Privacy Policy

ABOUT US

At Yolt, our aim is to empower you with your money. We take away the hard work so you can go out and enjoy the things that really matter. Whether it’s saving for that first house or freeing up time and budget for our family and friends, we all have different goals. We all have a different relationship with our money, too. That’s why we’ve built Yolt to learn from each user, so we can provide a customised experience for each and every person.

How do we do it? Through the secure processing of your personal data. Your privacy and security are our number one priority, and, as a venture of ING Bank NV, your data is protected by bank level security. To find out exactly what that means, read on to learn about our data protection principles and how we use your data.

A SUMMARY OF OUR DATA PROTECTION PRINCIPLES:


Privacy and security is in our DNA:

· We strongly protect and secure the personal data we hold about you.

· We will only use your personal data for your benefit and to deliver you our services.

· We do not sell your data to third parties.

· Where we track your use of the App, we do this to continuously improve and personalise your experience.

· Where we reuse your personal data, we do so to avoid asking you the same data twice;

· We may use suppliers to help us deliver our service, but we restrict their use of data to what you allow us to do and bind them to European data protection rules and to strict confidentiality.

· Where you enable partners on the Yolt platform, they may receive relevant data about you, but only:

· With your explicit consent

· When it is clear to you what you sent

· For what purpose these partners will use that data

Your are in control:

· You decide what banks to connect to the app or not.

· You can disconnect a bank at any time to stop data exchange. This will delete all data exchanged.

· You have the right to be forgotten: You can delete your Yolt account through the app. We will then delete all data we have about you.

· You decide what partners to connect and disconnect. If you disconnect a partner any data exchange will stop.

· Any data that a partner has received based on your consent, will still be with that partner. You should request deletion of that data and your right to be forgotten directly with them. We will help you where we can.

· If you don’t want us to personalise your App experience or use your data to improve our App or website, you can always disable this through the Cookie Settings on the website and in the future via the Privacy settings in the App.

Our community:

· We want to create a relevant experience for you, so the data we collect might be used anonymously in communications such as:

· Blog posts and infographics

· Emails such as weekly or monthly Yolt insights

· Social media posts

· Campaigns

Our public insights, posts and infographics are always anonymised and aggregated and can never be tracked down to you personally.

Europe:

· Your data is stored in Europe

· Your data is always protected by European rules

1. WHAT PERSONAL DATA DO WE USE?

What is personal data

Personal data is any data relating to a person who is identified or who can be identified (such as a name, an identification number, or an online identifier)

Personal data you give us:

You may give us personal data about you by filling in forms on, or interacting with, the App, our website, or by corresponding with us by phone, email or otherwise. Examples of personal data include:

• name, address, email address and phone number

• information about your budgets

• personal data about your financial circumstances (e.g. filling out a form to benefit from one of our comparison providers)

• content you share with us in our community (Facebook, Twitter etc) or via our social media channels or via our Customer Care

Personal data from connected banks:

If you connect one of your banks to our App, we will collect data from your connected banks, such as:

• Bank account details, account numbers, information about your transactions,

• information identifying the account you have with your connected bank;

• transactions made on those accounts;

• your direct debits and standing orders;

• As part of your account information, we may collect sensitive personal data:

· For example, if you have a payment for a membership to a particular political party, this could reveal your political beliefs.

· We will not profile you on the basis of this data and we will not use this data for any other purposes than providing our services as detailed hereunder

Personal data we collect from you:

When you use the App or our website we may automatically collect technical information such as

• IP address

• device details

• your login information

• information about each visit you make to the App (such as page response times and length of visit)

• location data

• info about your use of the App or website through tracking tools

We use well-known advertising platforms such as Facebook and Google to tell you about the App:

• If you click through such an advert and agree to the App Terms, an automated process will confirm to the advertising platform that you have signed up to the App and how much you use the App

• If you don’t use these platforms we will not collect or process this data

We use tools to improve the user experience of our website and to personalise your App experience. Therefore, we perform statistical analyses about the way you use the services of Yolt (such as information on how you navigate, how much time you spend, how long you visit, and from where you came to our service:

• For our website: Yolt uses Google Analytics on our website. We don’t use Google Analytics on our app or on your transaction data.

