14th September 2019
1. Who we are
1.1 VibePay (“VibePay”) is a social payments app that enables registered users (“Users”) to communicate directly, in real-time via an in-built chat messaging programme. Users can request money instantly and subsequently receive money by way of linking their bank account securely, via the Open Banking technology (“Open Banking” information can be found via their website).
1.2 The VibePay platform (“platform”) refers to both the mobile application ‘app’ and the website ‘site’ and all the information provided within it. The app is available on iOS and Android under the name ‘VibePay’, and the website is currently located at vibepay.com.
1.3 The VibePay service (“Service”) available on our platform is provided to you by Vibe Pay Limited (“Vibe Pay”), a company registered in England and Wales via Companies House under company number 11118944, with the Registered Office at The Storey, Meeting House Lane, Lancaster, England, LA1 1TH.
2. Privacy responsibilities
2.1 If you are a registered VibePay user (“User”), subscriber or a visitor to our platform, Vibe Pay act as the data controller (“Data Controller”) of your personal data (“Personal Data”). This means we control how and why your data (“Data”) is processed.
2.2 Vibe Pay is compliant with the Data Protection Act 2018, which states that you have the right to find out what information the government and other organisations store about you. These include the right to:
-be informed about how your data is being used
-access personal data
-have incorrect data updated
-have data erased
-stop or restrict the processing of your data
-data portability (allowing you to get and reuse your data for different services)
-object to how your data is processed in certain circumstances
2.3 Vibe Pay are also registered with the Information Commissioner’s Office (ICO), who are the independent regulatory office in charge of upholding information rights in the interest of the public. The organisation covers the Data Protection Act. The ICO can be contacted in the case of any complaints, queries or concerns you have about the data Vibe Pay holds about you.
2.2 The following are your responsibilities:
2.You must also read and accept VibePay Terms and Conditions
3. Stages of data collection
3.1 We begin collecting data about you as soon as you have made contact with us via our platform. This can be data that you provide to us, or data that we collect automatically.
3.2 The stages at which we may collect your data, and how it is collected are as follows:
1.When you browse any page of our website or through our app, we may collect data
2.When you create an account, we will collect the data you provide
3.When you use our Services, we may collect data and we will collect any data you provide
4.We will collect the data you provide with regards to your opt-in options to marketing communications
5.We may collect data from your communications with us for customer support or from concerns you raise
4. What data we collect
4.1 Personal information – Such as your full name (as provided to us), email address, and mobile phone number.
4.2 Payment information – When you choose to create a group (“Group”) and subsequently taken through to your bank via open banking to receive payments, or invited to a group via a link and also taken through to your bank to make a payment, we will capture your bank provider, your sort code and account number, the time and date of the payment, the same for the recipient, and the amount of the transaction.
4.3 Data that identifies you – We may collect data that can be used to identify you and/or your location. This includes your IP (internet protocol) address, login information, browser type and version, geolocation information about where you might be, operating system and version, device ID, device type, and cookie information.
4.4 Images and recordings you upload – We may capture and store profile pictures, and any images or recordings (visual or audio) you add to chat messages.
4.5 Your use of VibePay – We capture data about how you use VibePay such as your paths taken through our platforms, options viewed, any interactions with your Group contacts, how long each action takes you to complete, what actions you take, how often, and other actions.
4.6 Communications with our team – Messages you send to us via social media, our email addresses, the post or any other method.
5. How and why we use your Data
5.1 We can only use your data where we have a legal basis to do so. The uses of your information are as follows:
1.Managing our relationship with you, this includes, managing your requests, creating your user account, creating a group chat, your interaction with your contact(s), login and authentication (making sure you are who you say you are), remembering your settings, preferences, and to ensure access to your bank via Open Banking.
2.Improving the VibePay Platform or service, such as testing new or redesigned features, interacting with feedback platforms, surveys and questionnaires, managing our platforms, traffic optimisation and data analysis and research
4.Monitoring your marketing preferences this includes sending you emails and messages about new features, products and services, competitions, articles and content. We’ll only ever contact you with marketing messages if you have given us your explicit consent to do so. (see section 6).
5.To help us investigate any suspicions or notifications of illegal or prohibited activity (see VibePay Terms & Conditions)
6.Compliance with any legal or regulatory requirements imposed on us, such as liaising with law enforcement on any concerns they have, or providing reporting information to our regulator.
6. Marketing Communications
6.1 Under the General Data Protection Regulation 2016 (“GDPR”), individuals are given more control of their data. Where marketing preferences are concerned in order for marketing communication to be lawful, an individual must give consent with a clear affirmative action. In other words, individuals need a mechanism that requires a deliberate action to opt in.
6.2 We ask you specifically to opt-in to receiving marketing messages from Vibe Pay. This request is made when you sign up for access to the VibePay app via the VibePay site https://vibepay.com/ or download the app.
6.3 You can opt-out or unsubscribe from our marketing at any time, either within the app or by contacting us directly by email at email@example.com or write to us at Vibe Pay Limited, The Storey, Meeting House Lane, Lancaster, Lancashire, LA1 1TH, United Kingdom.
