Zuberi Pay 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.
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.
Who we are and how to contact us
You can contact us through the Zuberi Pay app, or by emailing: Hello@zuberipay.com
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.
Where your request relates to information processed by Zuberi Pay as Processor, and not Controller (generally, where the personal data is processed as part of the Zuberi Pay service), please contact your employer in the first instance, who is the Controller of the personal data (typically the Human Resources or Payroll department processing your salary related personal information).
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 if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.
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 to speed up our response.
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.
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, company of employment .|
|Contact Data||Your home address, email address and telephone numbers.|
|Financial Data||Your bank sort code and account number, Net 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.|
|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 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.
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:
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|
|Account Creation and Transfer||Identity Data
|To register you as a new user and provide you with the Zuberi Pay services.|
|Fraud Prevention||Identity Data
|To keep our website, our services and associated systems operational and secure. To keep your data and identity secure.|
|Troubleshooting||Technical Data||To track issues that might be occurring on our systems.|
|Optimisation and Analytics||Identity Data
|To understand and measure how users use our Platform to improve it and report relevant aggregated management information.|
|To capture interest in Zuberi Pay and to keep prospects and clients informed.|
|Product Referrals||Identity Data
Contact Data .
|To allow interested employees to refer Zuberi Pay to their employer.|
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 have with us, but we will notify you if this is the case at the time.
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.|
|Your employer||No||Identity Data
Zuberi Pay does not apply automated decision making to profiling, i.e. to assess suitability for our products.
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|
|Your Employer(s)||Financial Data Transaction Data||Your employer(s) engaged Zuberi Pay to provide the Platform and Zuberi Pay services. We share your personal data with your employer(s) to provide them and you with such|
|Business partners, suppliers and subcontractors||Identity Data
|For the performance of any contract we enter into for the uses set out in the section|
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:
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.
We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above. 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 Zuberi Pay, 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.
This Platform is not intended for individuals below 16 and we do not knowingly collect data relating to such children.
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.