Pouch Privacy Policy


Find out exactly how Pouch uses your data and how Pouch keeps this information secure.


Pouch LTD Privacy Policy

Last updated August 23, 2024

Introduction

Welcome to Pouch LTD ("we", "us", "our"), is a company registered in England and Wales whose registered office is at 1A Spen Road, Leeds, LS16 5AL and whose registered number is 15278653.  We are committed to protecting and respecting your privacy. We are the data controller for the purposes of the personal data we collect via our platform and for the performance of the services listed under the usages of your personal data, below (together, the “Services”). This Privacy Policy outlines how we collect, use, and protect your personal data when you interact with our Services. By using our Services, you agree to the terms of this Privacy Policy.  We are registered with the Information Commissioner's Office (the ICO) with registration number: ZB741458.

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Use of our online services​

Collection of personal data

‍When you use our Services we will have access to your personal data that you submit to us and personal data held by Account Servicing Payment Service Providers (i.e. any payment service provider, such as a bank or a credit card issuer that maintains an online payment account on your behalf) (“ASPSPs”) (“Personal Data”) for the duration of the transmission. Such Personal Data may include your date of birth, gender, account information, account balance, transactions, information on loans, insurance data and investments data. The manner in which we access, use, process and store your personal data for the provision of the Services is set out below.

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‍Images

Pouch stores the image that you decide to upload when verifying your identity with us or adding a profile picture to your profile. You can, of course, choose not to upload any of this data.

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Usage Data: 

 App Usage Information: We collect information about how you interact with our app, including pages visited and actions taken. 

 

Device and Log Data: 

  • Device Information: We collect device information such as device model, operating system version, and unique device identifiers. 

  • Log Data: Our servers automatically record information that your device sends whenever you use our app. 

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Purposes for Which We Will Use Your Data

Use of your personal data

In order to access and use the main functionality of our Services, we will direct you to use one of our trusted service providers or an ASPSP that implements Open Banking in order to transmit and access information (including personal data) relating to payment accounts (“Account Information”) that you hold with ASPSPs to us.

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The information we collect and process will be used to run the Services which include:

  • Providing, operating, and maintaining our app. 

  • Personalising your experience and improving our services. 

  • Communicate with you, including customer support. 

  • Analysing usage to improve functionality

  • Facilitate bank integrations and provide financial services through our AISP

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Consent

We’ll be able to access your Account Information (including any Personal data), if you give us explicit consent.

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‍How do I withdraw my consent?

If after you provided your consent, you change your mind, you may withdraw your consent by contacting us at our address or at the email address set out in the contact information within this Privacy Notice.

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Data Retention

Pouch LTD will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. The criteria we use to determine the retention periods include:

  • Legal and regulatory requirements: We will retain certain types of information for as long as required by law or regulation.

  • Business purposes: We will retain personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purpose of satisfying any legal, accounting, or reporting requirements.

Typically, we retain personal data up until our business relationship with you ends or such period as required by applicable local laws. Once the retention period expires, your personal data will be securely anonymised and deleted within 30 days to prevent it from being associated with you.

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Delete Account Flow 

You have the right to delete your account and personal data from our servers, including any data collected via transmission from ASPSPs. Here’s how you can delete your account: 

  • Launch Pouch Application: Open the Pouch app on your mobile device. 

  • Login: Sign in to your account using your credentials. 

  • Navigate to Settings: Tap on the settings icon in the app. 

  • Profile Settings: Select "Profile Settings" from the menu. 

  • Delete Profile: Tap on "Delete Profile" and follow the instructions provided. 

  • OTP Verification: Enter the OTP received on your registered phone number to verify your identity. 

  • Account Deletion: Your account will be permanently deleted.

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Disclosure of Your Information

We do not sell, trade, or otherwise transfer your personal information to third parties without your consent, except as described in this Privacy Policy or required by law. We may share your information with service providers who assist us in providing the app and its services. 

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We ensure that any third parties with whom we share your data are required to respect the security of your personal data and to treat it in accordance with the law. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

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Keeping Your Personal Information Secure

We take the security of your personal information very seriously. We implement appropriate physical, technical, and administrative measures to safeguard your data from unauthorised access, use, or disclosure. This includes:

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  • Encryption: Any personal information transferred to our banking partner or other third parties is encrypted.

  • Access Controls: Strict procedures and security features are in place to prevent unauthorised access to your data.

  • Contractual Safeguards: Agreements with our third-party service providers ensure they employ suitable security measures to protect your information.

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Your Rights

You have the right to access, update, or delete your personal information. You may also withdraw your consent for data processing at any time. 

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Subject Access Requests

You have the right to ask us to provide any personal data we have collected about You, to You. Should You wish to do so, please email us at info@getpouchai.com to make a subject access request detailing:

  • your name,

  • your phone number,

  • the period of data you’d like access to.

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Making a complaint to a supervisory authority

Should you be dissatisfied with the service we provide, you have the right to file a formal complaint to the Information Commissioner's Office at www.ico.org.uk.

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To exercise any of these rights, please contact us at info@getpouchai.com.  We aim to respond to all legitimate requests within one month. If your request is particularly complex, it may take us longer, but we will keep you informed.

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Lodging a Complaint

If you have any concerns about our use of your personal data, you can make a complaint to us at info@getpouchai.com.  If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO).

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Changes to This Policy

We may update this privacy policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any significant changes by posting the new policy on our website and, where appropriate, by other means. The date of the latest revision will be indicated at the top of the policy.

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Contact Information

If you have any questions or concerns about this privacy policy or our data practices, please contact us at:

Pouch LTD
Address: 1a Spen Road, Leeds, LS16 5AL, United Kingdom
Email: info@getpouchai.com

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Thank you for using Pouch LTD. Your trust is important to us, and we are committed to protecting your personal data.