK, Curve OS Limited is your data controller. We’re registered with the UK Information Commissioner’s Officer with reference ZA135276. If you’re based in the rest of Europe, Curve Europe UAB is your data controller. We’re registered with the UK Information Commissioner’s Officer with reference ZA881683. If you use any of our credit services, Curve Credit Limited is your data controller. Our group Data Protection Officer is The Law Boutique Limited, incorporated and registered in England and Wales with company number 09509112, whose registered office is at Flat 17, 12 Ebenezer St, Hoxton, London, England, N1 7RP. They can be contacted at dpo@imaginecurve.com. Got questions? Just drop our friendly customer support team a line at support@curve.app or get in touch via the Curve app. What information do we collect about you? Identity <ul> <li> Full name  </li> <li> Date of birth </li> <li> ID document details </li> <li> Selfie photograph </li> <li> Employment status and industry </li> </ul> Financial Details of the funding card(s) added to your Curve account and your Curve card including your card number, expiring date, CVV number, name and billing address Details of your credit history held at credit reference agencies Contact <ul> <li> Home and shipping address </li> <li> Email address </li> <li> Mobile number </li> </ul> Transaction  Information about your transactions and purchases Device Internet Protocol (IP) address used to connect your computer/mobile device to the internet location, model of your phone, Geo-location Profile Your communication preferences, social media handles, feedback, survey and questionnaire responses. Aggregated Aggregated data such as statistical or demographic data. This means your data is bundled up with other people’s data and you aren’t identifiable as an individual. However, if you are identifiable, that information will be treated in accordance with this policy Where do we get your information from?  Direct interactions, including when you: <ul> <li> Create an account </li> <li> Use one of our products (including features like Curve Send)  </li> <li> Request marketing </li> <li> Contact us or provide feedback </li> <li> Use Curve Community </li> </ul> Automatic collection by us, including: <ul> <li> Technical data from your electronic devices, browsing actions and patterns.  </li> <li> This is collected using cookies, server logs and similar technologies. </li> </ul> From third parties or publicly available information, including:  <ul> <li> Analytics providers </li> <li> Payment services and e-wallet providers </li> <li> Customer service providers </li> <li> Electoral register </li> <li> Governmental agencies </li> <li> Credit reference agencies </li> </ul> What do we use your information for?  We’ll only use your data to help provide the best product experience possible and where it's lawful to do so: Purpose: Signing you up as a Curve customer and creating your account Data: Identity, Contact, Financial, Device Lawful basis: Contract, Legal obligation (the law requires us to verify your identity) Purpose: Confirm your identity and help prevent fraud Data: Identity, Contact, Financial, Transaction, Device Lawful basis: Legal obligation, Legitimate interests (to ensure we use the best fraud prevention providers when performing our services) Purpose: Provide you with Curve products and services and manage your account Data: Identity, Contact, Financial, Transaction Lawful basis: Contract, Legitimate interests (to provide you with services and recover fees) Purpose: Conduct credit checks and provide Curve credit products and services Data: Identity, Contact, Financial, Transaction Lawful basis: Consent Purpose: Process your payment transactions, including Curve Send Data: Identity, Contact, Financial, Transaction, Device Lawful basis: Contract, Legal obligation, Legitimate interests (to facilitate transactions and maintain integrity of Curve systems) Purpose: Provide you third-party services, including Samsung Pay Data: Identity, Financial, Transaction, Profile Lawful basis: Contract, Consent (for profile data) Purpose: Manage our relationship, including updates to our terms and providing top-notch customer support Data: Identity, Contact, Transaction, Profile, Device Lawful basis: Contract, Legal obligation, Legitimate interests (to keep our records updated, delight our customers and improve our product) *Please note we may record your calls with our customer services team for training and monitoring purposes. Purpose: Improve our services and troubleshoot Data: Identity, Contact, Device Lawful basis: Legitimate interests (to delight our customers and improve our products). Purpose: Suggest goods, services, programmes or activities that may be of interest to you  Data: Identity, Contact, Device, Profile, Financial, Transaction Lawful basis: Consent, Legitimate interests (to develop our product offering and grow our business). Purpose: Send you marketing communications Data: Identity, Contact, Profile, Device, Transaction Lawful basis: Consent, Legitimate interests (to ensure you are kept up to date with our services) Purpose: Comply with regulations and legal obligations Data: Identity, Contact, Financial Lawful basis: Legal obligation We’ll only ever use your personal data for the purpose we collected it or a similar, connected purpose. If we ever need to use your information for an unrelated purpose, we’ll let you know and explain why. We may also be required by law to process your personal data without your knowledge or consent. Who do we share your data with and why?  