Privacy Policy

1. Introduction

1.1 We at Ribbon PLC are committed to safeguarding your privacy and keeping your personal data private.

1.2 This Privacy Notice applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data. Details of how Transact Payments Limited, issuer of your Ribbon VISA debit card collects and processes your personal data can be viewed in their Privacy Policy.

1.3 We will ask you to consent to our use of cookies in accordance with the terms of our Cookie Policy when you first visit our website.

2. How we obtain and use your personal data

2.1 In this section we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(d) the legal basis of the processing.

2.2 The type of information we hold about you:

We may collect, store, and use the following categories of personal data about you:

Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
ID documents, such as, driving licences, passports, etc.
Photographs
Date of birth
Gender
Employment status and salary
Marital status and dependants
Financial information
Pay records
Details of your employment or workplace
Details on payer or payees sending or receiving funds from you using Ribbon account
Information we obtain from third parties, such as information that we obtain when verifying details supplied by you and information collected from publicly available sources, including Companies House. Such third parties may include fraud prevention agencies, banks, merchants and credit reference agencies.
Other information about an individual that you or they disclose to us when communicating with us
CCTV footage
IP addresses
Special category data and/or - data/details relating to your health, marital or partnership status (e.g. any kind of vulnerability, health condition, etc.)
Cookies (please see our COOKIES policy)

2.3 Lawful grounds for using your information:

We are permitted to process your personal data in compliance with Data Protection Legislation by relying on one or more of the following lawful grounds:

You have explicitly agreed to us processing such information for a specific reason;
The processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you;
The processing is necessary for compliance with a legal obligation we have;
The processing is necessary for the purposes of a legitimate interest pursued by us, which might be: to provide services to you;
- to ensure that our customer accounts are well-managed;
- To prevent, detect, investigate and prosecute fraud and alleged fraud, money laundering and other crimes and to verify your identity in order to protect our business and to comply with laws that apply to us and/or where such processing is a contractual requirement of the services or financing you have requested;
- to protect our business interests;
- to ensure that complaints are investigated;
- to evaluate, develop or improve our services; or
- to keep our customers informed about relevant services, unless you have indicated at any time that you do not wish us to do so.

2.4 Purposes of processing:

How we use your information	Legal basis
To provide and manage your account(s) and our relationship with you	Where necessary for the performance of our agreement or to take steps to enter into an agreement with you Where the law requires this Where it's in our legitimate interests to ensure that our customer accounts are well-managed, so that our customers are provided with a high standard of service, to protect our business interests and the interests of our customers
To give you statements and other information about your account or our relationship	Where necessary for the performance of our agreement or to take steps to enter into an agreement with you Where the law requires this
To handle enquiries and complaints	Where necessary for the performance of our agreement or to take steps to enter into an agreement with you Where the law requires this Where it's in our legitimate interests to ensure that complaints are investigated, for example, so that our customers receive a high standard of service and so that we can prevent complaints from occurring in future In the case of sensitive information, such as medical information, where you have shared it with us
To provide our services to you	Where necessary for the performance of our agreement or to take steps to enter into an agreement with you Where the law requires this
For assessment, testing (including systems tests) and analysis or behaviour scoring, statistical, market and product analysis and market research.	Where the law requires this Where it's in our legitimate interests to develop, build, implement and run business models and systems which protect our business interests and provide our customers with a high standard of service
To evaluate, develop and improve our services to you and other customers	Where it’s in our legitimate interests continually to evaluate, develop or improve our products as well as the experiences of users of our sites, so that our customers are provided with a high standard of service
To protect our business interests and to develop our business strategies	Where it's in our legitimate interests to protect our people, business and property and to develop our strategies Where necessary for the performance of our agreement or to take steps to enter into an agreement with you Where the law requires this
To contact you, by post, phone, text, email and other digital methods. This may be: to help you manage your accounts to meet our regulatory obligations to keep you informed about products and services you hold with us and to send you information about products or services (including those of other companies) which may be of interest to you.	Where the law requires this; Where you have consented to contact you for any promotional or marketing communication. Where we send you such messages, you can always tell us when you no longer wish to receive them. We have a legitimate interests to do so, taking into consideration your rights. Our legitimate interests may include one or more of the following: Ensuring the reliability of services offered by us Protection of your interest from any potential frauds Compliance with contractual obligations
To meet our regulatory compliance and reporting obligations and to prevent, detect, investigate and prosecute fraud and alleged fraud, money laundering and other crimes.	Where the law requires this Where it's in our legitimate interests to prevent and investigate fraud, money laundering and other crimes Where such processing is a contractual requirement of the services you have requested.
To assess any application you make, including carrying out fraud, money laundering, identity, sanctions screening and any other regulatory checks.	Where you have made data public Where such actions are in our legitimate interests, for the protection of our business interests Where the law requires this
To monitor, record and analyse any communications between you and us, including emails, chatbot and phone calls	Where it’s in our legitimate interests, to check your instructions to us, to prevent and detect fraud and other crime, to analyse, assess and improve our services to customers, and for training, for the enhancement of our customer service provision and protection of our business interests In the case of sensitive information, such as medical information, where you shared it with us
To transfer your information to or share it with any third party to whom your account has been or may be transferred following a restructure, sale or acquisition of any Ribbon group company	Where necessary for the performance of our agreement with you Where we have a legitimate interest in restructuring or selling part of our business
To share your information with UK or other relevant tax authorities, credit reference agencies, fraud prevention agencies, and UK and overseas regulators and authorities	Where the law requires this Where we have a legitimate interest in performing certain credit checks so that we can make responsible business decisions. As a responsible organisation, we need to ensure that we only provide certain products to companies and individuals where the products are appropriate, and that we continue to manage the services we provide, for example if we consider that you may have difficulties making a payment to us. Where we have a legitimate interest in assisting with the prevention and detection of fraud and other crime Where we have a legitimate interest in assisting Gibraltar or UK and overseas regulators, who monitor financial institutions to ensure that they comply the law and regulations. More detail on our data sharing with these organisations is set out below
To share your information with our partners and service providers	Where necessary for the performance of our agreement Where we have a legitimate interest in using third parties to provide some services for us or on our behalf See more information about this in section 4.

