Privacy Policy

Website Privacy Policy

We ask that you read this website privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

This website privacy policy is divided into the following sections:

  • Who we are
  • Our website
  • Our collection and use of your personal information
  • Transfer of your information out of the UK and EEA
  • Cookies and similar technologies
  • Marketing
  • Your rights
  • Keeping your personal information secure
  • How to complain
  • Changes to this website privacy policy
  • How to contact us
  • Do you need extra help?

Who we are

This website is operated by Openwage Limited. We are a company incorporated in England and Wales under company registration no: 12957705 with a registered address at: Leconfield House, Curzon Street, London, England, W1J 5JA. 

We collect, use and are responsible for certain personal information about you. When we do so we are compliant with the provisions of the Data Protection Act 2018 and we are responsible as ‘controller’ of that personal information for the purposes of that legislation.

Our website

This privacy policy relates to your use of our website only.

Throughout our website we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you. These other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.

Our collection and use of your personal information

We collect personal information about you when you access our website, register with us to use the service, contact us, or send us feedback via our website.

We collect this personal information from you either directly, such as when you register with us or access our services via our website or indirectly, such as your browsing activity while on our website (see ‘Cookies’ below).

The personal information we may collect about you depends on the particular activities carried out through our website. 

This information may include:

  • your name, address and contact details
  • your date of birth
  • your bank sort code and account number
  • your gender; age; income and employment status
  • your salary and respective payment details
  • details about payments to and from you and other details of subscriptions and services you have purchased from us 
  • data in respect of your transactions with 3rd parties
  • your account details, such as username and login details
  • details of any feedback you give us by phone, email, post or via social media
  • information about the services we provide to you

We may also collect behavioural data relating to your website visits and app usage, such as Internet Protocol (IP) address, mobile device identifier, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, download errors, response time, page interaction (such as scrolling, clicks, and mouse-overs) device type and model, operating system and platform and other technology on the devices you use to access the services we provide.

Lastly, we may collect technical data: this may include data that is inferred or assumed information relating to your behaviour and interests, based on your activity online and/or in the application. This data will be anonymised and aggregated but may be collated and grouped into “segments” (e.g., there may be a segment for users, living in London and aged under 25, who use our services twice a month).

We use this personal information to:

  • create and manage your account with us
  • verify your identity
  • provide services to you
  • comply with legal or regulatory obligations 
  • customise our website and its content to your particular preferences
  • notify you of any changes to our website or to our services that may affect you
  • drive analytics to assist us in improving and optimising our site and service.

This website is not intended for use by children and we do not knowingly collect or use personal information relating to children.

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:

  • consent: where you have given us clear consent for us to process your personal information for a specific purpose
  • contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
  • legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)
  • legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests)

Further information—the personal information we collect, when and how we use it

For further details on when we collect personal information, what we collect as well as how we use it, please read the following sections.

We have set out below, in a table format how we use your Personal Data.

PURPOSECATEGORIES OF PERSONAL DATAWHY WE DO THISOUR LEGAL BASIS FOR THIS USE OF DATA
Account creationIdentity data
Contact data		To register you as a new userLegitimate Interest
Transfers and Service ProvisionIdentity data
Contact data
Financial data		To provide you with the Openwage services and communications on behalf of your employerPerformance of Contract
Making third party product availableIdentity data
Contact data		To enable you to access third party productsConsent 
Fraud PreventionIdentity data
Contact data
Behavioural data
Technical data		To keep our website, our services and associated systems operational and secure and to keep your data and identity securePerformance of Contract
TroubleshootingTechnical dataTo track issues that might be occurring on our systemsPerformance of Contract
Optimisation and AnalyticsIdentity data
Contact data
Behavioural data
Technical data
Transactional data		To understand and measure how users use our platform to improve it and report and relevant aggregated management informationPerformance of ContractLegitimate Interest
MarketingIdentity data
Contact data		To capture interest in Openwage and to keep prospects and clients informedConsent
Product ReferralsIdentity data
Contact data		To allow interested employees to refer Openwage to their employerLegitimate Interest
Survey InvitationIdentity data
Contact data		Improve our serviceLegitimate Interest

Who we share your personal information with

We may share your personal data with the parties set out below for the purposes set out in the table at section 4 above “Purposes for which we will use your personal data”.