• For our App: Yolt uses Webbtrek to personalise your App.

If you don’t want this, you can always disable this through the Cookie Settings on the website or via the Privacy settings in the App.

2. WHAT DO WE USE YOUR PERSONAL DATA FOR?

Your consent:

We rely on your consent to process and use your personal data for the following purposes:

• Provide information on your Accounts, such as Smart Money Insights, Alerts and budget information and an account overview.

• Enable you to use the services of our partners which are displayed in the App (for example, comparison services);

• Run competitions that you enter.

Legitimate interest:

We use your personal data on the basis of our legitimate interest and to your benefit so that we can:

• Provide you with updates about ING and the App;

• Improve your experience of our service:

· Assess the use of the App;

·Help us identify people like you that might enjoy the App;

• Make a secure connection between your device and the App

• Take action if we need to defend our rights under the App Terms if you would misbehave or act in deviation of laws or regulations or our App Terms

• Track and examine the use of the App and the website to prepare reports on its activities and analyse that data

• Attract new partners and get you the best deals available from our partners

• Perform research and trend analysis to optimise your experience;

·Creating content using some personal data will enable us to engage with you in a relevant and human way.

·Using and presenting content based on data provides an ideal way to talk to you about the benefits of Yolt and its features in an engaging and relatable way and link you back to the benefit of the product

• Engage and activate our users by:

·Learning from beta services

·Re-engaging our users on social media and via email

·Providing more detailed information on your spending data. e.g. a weekly or monthly email on personalised insights

• We could use your personal data in an anonymised and aggregated form to enrich content in:

· Blog posts and infographics

· Emails, such as a weekly or monthly Yolt insight

· Social media posts

· Campaigns

This will never contain data or insights or information that can be tracked down to you personally.

We will always use the minimum data required and will process to the minimum extent required.

Legal obligations: We will also process your personal data where we are under a legal obligation to do so to:

• Prevent and detect fraud, money laundering, other crime, and security issues, and to reduce ING’s risks; and

• Comply with laws and regulations, as well as any sector-specific guidelines and regulations.

3. YOUR KEY RIGHTS

Your primary right is the right to stop processing your data (right to object):

• The App is designed to put you in control and enables you to withdraw your consent by:

· Deleting your account or deleting a connected bank

· Disabling a connection with an activated partner.

· Disabling tracking your use of the App in the Privacy Settings of the App

· Sending us an email with the request to be forgotten if any of the above does not work or if you cannot connect to the App.

• You have the right to ask us not to process your personal data for marketing purposes:

· You can always unsubscribe to our emails and campaigns

• You have the right to object to us processing information about you where we do so on the basis of a legitimate interest. If we cannot make that work, it could mean that we may not be able to provide you with the App at all.

This would not invalidate any processing of the personal data prior to your withdrawal of consent.

Your other rights are:

Right of access and data portability: All data that you have provided us is accessible in the App.

You can request a copy of all personal data you have provided us through the App or via the email-address you have provided us at registration.

If technically possible, we will help you to automatically export this data to other platforms or users.

We can only give you the data we hold ourselves. Any data that a partner holds about you is with that partner. You should request deletion of that data and your right to be forgotten directly with them. We will help you where we can.

Right to rectification: You can control your data through the App. Where you cannot change this data through the App, you have the right to ask us to rectify inaccurate or incomplete personal data which we have about you.

Right to erasure: You have the right to ask us to erase your personal data:

• You can delete your Yolt account through the app. This will automatically delete all information we have about you.

• Be aware that the partners you have activated may still have data about you. You will need to contact them directly in order for them to delete this data.

Right to object to automatic processing: You don’t need to object because we don’t subject you to decisions based solely on automated processing which significantly affect you.

4. WHERE DO WE STORE YOUR PERSONAL DATA?

Your data is stored in Europe: The personal data we collect from you is stored on secure information technology systems located in the European Economic Area (for example: The Netherlands, Germany, United Kingdom, and Ireland)

For the provision of customer support, or as necessary to troubleshoot the App, we may give access to our systems to suppliers outside of Europe:

• This will only be incidental access.

• If we give access, we will only do so under European data protection rules, and our suppliers are bound to abide by this.