7. Disclosure of your personal data
7.1 Your information is of the utmost importance to us and we will not share your data outside of our organisation, except in the following cases, with third parties (see section 5) or if we have the legal standing to do so:
1.Banks and Financial Institutions that can be used on our platform
2.Third party providers we may use to help identify illegal activities and prevent fraud;
3.Governing bodies, law enforcement agencies, and regulators within the UK
4.Governing bodies, law enforcement agencies, and regulators outside of the UK, where we have cause to and we will ensure that your data is protected at all times
8. What we do not collect
8.1 Vibe Pay does not obtain and then collect any sensitive data about you (like racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, data about your sexual life or orientation, and offences or alleged offences) except when we have your specific consent, or when we have to comply with the law.
8.2 Data that you provide to your contacts using our platform (see section 4) may be subject to disclosure if it is deemed unacceptable, inappropriate, or illegal (see section 7 and VibePay Terms & Conditions)
8.3 VibePay is not intended to be used by minors (“Minors”). However the basis of the app, which is to send money securely is operated by your bank via Open Banking. This means that if you have a bank account that Open Banking facilitates, and Vibe Pay have connected to, then you can access VibePay irrespective of your age. As a result we may be collecting personal data from a minor.
8.3.2 We do not knowingly collect, maintain, or use personal data from our platforms about children under the age of 13. We will never knowingly request personal data from a child under the age of 13. If we become aware that a child under the age of 13 has sent personal data to us, we will terminate their VibePay account (see VibePay Terms & Conditions) and remove his or her personal data from our files.
9. Data Security
9.1 We take the security of your data very seriously and have physical, electronic, and managerial procedures to safeguard and secure all information we collect.
9.2 As a user you will need to bear some responsibility for the data you provide (see section 2). Any personal data you provide is done so at your own risk, unfortunately, no data transmission is guaranteed to be 100% secure
9.3 If you believe your privacy has been breached, please contact us immediately using the contact details found in section 6.3, but we recommend emailing us for the sake of urgency.
10. Retention Periods
10.1 Under the GDPR there are no specific retention periods for Personal data. However, your personal data will only be kept in a form that permits identification of you for no longer than is necessary for the purposes for which it was processed.
10.2 In deciding the period of time to retain personal data, we will consider our need to process the data, including any legal obligations to keep data for a specified time period. We will also consider archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.
10.3 Vibe Pay assures that we have the appropriate technical and organisational measures required by GDPR in order to safeguard the rights of our users.
11. Your legal rights and control
11.1 You can choose not to provide us with your personal data. You’ll still be able to visit our VibePay site but you won’t be able to use our VibePay app.
11.2 The first time you visit the VibePay website we may ask you to consent to using cookies. If you accept, we’ll use the cookies detailed in section 13. If you decline, you can still access the website but some features may not work properly.
11.3 You have the right to access all the information we hold about you, including supplementary information such as:
-The categories of data we are processing
-The purposes of data processing
-The categories of third parties to whom the data may be disclosed
-How long the data will be stored
-Your other rights regarding our use of your data
We will collate and send this information to you within one month of your request, unless doing so would adversely affect the freedoms and rights of others (e.g. another person’s confidentiality). We will tell you if we are unable to meet your request for that reason.
11.4 You have the right to have your personal data corrected. If you believe any of the personal data we hold about you to be inaccurate you can tell us, and we’ll update our records.
11.5 Opt-out of automated decision making and profiling. Your data may be used to make automated decisions about you or for profiling. For example we may want to let you know information that may be relevant to you, such as customising emails to you based on your behaviour or data we hold about you. However you can opt out of automated decision making and profiling, by amending your marketing preferences, or contacting us.
11.6 You have the right to ask us to “forget” you (also known as the right to erasure). If you ask us to, we will erase any personal data we hold about you, provided it is no longer necessary for us to hold the data for auditing purposes related to your use of VibePay
11.8 You have the right to lodge a complaint regarding our use of your data. We ask that you please tell us first, so we have a chance to address your concerns. If we fail in this, you can address any complaint to the UK Information Commissioner’s Office, either by calling their helpline or as directed on their website at www.ico.org.uk.
11.9 You can exercise any of these rights, at any time, by emailing firstname.lastname@example.org or by writing to Vibe Pay Limited, The Storey, Meeting House Lane, Lancaster, Lancashire, LA1 1TH, United Kingdom.
12.2 We also recommend that you review this policy prior to raising any concerns or complaints.
12.3 We are regularly updating and upgrading the VibePay platform and service, and may release new features to comply with the law and to provide a better service for our customers.
12.4 By agreeing to the VibePay Terms and Conditions you acknowledge our right to make these changes.
13. Google analytics cookies used on this site
13.2 Strictly necessary cookies – These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to view recent listings on our website.
13.5 WebAccessTokenVibePay cookies – These cookies help to ensure that our website loads properly, displaying content and listings on each page as you move throughout the site.
13.5 Analytical/performance cookies – These cookies allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. These cookies also help us capture visitor behaviour to improve the quality of experience we can offer, including enhanced browsing experience. We use the services Google Analytics, Hotjar and Salesforce, which anonymously track visits to our website and pages viewed.
Google Analytics uses the following cookies:
13.6 Salesforce uses digital marketing cookies:
13.7 Smallchat cookies – _cfduidsc-KiV-AgshP1EjqOaykdWpageviews
These cookies allow our website chat feature to work, letting you talk to our team via our website. They also ensure that as you go from page to page on our site, your chat doesn’t disappear.