Welcome to Wagestream’s Privacy Notice
What does this Privacy Notice Cover?
This Privacy Notice covers the position where Wagestream is the Controller of your Personal Data. Please see the end of this Privacy Notice for a statement concerning where Wagestream is a Processor.
Wagestream respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data in making available our platform, mobile application (“App”) and/or website(s) (together “Platform”) and tell you about your privacy rights and how the law protects you.
With that in mind, this Privacy Notice describes how Wagestream collects and processes your Personal Data, which may be either through your use of the Wagestream Platform, including any data you may provide through this Platform; or through your interaction with Wagestream through social media and marketing activities. The Privacy Notice complies with and is intended to meet our duties of Transparency under the retained EU law version of the General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018.
It is important that you read this Privacy Notice together with any other privacy or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data. This Privacy Notice supplements other such notices and is not intended to override them.
Who we are and how to contact us
Who we are
Wagestream Limited is a company registered in England and Wales (number 11173225) at 35 Gresse Street, London, W1T 1QY; registered with the Financial Conduct Authority (“FCA”) (firm reference 902046) as an EMD Agent of Electronic Money Institutions authorised by the FCA: PayrNet Limited (firm reference 900594) and Modulr FS Limited (firm reference 900573); acts as an agent of TrueLayer Limited, who is authorised by the FCA as an Authorised Payment Institution (firm reference 901096); and as a PSD agent (firm reference 995651) of Bud Financial Limited (firm reference 793327), both Payment Institutions authorised by the FCA, for Account Information Services.
Insurance services are provided by Wagestream IS Limited. Wagestream IS Limited is a company registered in England and Wales (number 14141395) at 35 Gresse Street, London, W1T 1QY; registered with the FCA (firm reference 998852) as an appointed representative of Resolution Compliance Limited (firm reference 574048), which is authorised and regulated by the FCA.
Wagestream Financial Services UK Limited is a company registered in England and Wales (number 13926226) at 35 Gresse Street, London, W1T 1QY.
We are registered with the Information Commissioner’s Office (“ICO”) reference number: ZA421647 (Wagestream Limited), ZB511084 (Wagestream IS Limited) and ZB325608 (Wagestream Financial Services UK Ltd).
Where we refer to “Wagestream”, “we”, “us” or “our” in this Privacy Notice we mean Wagestream Ltd except for (i) insurance services where we mean Wagestream IS Limited, and (ii) services provided under additional terms which identify that they are provided through Wagestream Financial Services UK Limited where we mean Wagestream Financial Services UK Limited.
How to contact us
We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about it, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
What personal data we collect
The types of Personal Data we may collect about you, is outlined in the table below.
What personal data we collect
The types of Personal Data we may collect about you, is outlined in the table below.
|Category of Personal Data collected||What this means|
|Identity Data||includes full name; username or similar identifier; title; date of birth; gender; age; nationality and language(s); passport, driving licence or other identity document, which includes a photograph (for KYC and AML checks).|
|Contact Data||includes your home address; email address and telephone numbers.|
|Profile Data||includes your password, your interests, preferences, feedback and survey responses.|
|Other Personal Data||includes data provided to customer services support including about personal circumstances, which may include additional financial information such as household income; financial income other than salary; financial liabilities.|
|Employment Data||includes income; employment status; shifts and hours; name of employer and place of work.|
|Financial Data||includes sort code; account name; account number; salary and statutory payments.|
|Open Banking Data||includes transaction history; transaction amounts and descriptions; account name; account number; account balance; currency; overdraft availability and balance; payment due dates and other information about your transactions, such as fees and account charges.|
|Transaction Data||includes any details about payments to and from you; other details of our services you have used and your transactions with 3rd parties.|
|Behavioural Data||includes inferred or assumed information relating to your behaviour and interests; based on your online activity and/or in App. This is most often 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).|
|Technical Data||includes data related to 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; device language settings; 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 this Platform or use our services.|
|Marketing and Communications Data||includes your preferences in receiving marketing from us and third parties and your communication preferences.|
|Health Data||Includes data about your health included in your fit notes (such as dates of appointments, doctors’ details, duration of and reason for absence, confirmation policyholder is unfit for work) but only where you use our Insurance Services and it is relevant to the specific insurance (e.g. Accident and Sickness Insurance).|
We may use and share Personal Data as “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 UK 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 treat the combined data as Personal Data which will be used in accordance with this Privacy Notice.
