Tide Platform Ltd (Company number 09595646) (Tide, we, us or our) provides the products and services offered on the Tide website and/or mobile application www.tide.co (Platform).
For the purposes of the Data Protection Act 1998 and General Data Protection (Regulation), coming into effect on the 25th of May 2018, we are the data controller.
We have adopted this policy to ensure that we have standards in place to protect the data that we collect about you that is necessary and incidental to:
providing the products and services that we offer; and
the normal day-to-day operations of our business.
By publishing this policy, we aim to make it easy for our users, customers and the public to understand what data we collect and store, why we do so, how we receive and/or obtain that information, and the rights you have with respect to your data in our possession.
Please note that our financial services partner, PPS, is a separate Data Controller. You can see details about how PPS uses and protects your personal data at the bottom of this page.
WHO AND WHAT THIS POLICY APPLIES TO
We handle data in our own right and also for and on behalf of our customers and users.
Our policy does not apply to information we collect about businesses or companies, however it does apply to information about the people in those businesses or companies which we store.
The policy applies to all forms of information, physical and digital, whether collected or stored electronically or in hardcopy.
If, at any time, you provide data or other information about someone other than yourself, you warrant that you have that person’s consent to provide such information for the purpose specified.
Tide is not available to children (persons under the age of 18 years).
THE INFORMATION WE COLLECT
In the course of business, it is necessary for us to collect data. This information allows us to identify who you are for the purposes of our business, share data when asked of us, contact you in the ordinary course of business and transact with you. Without limitation, the type of information we may collect is:
Personal Information. We may collect personal details such as your name, location, date of birth, photograph, passport, driver’s license and other information that allows us to identify who you are;
Contact Information. We may collect information such as your email address, mobile and/or landline telephone number, third-party usernames, residential and business address, and other information that allows us to contact you
Financial Information. We may collect financial information related to you about payments you make and receive, such as the date, amount, currency and the details of the payee or payer, and other information that allows us to transact with you and/or provide you with our services;
Statistical Information. We may collect information about your online and offline preferences, habits, movements, trends, decisions, associations, memberships, finances, purchases and other information for statistical purposes;
Device Information. We collect device-specific information, such as the hardware model, operating system version, advertising identifier, unique application identifiers, unique device identifiers, browser type, language, wireless network, and mobile network information (including the mobile phone number); and
Information you send us. We may collect any personal correspondence that you send us, or that is sent to us by others (such as credit reference or fraud prevention agencies) about your activities, including activities with our third-party partners.
We may collect other data about you, which we will maintain in accordance with this policy.
We may also collect anonymous non-data about you such as information regarding your computer, network and browser (including an IP address).
HOW INFORMATION IS COLLECTED
Most information will be collected in association with an individual’s use of Tide, our products and services, an enquiry about Tide or generally dealing with us. However, we may also receive data from other sources such as advertising, an individual’s own promotions, public records, mailing lists, contractors, staff, recruitment agencies and our business partners. In particular, information is likely to be collected as follows:
Registrations/Subscriptions/Purchases. When an individual registers, subscribes and or purchases a product, service, list, account, connection or other process whereby they enter data details or grant access to information in order to receive or access something, including a transaction or services;
Accounts/Memberships. When an individual submits their details to open an account and/or become a member with us;
Partners. When an individual grants us access to their accounts or allows information to be shared by our business partners.
Supply/Contact. When an individual supplies us with goods or services. or contacts us in any way;
Pixel Tags. Pixel tags and web beacons may enable us to send email messages in a format customers can read and they tell us whether mail has been opened.
Shareholder Information. We collect information from each of our shareholders, such as the name, date of birth and address.
As there are many circumstances in which we may collect information both electronically and physically, we will endeavour to ensure that an individual is always aware of their data being collected, in particular by third parties.
We may also collect anonymous non-data, which may be used and shared on an aggregated and anonymous basis.
HOW DATA IS STORED
The data that we collect from you will be stored in the European Economic Area (EEA), but may be transferred to, and stored at, a destination outside the EEA, with and by third parties.
Data may also be processed by third parties and/or staff operating outside the EEA who work for us or for one of our third party partners. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
We will retain data for the period necessary to fulfil the purposes outlined in this policy unless a longer retention period is required or permitted by law.
WHEN DATA IS USED
In general, we will only use any data for the purpose for which it was collected, except with your permission. The purpose of collection is determined by the circumstances in which the information was collected and/or submitted.
Information is used to enable us to operate our business, especially as it relates to you. This may include:
the provision of Tide and related services to you;
verifying your identity;
communicating with you about:
your relationship with us;
our marketing and promotions to customers and prospects; and/or
competitions, surveys and questionnaires;
marketing and promotions to customers and prospects;
investigating any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity;
carrying out regulatory checks and meeting our obligations to our regulators;
preventing and detecting fraud, money laundering and other crime (such as identity theft);
preparing high-level anonymised statistical reports, which would contain details such as the average number of company directors being authorised signatories to a company’s accounts. The information in these reports is never personal and you will never be identifiable from them. We may share these statistical and anonymised reports with third parties including non-Tide companies; and/or
as required or permitted by any law.