We require all third party service providers to respect the security of your personal data and to process it in accordance with data protection law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 RECIPIENTSCATEGORIES OF PERSONAL DATA SHAREDREASON SHARED
Service ProvidersIdentity Data
Contact Data
Financial Data
Employment Data
Transaction Data
Device Data
Aggregate Data
Usage Data		So that survey, hosting, analytics, search engine and other technical assistance providers can assist us in the improvement and optimisation of the Openwage website.Survey companies are only permitted to use your personal data to request a review from you in the context of your use of the Openwage website. They may not use it for any other purpose.Our IT service providers provide us with software development, business analyst and system administration services.
Advertising and remarketing networksTechnical DataUsage DataOur website uses remarketing and conversion tracking technologies provided by Google AdWords (for further details about the Remarketing product we use, see here; for the product’s privacy policy, see here), LinkedIn Pixel (for further details about the LinkedIn privacy policy, see here) and Facebook Pixel (for further details about the Facebook product we use, see here).This technology allows us to display targeted advertising to users who have already visited our website when they use the websites of the partner networks of Google, LinkedIn and Facebook across the internet. We may add similar providers to those mentioned here in the future. Third-party vendors, including Google and Facebook, use cookies to serve you ads based on your visits to our website. Please refer to our cookie policy for further information about how these technologies are used on our website.
Communication PartnersContact DataOur third-party partners provide live chat and facilitate communication (like email, chat and phone), in order to provide you with the full functionality of the Openwage website.They may ask for your name and email to provide assistance to you.
Professional advisersIdentity Data
Contact Data
Device Data
Usage Data		To our lawyers, bankers, consultants, auditors and providers of banking, legal, insurance and accountancy services if such disclosure is reasonably required to comply with any legal obligation; to enforce any contract entered into with you; to protect the rights, property or safety of Openwage or our customers (including by exchanging information with other organisations for the purposes of fraud protection).
Openwage Group CompaniesIdentity Data
Contact Data
Employment Data
Usage Data
Device Data
Aggregate Data
Location Data
Camera Data		We may share your information with our corporate affiliates and associates (e.g., parent company, sister companies, associated trust entities, subsidiaries, joint ventures, or other companies under common control). We have a legitimate business interest to share data with our group as it allows us to better understand the performance of our services and how to offer and improve our product offerings across the group. It also assists us with finding operational efficiencies (such as financial efficiencies though sharing IT infrastructure), making use of group level software solutions and improving our technological offerings which form an integral part of our Service.
Purchaser of Openwage and/or any member of the Openwage GroupIdentity Data
Contact Data
Usage Data
Device Data
Aggregate Data 		Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We will also share information at the negotiation stage or in a bidding process, as applicable.
Law Enforcement AgenciesIdentity Data
Contact Data
Usage Data
Device Data
Aggregate Data		On the basis of the compliance with a legal obligation for example if we are required to disclose information pursuant to regulatory, employment, taxation, criminal, terrorist financing and money laundering law requirements.
Legal, civil or business affairsIdentity Data
Contact Data
Usage Data
Device Data
Aggregate Data 
We may disclose information when we believe disclosure is appropriate to comply with the law, to enforce or apply applicable terms and conditions and other agreements, or to protect our rights, property or safety or the rights, property or safety of our affiliates, users, or third parties. For example, we may disclose information in response to subpoenas, arbitration proceedings, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.

We will share personal information with law enforcement or other authorities if required by applicable law.

Third Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

Digital Marketing Service Providers – We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information.

Our appointed data processors include:

  • Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: Z123456 their Data Protection Officer can be emailed at: dpo@sopro.io.
  • Payments, e-money accounts providers: We appoint partners to provide payment transfer and e-money facilities to us. Our partner is Modulr FS Limited. You can view their privacy policy here: https://www.modulrfinance.com/privacy-policy. Openwage Limited is a distributor of Modulr FS Limited, a company registered in England with company number 09897919. Modulr FS Limited is authorised and regulated by the Financial Conduct Authority as an Electronic Money Institution (Form Reference Number: 900573). 
  • Open Banking data providers: We appoint partners to provide connections to bank accounts, in order to share bank account data information. Our partner is Plaid Financial Limited. You can view their legal and privacy policy here: https://plaid.com/legal/. Plaid Financial Limited is authorised and regulated by the Financial Conduct Authority (ref. 804718), registered and incorporated in England and Wales (company no. 11103959).

We will not share your personal information with any other third party.

Aggregated Data

We may use and share personal data that is aggregated and anonymised  (“Aggregated Data”) for  statistical purposes only. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we will treat the combined data as Personal Data which will be used in accordance with this Privacy Notice.

Whether information has to be provided by you, and if so why

We require you to provide your name or your employer’s name, email address and/or phone number to enable us to contact you and/or your employer. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.

Transfer of your information out of the UK and EEA

We will not transfer your personal information outside the United Kingdom (UK) and/or the European Economic Area (EEA).

Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.

For further information on cookies, when we will request your consent before placing them and how to disable them, please see our https://openwage.com/cookie-policy/

Marketing

We would like to send you information about special offers, newsletters our products and services, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, text message (SMS) or automated call.

If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:

—contacting us at marketing@openwage.com

—using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

—updating your marketing preferences on our preference centre

It may take up to 5 days for this to take place.

For more information on your rights in relation to marketing, see ‘Your rights’ below.

Your rights

Under the Data Protection Act 2018 you have a number of important rights free of charge. In summary, those include rights to:

  • access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
  • require us to correct any mistakes in your information which we hold
  • require the erasure of personal information concerning you in certain situations
  • receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
  • object at any time to processing of personal information concerning you for direct marketing
  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
  • object in certain other situations to our continued processing of your personal information
  • otherwise restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under Data Protection legislation.

If you would like to exercise any of those rights, please:

  • email, call or write to us
  • let us have enough information to identify you (your name, company, account number), 
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
  • let us know the information to which your request relates including any account or reference numbers, if you have them

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that we can resolve any query or concern you raise about our use of your information.

The Data Protection legislation also gives you the right to lodge a complaint with a supervisory authority, in particular in a European Economic Area state or in the United Kingdom if you work, normally live or if any alleged infringement of data protection laws occurred in the relevant state. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

Changes to this website privacy policy

This website privacy policy was published on the 20rd of April 2021 and last updated on23rd of April 2021.

We may change this website privacy policy from time to time, when we do we will inform you via email.

How to contact us

Please contact us if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact us, please send an email to marketing@openwage.com, write to Openwage, Leconfield House, Curzon Street, London, England, W1J 5JA.

Do you need extra help?

If you would like this website privacy policy in another format (for example: audio, large print, braille) please contact us (see ‘How to contact us’ above).