Special Categories of Personal Data
We generally do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic data). Nor do we collect any information about criminal convictions and offences.
However, we collect biometric data for the purposes of Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance checks. We may also collect and process Health Data where you provide us with the same for the purposes of providing services relating to Accident and Sickness insurance.
Our Notice on children
This Platform is not intended for individuals below 16 and we do not knowingly collect data relating to such children. If you believe that we may have processed the data of any person under 16 years of age please contact our DPO by email at email@example.com; or writing to us at DPO, Wagestream, 35 Gresse Street, London, W1T 1QY.
How we collect your Personal Data
Directly from you via in-App chat, by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
- enrol in our services;
- create an account;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
Automated technologies or interactions
As you interact with the Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. Please see the Cookies section for further details.
From third party sources
In addition to the Personal Data that we collect directly from you, we may also collect certain categories of your Personal Data from third party sources. These sources are broken down in the table below.
|Third party data source||Categories of personal data received||Purpose|
|Your employer (including their agents and service providers for example, workforce management systems providers)||Identity, Contact, Employment, Financial||To register you as a user and provide you with the Wagestream services|
|Analytics providers (such as Google based outside the UK)||Technical||To track issues that might be occurring on our systems and to understand and measure how users use our Platform to improve it and report relevant aggregated management information.|
|Your bank(s) (where you have authorised an Open Banking connection)||Open Banking||To provide you with account information services and product referrals.|
|Our service providers||Identity, Contact||To perform identity checks and compliance monitoring|
How we use your Personal Data
We have set out below, in a table format, how we use your Personal Data. We will only use your Personal Data where we have a lawful basis to do so.
|Purpose||Category(ies) of Personal Data involved||Why do we do this?||Our legal basis for this use of data|
|Account Creation||Identity, Contact||To register you as a new user||Performance of contract|
|Transfers and Service Provision||Identity, Contact, Profile, Employment, Financial||To provide you with the Wagestream services and related communications||Performance of contract|
|Open Banking||Open Banking||To provide our account information services||Performance of contract|
|Customer services||Identity, Contact, Profile, Employment, Financial, Customer Support, Technical, Marketing||To provide user support||Performance of contract|
|Compliance and Fraud Prevention||Identity, KYC, AML, Contact, Behavioural, Technical, Financial||To keep our App, our services and associated systems operational and secure. To keep your data and identity secure and comply with our AML and KYC obligations||Performance of contract, Legitimate Interest|
|Troubleshooting||Technical||To track issues that might be occurring on our systems||Performance of contract, Legitimate Interest|
|Optimisation and Analytics||Identity, Contact, Transactional, Technical, Behavioural, Open Banking||To understand and measure how users use our Platform to improve it and report relevant aggregated management information||Performance of contract, Legitimate Interest|
|Product Referrals||Identity, Contact, Financial, Open Banking||To allow Wagestream to refer to you, and for you to access, third party products and services||Performance of contract, Consent|
|Surveys||Identity, Contact, Profile||To improve our service||Legitimate interest|
|Research and Statistics||Identity, Contact, Profile, Employer, Financial, Open Banking, Transaction, Behavioural, Technical and Other Personal Data||We use a range of rigorous scientific methods to understand our users better and how to support them which also serves to further a general public interest.||Legitimate Interest|
|Service Improvement and Development||Identity, Contact, Profile, Employer, Financial, Open Banking, Transaction, Behavioural, Technical and Other Personal Data||To improve our existing Wagestream services and develop ancillary services where we think these would be of interest to our users.||Legitimate Interest|
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Behavioural, Open Banking and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications (including by email and push notification) from us if you have requested information from us or obtained services from us and you have not opted out of or unsubscribed from receiving that marketing.
We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.
You can ask us to stop sending you marketing communications at any time by logging into the App and changing your preferences via the Profile tab (in respect of push notifications) or by following the unsubscribe links in any of our marketing emails sent to you (in respect of email communications) or by contacting us at any time using the contact details shown in “Who We Are and How to Contact Us” above (in respect of either or both).
Where you opt out of receiving these marketing messages, this will not apply to transactional or service messages. Please allow two working days for instruction to take effect in all of our systems.