If you publicly post about Tide, or communicate directly with us, on a social media website, we may collect and process the data contained in such posts or in your public profile for the purpose of addressing any customers services requests you may have and to monitor and influence public opinion of Tide.
WHEN DATA IS DISCLOSED
Upon your authorisation and instruction, to your advisers (such as accountants, lawyers, financial or other professional advisers).
It may be necessary for us to disclose your data to third parties in a manner compliant with the Regulation in the course of our business, such as for processing activities like verification, due diligence, website hosting, data analytics, payment processing and when opening an account with Tide through one of our trusted partners (such as your accountant).
We will not disclose or sell an your data to unrelated third parties under any circumstances unless we employ other companies to perform tasks on our behalf and we need to share your information with them to provide products and services to you.
There are some circumstances in which we must disclose your information:
where we reasonably believe that you may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of;
as required by any law including court orders;
as required by UK and overseas regulators and authorities in connection with their duties, including the regulator or authority having access payment details (including information about others involved in the payment);
fraud prevention agencies, in particular, we will always tell fraud prevention agencies if you give us false or fraudulent information. They will also allow other organisations (in the UK or abroad), including law enforcement agencies to access this information to prevent and detect fraud, money laundering or other crimes; and/or
in order to sell our business (as we may transfer data to a new owner).
If the Company becomes involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of the business to another company, we may share information with that company before and after the transaction closes.
THIRD PARTY SERVICES, WEBSITES AND ACCOUNTS
We may share your information with third-party service providers in connection with the provision of Tide and related services to you, and otherwise operating our business, marketing and promoting our products and services. We may link your account with a third party to our services to enable certain functionality, which allows us to obtain information from those accounts.
If you sign-up to Tide through one of our trusted partners (such as your accountant) we may share information (such as your transaction data) in line with this service.
For example, we may share your information as follows:
authentication of identity, passport and driver’s license (such as AU10TIX, Onfido, GB Group, Trulio);
all information may be processed and stored with cloud service providers (such as Amazon Web Services);
information may be required to communicate with you (such as Gmail from Google, Inc);
to assist marketing and promotions to other customers and prospects on social media (such as Facebook or via post – please see the “Direct Mail Marketing” section below);
in relation to the provision of a cross-border payment solution (such as our partnership with Saxo Payments).
When you click on links to third-party websites, we may link your account with a third party to our services to enable certain functionality, which allows us to obtain information from those accounts.
When linking your account with third parties, you must read the privacy policies of such providers, so that you can understand the manner in which they will handle your personal information. The information we may obtain from those services often depends on their privacy policies or account settings.
These service providers may be located or have facilities that are located a different jurisdiction (including outside the EEA), in which case your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
DIRECT MAIL MARKETING
We may collect your name and address from publicly available sources such as Companies House and use this personal data to send you information about our services via post. Our lawful basis for processing this personal data is the legitimate interest of growing our business.
You can opt out of receiving information from us via post at any time by following the instructions on the relevant correspondence or by contacting us using the contact details set out below. If you opt out, your request to opt out will override our legitimate interest in growing our business and we shall cease sending you information on our services via post.
You may opt to not have us collect your data and communicate with you at certain times. This may prevent us from offering you some or all of our services and may terminate your access to Tide, or other services you access with or through us.
Opt In. Where relevant, you will have the right to choose to have your information collected and/or receive information from us; or
Opt Out. Where relevant, you will have the right to choose to be excluded from some, if not all, information collection, and/or the receiving of that information from us. You may revoke your consent at any time, and the decision to opt out should be made through the same media by which you opted in.
If you believe that you have received information from us that you did not opt in to receive, you should contact us on the details provided at the bottom of this page.
THE SAFETY & SECURITY OF DATA
We will take all reasonable precautions to protect your data from unauthorised access. This includes appropriately securing our physical facilities and electronic networks.
Examples of such precautions include:
Intrusion detection systems
Physical protection of premises where data is stored (24/7)
Background checks for all employees accessing our physical facilities
The security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed. When you provide information to us via the internet or by post, you do so at your own risk. We cannot accept responsibility for misuse or loss of, or unauthorised access to, data, where the security of information is not within our control.
Privacy or security practices of any third party (including third parties that we are permitted to disclose your data to in accordance with this policy or any applicable laws) may be subject to separate privacy and security policies than that of Tide’s.
If you suspect any misuse or loss of, or unauthorised access to, your data, you should let us know immediately.
We are not liable for any loss, damage or claim arising out of another person’s use of the data where we were authorised to provide that person with the data.
HOW TO ACCESS AND/OR UPDATE INFORMATION
Current regulation gives you the right to request from us the data that we have about you.
If you cannot update your own information, we will correct any errors in the data we hold on you within one month of receiving written notice from you about these errors.
It is your responsibility to provide us with accurate and truthful data. We cannot be liable for any information that is provided to us that is incorrect.
