Zumo Financial Services Limited - August 2021
How to contact us
If you need to contact us, you can do so by emailing us at firstname.lastname@example.org. We will communicate with you in English.
The information we hold about you
We collect the following types of information when you sign up for a Zumo account, use our services and interact with us:
We collect the following types of information from other sources
When you sign up for a Zumo account we perform checks at:
For more information about who we share data with please see ‘Who we share your data with and why’ below.
We may also collect information about you from public sources for AML reasons, such as official public records or information published by the press or on social media.
How and why we use your information
We’re required to have a lawful basis for using your personal data. This means one of the following must apply: contractual duty, legal duty, legitimate interest, public interest, vital individual interest or consent. This section explains which one we rely on when we are using your data in a certain way.
This is when we need to use your data for a contractual duty we have with you, or to enter into a contract with you. We use information about you to:
This is when we need to use your data to comply with a legal duty. We use information about you to:
We use your data for our legitimate interests, or those of a third party. This means using data in a way that you might expect us to, for a reason which is in your and/or our (or a third party’s) interest and which doesn’t involve overriding your privacy rights. The situations where we do this are set out below.
i) Product development and marketing. We:
ii) Security and business management. We:
iii) Companies that give services to us. We:
We ask for your consent to:
You can withdraw your consent at any time by unsubscribing from such marketing, or deleting your profile picture in the app.
The nature of cryptoassets and blockchain
Your Zumo account includes a cryptoasset wallet which is non-custodial. Transfers to and from your cryptoasset wallet take place directly on the blockchain for that cryptoasset. The blockchain is a publicly viewable ledger. This means your transactions can be identified and viewed from this ledger. This is a design feature of the blockchain and Zumo has no control over this.
You can choose to keep your address hidden in the app, but this will not necessarily stop it from being identifiable to others. For example, if a Zumo contact sends you Bitcoin, that contact can look at their transaction on the blockchain to identify the address (i.e. your address) it was sent to and use that to look at your other transactions. Similarly, if you give your Zumo wallet address to a friend so they can send Bitcoin to it, they can also use your address to look at your transactions on the blockchain.
Who we share your data with and why
Companies that provide services. We share your data with companies that help us provide the services you use and which need to process details about you for this reason. These are:
Law enforcement and other external parties. We may share your details with:
We’re required to keep most of your data for as long as you are a Zumo customer and then for at least 5 years after that time. This is a regulatory requirement which means this period of time can change to stay in line with any change in regulations. In some circumstances, like cases of anti-money laundering or fraud, we may keep data longer if we need to for a legitimate interest and/or the law says we have to.
To work out how long we keep different categories of data, we consider why we hold it, how sensitive it is, how long the law says we need to keep it for, and what the risks are.
You have a right to:
Where we store or send your data
We may transfer and store the data we collect from you to organisations outside the UK. When we do this we make sure your data is protected. We also make sure it is either a country that the UK states has adequate data protection standards, or we have European Commission approved standard contractual clauses in place with the relevant organisation.
How to make a complaint
If you have a complaint about how we use your personal information, please contact us by emailing email@example.com. We will communicate with you in English and you should let us know if any of your contact details change.
Complaints If you’re still not happy you can raise your complaint to the Information Commissioner’s Office (ICO). For more details please visit the ICO’s website at https://ico.org.uk/
Changes to this policy