3. Automated Decision Making

3.1 As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision making: if you want to know more please contact us using the details provided in this Privacy Notice.

3.2 If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk: (i) we may refuse to provide the services you have requested, or we may stop providing existing services to you; and (ii) a record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services or employment to you.

3.3 A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details above.

4. Providing your personal data to others

4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this Notice.

4.2 We may disclose your personal data to third party service partners or data processors. We use data processors who provide elements of services for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

4.3 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.4 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own p

4.5 In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.6 The recipient of your personal data may also include the following:

Gibraltar, UK and overseas regulators and authorities in connection with their duties (such as crime prevention).
Any revenue service or any tax authority.
Credit reference, identity and address verification organisations who may record and use your information and disclose it to other lenders, financial services organisations and insurers. We perform identity checks on you with one or more credit reference agencies. To do this, we will supply your personal data to the credit reference agencies and they will give us information about you. We will also continue to exchange information about you with credit reference agencies while you have a relationship with us.

4.7 In addition, please note the following:

Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.
The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity.
We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested

5. Data transfers

5.1 In this section, we provide information about the circumstances in which your personal data may be transferred to countries outside the UK, Gibraltar or the European Economic Area (EEA).

5.2 We and our subsidiary companies have offices and facilities in India, UK and Gibraltar. The European Commission has thus far, not made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from here.

5.3 You acknowledge that personal data that you submit for publication through our app, website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5.4 Further, fraud prevention agencies may allow the transfer of your personal data outside of the UK. This may be to a country where the UK Government has decided that your data will be protected to UK standards, but if the transfer is to another type of country, then the fraud prevention agencies will ensure your data continues to be protected by ensuring appropriate safeguards are in place

6. Retaining and deleting personal data

6.1 This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6.4 Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years

7. Amendments

7.1 We may update this Privacy Notice from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes to this Privacy Notice.

7.3 We may notify you of changes to this Privacy Notice by email or through the private messaging system on our website.

8. Your rights

8.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a) The request has been provided to us in writing.

(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

We may refuse your request if it is manifestly excessive or repetitive of a previous request, we have already provided to you. It will help expedite your request if you can provide sufficient detail of the nature of your request to enable us to provide a prompt targeted response.

Please note we will comply with your request within 30 days of proof of identity being provided and accepted. In circumstances where your request is complex and we require more time, we will write to you to inform of this and our anticipated response timeframe.

8.2 We may withhold personal information that you request to the extent permitted by law.

8.3 You may instruct us at any time not to process your personal information for marketing purposes.

8.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt-out of the use of your personal information for marketing purposes.

8.5 You have the right to:

8.5.1 Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

8.5.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

8.5.3 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.

8.5.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) 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.

8.5.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data's accuracy.
Where our use of the data is unlawful, but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

8.5.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.

8.5.7 Withdraw consent at any time where we are relying on consent to process your personal data by writing to customerservices@ribbonglobal.com. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you would like to contact us in relation to any of the rights set out above please contact us using the following contact details. To protect your privacy and security, we may take reasonable steps to verify your identity before providing you with the details.

Ms Sonal Chopra, The Data Protection Officer, Ribbon Plc. Registered Office: 2 Irish Town, Gibraltar GX11 1AA

9. Special Category Data

In general, we will not collect any sensitive (special category data) about you unless we have a lawful reason to do so. In the event that we are required to obtain special category data we will provide you with the rationale for our request and the purpose. We will obtain your consent to hold special category data about you, except under circumstances where we need to classify you as a vulnerable customer.

10. Right To Complain To The Supervisor

You can contact the respective regulatory authority, as the Information Commissioner, if you have any concerns about how Ribbon Plc has handled your personal data and you also have the right to make a complaint at any time to the Information Commissioner's Office. You can find out more information about your rights as a data subjects, their regulatory powers and actions they can take on their website.