We may charge an you a reasonable fee for our costs incurred in meeting any of your requests to disclose the data we hold on you, if such a request is manifestly unfounded or excessive. We reserve the right to clarify the specific information your request relates to.
Information will be provided within one month of receipt of the request.
You have the right to request that information held on you by Tide is erased, where there are no additional legal and/or regulatory requirements for Tide doing so.
COMPLAINTS AND DISPUTES
You have the right to object to:
processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
direct marketing; and
processing for purposes of scientific/historical research and statistics
unless we hold compelling legitimate grounds for processing or the processing is for the establishment, exercise or defence of legal claims.
After 25th May 2018, you will be able to adjust your contact preferences at any time in the ‘More’ section of the Tide app.
You can choose how you would like to receive marketing and other non-business critical communications.
Any changes made to these contact preferences can take up to 72 hours to come into effect.
If you have a complaint about our handling of your data, you should address this complaint in writing to the details provided at the bottom of this page.
You have the right to lodge a complaint with a supervisory authority if you consider that the processing of your data infringes the General Data Protection Regulation.
If you lodge a dispute regarding your data, we both must first attempt to resolve the issue directly between us.
If we become aware of any unauthorised access to your data which is likely to result in a high risk for the rights and freedoms of the data subjects, we will inform you without undue delay after becoming aware of it, once we have established what was accessed and how it was accessed.
ADDITIONS TO THIS POLICY
We reserve the right to modify this policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the Platform. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.
If we decide to change this policy, we will post the changes on our Platform at www.tide.co/privacy. It is your responsibility to refer back to this policy to review any amendments.
All correspondence relating to privacy should be addressed to (by email where possible):
The Data Controller,
Tide Platform Ltd
2nd Floor White Bear Yard
144a Clerkenwell Road
PROVISION OF PAYMENT SERVICES Prepay Technologies Limited trading as Prepay Solutions (PPS) provides technology, expertise and regulatory authority appropriate for the operation of payment services and e-money accounts on Tide’s behalf.
WHO IS PPS SOLUTIONS AND HOW DO THEY PROTECT MY PERSONAL DATA?
PPS is a company registered in England and Wales (Company number 04008083) and a registered office at 6th Floor, 3 Sheldon Square, Paddington, London, W2 6HY, United Kingdom. You can email PPS at email@example.com or you can call PPS on 0845 303 5303 (+44 845 303 5303 from outside the UK).
PPS is the Data Controller in relation to your Card and all necessary activities relating to the operation of the Card: allowing you to receive, activate and use your Card (activating, managing and using your online account where applicable, making and receiving payment transactions, meeting legal requirements, answering requests, providing information to you).
Processing is necessary for the performance your contract for the issue and operation of Cards and is necessary for compliance with legal obligations applicable to PPS. PPS does not use your personal information for marketing purposes and will not share your information with third parties for marketing purposes.
WHAT PERSONAL DATA DOES PPS PROCESS?
Type of personal information
Full name and date of birth
Where you live and how to contact you including phone numbers and e-mail addresses
Transactional and Card Data
Details about your Card, use of your Card and payments to and from your accounts
Details about you that are stored in documents in various formats, or copies of them. This could include things like your passport, drivers licence or birth certificate collected to fulfil customer due diligence requirements.
Personal information will only be collected directly and voluntarily from you as part of the application process or as a result of transactions relating to your Cards. Some personal information may be verified by PPS with use of publicly accessible sources to fulfil customer due diligence.
SENDING PERSONAL INFORMATION OUTSIDE OF EEA
PPS will only send your personal information outside of the European Economic Area (EEA) to:
Follow your instructions
Comply with a legal duty
In relation to personal information processed by Mastercard certain processors are located outside of Europe. Personal information processed by Mastercard is subject to Mastercard Binding Corporate Rules which you have enforcement rights under as a third-party beneficiary.
DOES PPS SEND MY PERSONAL DATA TO ANY THIRD PARTIES?
PPS is committed to ensuring that your information is secure with us and with third parties who act on our behalf. These third parties include MasterCard, card manufacturers, suppliers of identity validation services, IVR and call recording (telephone) suppliers and to Tide. PPS uses many tools to make sure that your information remains confidential and accurate.
HOW LONG DOES PPS HOLD MY PERSONAL DATA?
PPS does not keep your information for longer than we need to, which is usually up to 7 years after termination of your contract, unless we they are required to keep it longer (for example due to a court order or investigation by law enforcement agencies or regulators).
WHAT ARE MY RIGHTS?
You have the same rights as apply to personal data controlled by Tide. To exercise any of your legal rights, you can email PPS at firstname.lastname@example.org or you can write to PPS DPO at PO Box 3883, Swindon SN3 9EA.
RIGHT TO LODGE A COMPLAINT
If you wish to raise a complaint on how PPS has handled your personal information, you can contact PPS’ Data Protection Officer and if PPS fails to address your complaint you can contact the Information Commissioner’s Office (https://ico.org.uk/).