Partners are bound by the same European data protection rules as we are, but partners could decide to store your data in other countries or parts of the world than we do. That is not in our control and between you and the partners you connect. We recommend you to carefully read their privacy policies. Upon connection to a partner, the App will give you easy access to these privacy policies.

5. PROTECTING YOUR PERSONAL DATA

Security is in our DNA:

• We are committed to ensuring that your personal data (including your Account Information and financial details (described in the App Terms) is secure.

• In order to prevent unauthorised access to or disclosure of it, we have put in place suitable physical, electronic and operational procedures to safeguard and secure the personal data we collect about you.

• In particular, we protect your personal data by deploying SSL and high standard encryption algorithms.

• We also ensure that we meet security standards imposed by law that are applicable to the operation of Yolt.

• We will never ask your PIN or other security credentials.

Help us protect you:

• To help us protect your personal data, you agree to comply with our security policies and procedures that we notify to you from time to time.

• You also agree to take all reasonable steps to prevent the unauthorised or fraudulent use of your User Login or PIN code, or other security credentials.

• If you find out or suspect that your App's User Login, PIN code, or recovery code has been lost, stolen, or someone has used it without your permission, you must tell us as soon as possible.

6. PARTNER PLATFORM

We may use your personal data to enable you to use the services of other service providers and partners if you want to connect with one of our partners.

You are in control:

• We only share your personal data if you consent to connect a partner.

• Only after such consent will we disclose or prefill your personal data to those third parties so that they can provide their services to you and give you a smooth user experience.

• We won't disclose more than is needed for the services of that partner.

Always read the partner’s terms and conditions and their privacy policy:

• The use of your data by the partners will be governed by their terms and conditions and their privacy policy – we do not control this.

De-activate a partner: You can always de-activate a partner:

• This will stop any data-exchange, but be aware that a partner could retain certain personal data about you that has been exchanged before.

• If you want a partner to delete your data then you should contact this partner directly.

Partner services could be:

1. International payments

2. Consumer credit

3. Insurance products

4. Pension products

5. Investment products

6. Current accounts (including debit cards)

7. Prepaid cards

8. Savings

9. Utilities

10. Leisure

11. Phone & Broadband

7. PROVIDERS, REGULATORS AND LAW ENFORCEMENT


Other than what is described above, we will only share your personal data in a very limited way.

This will happen either where we need to use services we cannot build ourselves or have a duty or legal obligations to disclose it:

Our service providers (including their sub-contractors). This may happen where they help us to run our service or the technology systems that are needed to operate our App and services. This may include:

1. Data storage providers to safely and securely store your data.

2. Aggregation service providers, where necessary in order to retrieve Account Information for use in the App on your behalf.

3. Social Media Platforms via anonymised campaign-IDs so that we can provide relevant content to you on Social Media.

4. Email services e.g. to send you regular updates or communication.

5. Customer relation management to provide you with customer care services.

6. Website and app analytics to provide you with the best experience.

Regulators in connection with their duties, such as crime prevention or carrying out regulatory oversight of what we do.

Fraud prevention agencies and law enforcement agencies, to prevent and detect fraud, money laundering or other crimes.

8. USING COMPUTERS TO MAKE DECISIONS ABOUT YOU

The App produces smart insights to empower you with your money, from smarter spending to better budgeting. We store information about you into our systems in order to make decisions on what products and services to recommend to you.

We do not use automatic processing or profiling to make automated decisions about you that could significantly impact you (like refusing you financial products or credit profiling).

9. OUR CONTACT DETAILS

• Yolt is registered trade mark of ING Bank NV.

• ING has its statutory seat in Amsterdam at Bijlmerplein 888, 1102 MG Amsterdam, the Netherlands, and is entered in the Amsterdam Trade Register under no. 33031431.

• You can exercise any of the rights under this privacy policy or contact us at: hello@yolt.com

COMPLAINTS TO THE PRIVACY REGULATOR

You have the right to complain to the privacy regulator in the country in which you reside, where you work, or anywhere where you believe we might have broken data protection rules.

In the UK, the privacy regulator is the Information Commissioner's Office (the "ICO"). The ICO can be contacted at:

• Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

• Telephone: 0303 123 1113 (local rate) or 01625 545 745

• Email: https://ico.org.uk/global/cont...