When we share data with third parties, they can only process it for specific purposes and in accordance with our instructions. Here’s who we share data with and why: Curve group companies  We share your personal data within our Curve&nbsp. group of companies in order to provide you with the best service. Sign-up and verification checks Identity checking and fraud prevention partners. When Curve shares data with identity and fraud prevention partners, they will become a joint controller of your data to determine how your data will be used to best provide their services. Hosting and IT services IT vendors including cloud storage providers to securely store your personal data. Making and sending your Curve card Card manufacturing, personalisation and delivery companies. Payment processing Financial services providers, including card issuers, payment processors and banking partners to facilitate payment transactions. Our payment processing activities for customers in Europe will be carried out by Curve Europe UAB as it is licensed to provide financial services in Europe in accordance with EU financial regulations. People or companies that you transfer money to from your Curve card  Where you make a payment from your Curve account, we will share your first and last name with the recipient in their transaction history. Curve Send We may share your data with other customers when you use Curve Send. If you turn on Curve Send, you will be prompted to connect your contacts list with the app. We will regularly scan this list to identify contacts to whom you can make and receive payments. You will also see the senders details on your bank statement. Insurance (Curve Black &amp. Metal only) For Curve Black &amp. Metal customers, your information is shared with insurance provider Inter Partner Assistance SA, member of the AXA Assistance group, Avenue Louise 166, 1050, Brussels, Belgium, insurance company regulated by the National Bank of Belgium under the number 0487, Company number 0415 591 055 (AXA).  You will enter into a separate agreement with AXA to enable them to provide you with insurance. This means AXA is wholly responsible for your data for insurance purposes (rather than Curve). Further information is available here. Social media marketing for targeted marketing purposes Social media sites, for the purposes of conducting market research and running marketing campaigns. When sharing data with these sites, we ensure that your data is only used in accordance with our instructions. If you don’t want us to use your information in this way, you can contact us at support@curve.app or via the app. Open banking We partner with Plaid to allow you to view account information from other payment providers on our app. If you would like to use this feature, Plaid will prompt you to connect your other payment accounts to the Curve app. This data will be sent to Curve to display on the app. This allows you to see your various account transactions and balances in one place. When you consent to the use of your data and enable this feature, both Curve and Plaid will become independent controllers of your data as we will independently determine the best means of processing your data to deliver the service to you. We may also anonymise the data collected from Plaid to improve our products and services. For more information on how Plaid will use your data, please see their Privacy Policy. Individual credit products When you apply, use or register for credit products, we may perform hard credit and identity checks on you with one or more credit reference agencies (CRAs). We may also make periodic soft credit checks on you to manage your account with us or fulfil our services. To do this, we may supply your personal information to CRAs and they will give us information about you.  We will use this information to: <ul> <li> Assess your creditworthiness and whether you are suitable for Curve products </li> <li> Verify the accuracy of the data you have provided to us </li> <li> Confirm your identity and prevent criminal activity, fraud and money laundering </li> <li> Manage your account </li> <li> Trace and recover debts </li> <li> Ensure any offers provided to you are appropriate to your circumstances </li> <li> Provide you with access to your credit bureau data where you have asked us to. </li> </ul> The Credit Reference Agency Information Notice (CRAIN) describes how the three main credit reference agencies in the UK each use and share personal data. The CRAIN is available on the credit reference agencies’ websites: <ul> <li> www.callcredit.co.uk/crain </li> <li> www.equifax.co.uk/crain </li> <li> www.experian.co.uk/crain </li> </ul> We may continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs. Hard credit checks will appear on your credit file and may affect your credit rating. Soft credit checks will not appear on your file and will not affect your credit rating. We may also request information on your other payment accounts to perform an affordability check. You will be prompted to connect your other payment accounts on the Curve app. This information will be shared directly with Plaid and subsequently shared with Curve.&nbsp. Curve will share this information with Credit Kudos to determine your affordability score. When you consent to share this data with us, Curve, Credit Kudos and Plaid will become independent controllers of your data as we will independently determine the means of processing your data. For information on how Credit Kudos will use your data, please see their Privacy Policy. SME credit products When you apply for SME credit products, we will conduct commercial credit checks on your business and you, as a director, using one or more CRAs. We will use this information to assess your creditworthiness and the affordability of repayments. We will continue to exchange information about your business with CRAs while you have a relationship with us. We will also inform the CRAs about your business’ settled accounts and if your business has any outstanding debt. This information may be supplied to other organisations by CRAs. We may also use DueDil to collect and verify your business information. When we receive information from DueDil, both Curve and DueDil will become independent controllers of your data as we will independently determine the means of processing your data. Please note that this service is only available to Curve customers who self-attest as a company director.  For more information on how DueDil uses your data, please refer to their Privacy Policy. Fraud prevention agencies The personal data 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 information can be found here. Samsung Pay If you register your Curve card on Samsung Pay, we will share your data with Samsung to authorise payments, display transactions, prevent and detect fraud, comply with legal requirements and industry standards. If you consent to marketing from Samsung, you consent to Curve sharing your profile data with Samsung for their marketing purposes.  