Who we share your Personal Data with
We may share your Personal Data with the third parties set out below for the purposes set out in this privacy notice:
Your employer. Your employer(s) engaged Wagestream to provide the Platform and Wagestream services. We share your Personal Data with your employer(s) to provide them and you with such Platform and services.
Members of our group of companies (Wagestream, Inc., Wagestream IS Limited and Wagestream Financial Services UK Limited). For reporting purposes and the provision of ancillary services, insurance services and customer services support.
Partners. Where partners provide elements of our, or ancillary, services.
Service providers. For the provision of IT and system administration services, email service providers, customer services, KYC and AML service providers, and other support services which allow us to run the business.
Professional advisers. For the provision of consultancy, banking, legal, insurance, accounting and similar services.
HM Revenue & Customs, regulators and other authorities acting as processors, and our principals, who require reporting of processing activities in certain circumstances.
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 Notice.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the 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.
International data transfers
Many of our external third parties are based outside the UK so their processing of your Personal Data will involve a transfer of data outside the UK.
Where we transfer your Personal Data outside the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- we will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data.
- we use certain service providers, we may use specific contracts approved for use in the UK which give Personal Data the same protection it has in the UK.
How we keep your Personal Data secure
We have put in place appropriate technical and operational security measures designed to prevent your Personal Data from loss, misuse, alteration or destruction. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. If you suspect any misuse or loss of, or unauthorised access to, your Personal Data, you should let us know immediately.
How long we store your Personal Data
We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above in “How we use your Personal Data and why”, unless a longer retention period is required by law (for example for regulatory purposes).
Generally, we will store your information for as long as you’re using Wagestream, and for five years after that to comply with the law. In some circumstances, like cases of anti-money laundering or fraud, we may keep data longer if we need to and/or the law says we need to.
Information related with Platform use and marketing activities are typically stored for three years.
What happens when you do not provide necessary Personal Data?
Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and your employer and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Platform).
In this case, we may have to stop you using our Platform, but we will notify you if this is the case at the time.
Automated Decision Making
Wagestream does not apply automated decision making (including profiling) producing legal effects concerning, or similarly significantly affecting, you.
Third party links
This Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the Privacy Notice of every site you visit.
Your rights relating to your Personal Data
By law you have the right to:
You have certain rights under the law, such as notice to request access to your information, to manage it and to request for it to be deleted or to transfer information about you or to restrict the way it is used.
- Request access to your Personal Data. This is commonly known as a “data subject access request” and enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below). Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest (or those of a third party) as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Platform. We will advise you if this is the case at the time you withdraw your consent.
How to exercise your rights
If you wish to exercise any of these rights where we are the Controller please contact us using the contact details shown in “Who We Are and How to Contact Us”. Where we are the Processor, please contact the Controller (this will usually be your employer). If you are unsure, please contact us and we will be pleased to help establish who will be best placed to help you. Please note, our own contractual obligations with the Controller may require us to advise the Controller of the request.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee, or refuse to comply with the request, if it is unfounded, repetitive or excessive.
We may need to request specific information from you to help us confirm your identity to exercise any of your rights, including those related to data protection). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you would like to make a complaint regarding this Privacy Notice or our practices in relation to your Personal Data, please contact us at: DPO@wagestream.co.uk or using our contact details above addressed “For the attention of: DPO”.
We aim to respond within one business day to all complaints and resolve them within the shortest time possible. Under the regulatory framework we are required to send a final response within 15 business days. If you submit a complaint, we both must first attempt to resolve the issue directly between us. However, if you feel that your complaint has not been adequately resolved, please note that the UK GDPR gives you the right to contact our lead supervisory data protection supervisory authority, which for the UK is the ICO (www.ico.org.uk).
You have the right to make a complaint at any time to the ICO, the UK regulator for data protection issues, (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Where we are a Processor
Where we are a Processor of your Personal Data we will operate under the terms of a Data Protection Agreement with the relevant Controller.
This is generally when we receive information from your employer for enrolment and awareness campaign purposes.
How your employer (or another Controller in respect of whom we are a Processor of your Personal Data) processes your Personal Data, including through us, will be set out in their Privacy Notice.
This privacy notice is version Privacy Notice: 2023_4 and was last updated on 11 July 2023. We will post any changes to this Privacy Notice on this page.