Privacy Policy

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 (as amended from time to time).

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 7-9 Rathbone Street, London, W1T 1LY; 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 a PSD agent (firm reference 995651) of Bud Financial Limited (firm reference 793327), a Payment Institution authorised by the FCA, for Account Information Services.

We are registered with the Information Commissioner’s Office (“ICO”) with reference number: ZA421647 (Wagestream Limited).

In this Privacy Notice, where we refer to “Wagestream”, “we”, “us” or “our” we mean Wagestream Limited unless expressly stated otherwise or the context otherwise requires.

The privacy notice applicable to the provision of regulated products and services (e.g. credit cards, loans and workplace savings) and provided by Wagestream Finance Limited can be found here.

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.

You can contact us through the App or website; by emailing: [email protected]; or writing to us at DPO, Wagestream, 7-9 Rathbone Street, London, W1T 1LY.

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, AML checks, and profile picture where added).
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; absences, name of employer, place of work and employment history.
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; our communications with you (which may include correspondences, call and video records, transcriptions and analysis thereof).
Health Data	Includes data about your health such as absence data, where shared by your employer, to allow Wagestream to accurately adjust your salary accrual, this may include the reason that you are absent from work; any sensitive health information that individuals provide us during Coach conversations, or conversations with our support team, or any other communications that may reveal your vulnerability status, such as a gambling addiction, or other health issues

Aggregated Data

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 may need to process sensitive information about you that data protection laws call “Special Category” data. This is information that can reveal details about a person’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and information about health and genetic data.

Our reasons for using special category data

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 or your employer provide us with the same for the purposes of (i) ensuring accurate earnings calculations when absent from work; (ii) providing our Coach product to you; or (iii) protecting your financial wellbeing if you are at risk.

We may share information about you externally where we deem it is necessary to protect your vital interests or the vital interest of another person.

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 immediately by email at [email protected]; or writing to us at DPO, Wagestream, 7-9 Rathbone Street, London, W1T 1LY.

How we collect your Personal Data

Directly

Directly from you via in-App chat, by filling in forms or by corresponding with us by post, phone, email, social media channels or otherwise. This includes, without limitation, 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 other Open Banking services including product referrals.
Our service providers	Identity, Contact	To perform identity checks and compliance monitoring
Affiliate networks (where you have authorised cookies for discount and/or cashback purposes)	Identity, Technical, Transaction Data	To perform our discount and cashback services

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, Health Data, Financial	To provide you with the Wagestream services and related communications	Performance of contract, Consent
Open Banking	Open Banking	To provide our account information services and other Open Banking services	Performance of contract
Customer services and staff training	Identity, Contact, Profile, Employment, Financial, Customer Support, Technical, Marketing and Communications Data	To provide user support; to train our staff	Performance of contract, Legitimate Interest
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, Technical Data, Transactional Data, 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
Verification Data Disclosure	Identity, Contact, Employment Data	When you make an application to a third party such as a utility provider, a financial services provider, or a potential employer, for a product such as a credit card, loan or a mortgage, or a potential job role, we would provide your income and employment verification to the third party you have made an application to (and their agents) at your request.	Legitimate Interest
Work Profile	Identity, Contact, Employment Data, Work Experience	Where you create a work profile with us upon leaving your employer, this will be made visible to potential employers.	Consent

Marketing

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.

You will receive marketing communications by text and/or WhatsApp only where you have consented to receive the same.

Third-party marketing

We will get your express opt-in consent before we share your Personal Data with any third party for their marketing purposes.

Opting out

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 in relation to text or WhatsApp messages by replying “STOP” as indicated in these messages. You may also unsubscribe or opt out 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 communications).

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 Financial Services UK Limited, and Wagestream Finance Ltd). Data is shared for: reporting purposes; and the provision of ancillary services; and insurance services; and credit/regulated products; and customer services support.

Partners. Where partners provide elements of our, or ancillary, services.

Affiliate networks. To track sales originating from our service.

Service providers. For the provision of IT and system administration services, email service providers, marketing service providers, customer services, KYC and AML service providers, to support our products and services, 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.

Utility or financial service providers and their third-party agents. When you make applications to access such third parties’ products or services who may need your income and employment verification and you request us to do so.

HM Revenue & Customs, regulators and other authorities acting as processors, and our principals, who require reporting of processing activities in certain circumstances.

Employers. To share your Work Profile, allow verification of your Work Profile, work history, and any associated data with prospective employers.

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.

Wagestream shall not transfer your personal data outside of the UK or the European Economic Area (EEA) unless it has taken such measures as are necessary to ensure the transfer is in compliance with applicable data protection laws (including EU GDPR and the Data Protection Act 2018/UK GDPR, in each case as in force and applicable, and as may be amended, supplemented or replaced from time to time) Such measures may include (but are not limited to) transferring your Personal Data to a recipient in a country that the UK or European Commission (respectively) has decided provides adequate protection for Personal Data, to a recipient that has achieved binding corporate rules authorisation in accordance with applicable data protection laws, or to a recipient that has executed standard contractual clauses adopted or approved by the UK or European Commission (respectively).

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 as long as necessary 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).

We may store your information for as long as you’re using Wagestream, and for five years after the end of our relationship with your employer 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.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Platform may become inaccessible or not function properly. Please click here for our Cookies Notice.

Your rights relating to your Personal Data

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.

By law you have the right to:

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.

Complaints

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: [email protected] 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: 2024_2 and was last updated on 16 October 2024. We will post any changes to this Privacy Notice on this page.