If you participate in the Curve-Samsung referral program, your data will be used to verify that you are a Samsung Pay customer and to facilitate the provision of your reward. For more information on how Samsung will use your data, please see their Privacy Policy. Please note that Curve is not responsible for the security of Samsung Pay or any third party provider to Samsung. Any information you give them is covered by their own Terms and Conditions. Support tools Analytics and search engine service providers and customer experience support platforms to optimise and improve our services. If you contact our customer services line out of hours, our external team will manage your enquiries. We will become joint controllers of your data as they will determine the means of collecting your data on our behalf. Third-party payment partners Third party payment service partners including Apple Pay, Samsung Pay and Airplus. Curve will only share your data with a third-party payment partner if you have opted to use their service with your Curve card. When we share your data with third-party payment partners, they will become an independent controller of your data to determine how your data will be used to best provide their services. Business reorganisation / sale Third parties we may sell the business to or acquire. We may also share anonymised, aggregated data with selected e-wallet and data analytics service providers. This means your data is bundled up with other people’s data and you aren’t identifiable as an individual.  What are your rights?  <ul> <li> Access the personal data we hold about you and/or in some circumstances, have it sent to another person. </li> <li> Correct your personal data by asking us to correct it for you. </li> <li> Request deletion of your data, although for legal reasons we might not always be able to do so. </li> <li> Restrict or object to our processing for direct marketing. </li> <li> Withdraw any consent you’ve given us to use your personal data in a specific way. </li> <li> Request a review of any automated decision made by technology. </li> </ul> If you want to do any of the above, drop our friendly customer support team a line at support@curve.app or via the Curve app. We have one month to respond unless your request is complicated, in which case we may need more time. If that’s the case, we’ll let you know. This is almost always free but we’re allowed to charge a reasonable fee or refuse your request if it’s clearly unfounded, repetitive or excessive. What about marketing?  You can ask us to stop sending you marketing emails at any time by following the unsubscribe links at the bottom of any Curve marketing message. You’ll still receive operational emails we need to send you, such as updates to our terms and conditions. If you would like to stop receiving Curve receipt emails (for each of your payments), you can change your preferences for each of your funding cards on the Curve app. Do you make automated decisions about me? Depending on the Curve products or services you use, we may make automated decisions about you. This means that we may use technology that can evaluate relevant factors about you and your circumstances to predict risks or outcomes. We do this for the efficient running of our services and to make sure that the decisions we make are fair, consistent and based on the correct information. Where we make an automated decision about you, you have the right to ask that it is manually reviewed by a human.  For example, we may make automated decisions about you that relate to: The approval of credit applications  <ul> <li> Credit and affordability checks to see whether we can accept your credit application. </li> <li> Setting credit limits. </li> </ul> Opening a Curve&nbsp. account <ul> <li> Anti-money laundering and sanctions checks. </li> <li> Identity and address checks. </li> </ul> Detecting fraud <ul> <li> Monitoring your account to detect fraud and financial crime. </li> </ul> Our legal basis for our use of automated decision making is to enable us to fulfil our contract with you or because we have a legal obligation to do so. How long do we keep your data?  The period for which we may retain data about you will depend on the purposes for which the data was collected, whether you have requested deletion of the data, and whether we have any legal or regulatory obligation to retain the data. We will not retain data about you for longer than is necessary to fulfil the purposes for which the data was collected. We will typically keep your data for up to 10 years after you last completed onboarding or had an active account or product with us. We may keep your personal data for a longer period where it is necessary for legal, regulatory or operational purposes. If a decision has not been made on your onboarding application, we will keep your data for up to 30 days. International data transfers  We may transfer and store the data we collect from you to organisations outside the European Economic Area (EEA). When we do this, we make sure that your data is secure, protected and that: <ul> <li> the European Commission says the country or organisation has adequate data protection laws in place, or </li> <li> we’ve agreed to standard data protection clauses in a written contract with the organisation, approved by the European Commission. </li> </ul>  How can you complain?  We hope you don’t ever need to, but if you do want to complain, you have the right to do so to the Information Commissioner's Office (ICO) however we’d love to try and sort it out first. Drop us an email at support@curve.app. How can you contact us?   If you have any further questions or would like to exercise any of the rights set out above, please contact us at support@curve.app or via the app. We always welcome your comments or suggestions, including thoughts on how we can improve or clarify this privacy policy.