Welcome to Wagestream’s Privacy Notice
Last updated 20 August 2020
What does this Privacy Notice Cover?
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 and/or website(s) (“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 our website, social media and marketing activities. The Privacy Notice is intended to meet our duties of Transparency under the “General Data Protection Regulation” or “GDPR”.
For the purposes of the Data Protection Act 2018 and General Data Protection Regulation (EU) 2016/679 as amended from time to time (“DPA”), we may be a data controller or processor of the data we hold that may be used to identify you (“personal data”) depending on the purpose of processing.
We will post any changes to this Privacy Notice on this page.
Who we are and how to contact us
Who we are
Wagestream Ltd (referred to as either “Wagestream”, “we”, “us” or “our” in this Privacy Notice) is registered in England & Wales (company number: 11173225); at registered address Hogarth House, 136 High Holborn, London, WC1V 6PX .
Wagestream limited is registered with the FCA as an EMD Agent (firm reference number: 902046) of PayrNet; PayrNet Limited is authorised by the FCA as an Electronic Money Institution (reference number: 900594); and Modulr FS Limited and Electronic Money Institution (reference number: 900573).
We are registered with the Information Commissioner (reference number: ZA421647).
How to contact us
You can contact us through the Wagestream app, or Wagestream website; by emailing: [email protected]; or writing to us at Wagestream, Hogarth House, 136 High Holborn, London, WC1V 6PX.
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 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).
- Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest 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.
- 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
The majority of our services to our app users is based on contractual agreements with the employer’s of those users. Depending on the service and access, Wagestream may be a Processor or Controller of the user personal data. Please contact your employer or Wagestream using the contact details shown in “Who We Are and How to Contact Us” if you have any questions. Please note, ur own contractual obligations with your employer may require us to advise your employer of the request.
Where your request relates to other processing activities, please contact us directly using the contact details shown in “Who We Are and How to Contact Us”.
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.
Personal Data we process
We apply the data minimisation principle and only collect the minimum necessary data for the process.
Personal Data we may collect about you from you, from your employer and from third parties about you, is outlined in the table below.
|Category of Personal Data collected||What this means|
|Identity Data||First name, surname, last name, username or similar identifier, title, and date of birth|
|Contact Data||Your home address, email address and telephone numbers.|
|Financial Data||Your bank sort code and account number; salary.|
|Transaction Data||Any 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.|
|Other Personal Data||Employment related; gender; age; income; employment status|
|Behavioural Data||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||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, 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.|
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 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.
No Special Categories of Personal Data
We 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 and biometric data). Nor do we collect any information about criminal convictions and offences.
How we use your Personal Data and why
We will only use your Personal Data where we have a lawful basis to do so.
We do not sell your personal information to any third parties. However we may share your personal information with third parties as follows:
- Selected other parties including: business partners, suppliers and sub-contractors for the performance of any contract we enter into with your employer and you;
- analytics and search engine providers that assist us in the improvement and optimisation of our site and service;
- to comply with legal or regulatory obligations.
We have set out below, in a table format how we use your Personal Data.
|Purpose||Category(ies) of Personal Data involved||Why do we do this||Our legal basis for this use of data|
|Account Creation||Identity Data|
|To register you as a new user.||Legitimate Interest|
|Transfers and Service Provision||Identity Data|
|Provide you with the Wagestream services and communications on behalf of your employer.||Performance of contract|
|Making third party product available||Identity Data|
|Enable you to access third party products||Consent|
|Fraud Prevention||Identity Data|
|To keep our website, our services and associated systems operational and secure. To keep your data and identity secure.||Performance of contract|
|Troubleshooting||Technical Data||To track issues that might be occurring on our systems.||Performance of contract|
|Optimisation and Analytics||Identity Data|
|To understand and measure how users use our Platform to improve it and report relevant aggregated management information.||Performance of contract|
|To capture interest in Wagestream and to keep prospects and clients informed.||Consent|
|Product Referrals||Identity Data|
To allow interested employees to refer Wagestream to their employer.
|Survey Invitation||Identity Data|
|Improve our service||Legitimate Interest|
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.
Personal Data from Third Party Sources
In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we may also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.
|Third party data source||Publicly available?||Category(ies) of personal data received.||Purpose|
|Your employer||No||Identity Data|
|Wagestream Service Provision|
Automated Decision Making
Wagestream does not apply automated decision making to profiling, i.e. to assess suitability for our products.
Who we share your Personal Data with
The table below describes who we share your Personal Data with, what we share and why we share it.
|Recipients||Category(ies) of Personal Data we share||Why we share it||Location(s)|
|Your Employer(s)||Financial Data|
|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.
|Business partners, suppliers and subcontractors||Identity Data|
|For the performance of any contract we enter into for the uses set out in the section||Within EEA|
Within the United States
Where we transfer your personal data outside the European Economic Area (‘EEA’), we only do so where:
- The European Commission say there is adequate data protection;
- We’ve agreed standard data protection clauses.
How we keep your Personal Data secure
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. Measures we take include:
- Data encryption;
- Intrusion detection systems;
- Background checks for all employees accessing our physical facilities.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g. where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
If you suspect any misuse or loss of, or unauthorised access to, your 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 website visits and marketing activities are typically stored for three years.
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 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].
We aim to respond with 24 hours 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 GDPR gives you the right to contact our lead supervisory data protection supervisory authority, which for the UK and Ireland is the Information Commissioner’s Office.
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.
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