Privacy policy

Version 4.0, 21 November 2022

Introduction

Coconut (“we”, “us”, “our”) takes your privacy seriously and we are committed to best practices in respect of your personal data and complying with data protection laws.

This policy applies to Coconut as a whole; including our website and mobile app, and is written for visitors to our website and our prospective and existing customers. This policy also applies to various storage mediums including physical and digital.

Who we are

Coconut is a company registered in England and Wales with number 09904418 (our registered name is Coconut Platform Ltd). Our registered office is 27 Old Gloucester Street, London WC1N 3AX.

We deliver the Coconut product and service, including designing and developing the Coconut app and providing ongoing customer support.

In respect of GDPR, we are the data controller, meaning we collect your personal information and choose how to process it and who we need to share it with for further processing.

You can contact us any time by emailing us at support@getcocout.com. For data protection specific questions please contact data@getcoconut.com.

The data we collect and why

In order to offer our service which is to operate, maintain and support our current account we need to collect various personal data for various reasons. These reasons are:

• Contract: when you open and use our account you enter into a contract with us to provide our services
• Legal obligation: we are legally obliged to process your personal data e.g. for the prevention of fraud and to offer strong customer security
• Legitimate interests: providing our type of product requires in some cases that we process data e.g. for improving our service
• Consent: where applicable, such as communications preferences, we will ask for your consent

The following summarises which data is collected and on which bases it is processed:

• Personal details (Contract, Legal Basis): Full legal name, preferred name, date of birth and address
• Business details (Contract, Legal Basis): Trading name, legal status and profession
• Contact details (Contract, Legal Basis): Your email and mobile number
• Technical data (Contract, Legal Basis): Device vendor ID, name, make and model. Your IP address may also be collected
• Transaction data (Contract, Legal Basis): Details about the transactional activity of your connected accounts and cards.
• Communications data (Contract, Legal Basis, Consent): What we learn about you from emails and conversations between you and us.
• Analytical data (Legitimate Interests): Data related to how you use our products and services such as which actions are taken in the app or on the account.

Account Information Services

We use an Account Information Services Provider (Truelayer) to connect your other accounts to Coconut. When you connect, Truelayer gains read-only access and stores transaction data associated with the connected accounts. This lets us display your account information and transactions within Coconut. All your details are encrypted and protected by bank level security.

By connecting with Truelayer you’ll be agreeing to their Terms of Service and Privacy Policy.

For the purposes of providing Account Information Services, Truelayer will retain Personal Data. 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 Truelayer access, use, process and store your personal data for the provision of the Services is set out in Truelayer’s Privacy Policy.

Sources of personal data

Personal information will only be collected directly and voluntarily from you as part of the sign up or as a result of transactions relating to your accounts and card connected to Coconut.

Storage and recipients of personal data

We store your data primarily in the European Economic Area (EEA) however there are some aspects of operating our service that require us to transfer and store parts of your personal data with 3rd parties in non-EEA countries. We only send your personal information outside of the non-EEA countries with your permission, on your instructions or to comply with a legal duty.

Where this is the case we have ensured that we have the necessary agreements in place with those 3rd parties to the level expected by European data protection law.

Some of the kinds of 3rd parties that receive your personal data are in the areas of:

• Infrastructure (servers, databases etc.)
• Address/account lookup
• System emails
• Update/marketing emails
• Text messages
• Push messages
• Error logging
• Customer support
• Product and marketing analytics

Security of data

We operate a “Secure by Design” approach to protecting your data. This involves the use of best practices such as intrusion detection systems, firewalls, access control, encryption and key rotation and policies that ensure only those who need access to data do.

3rd parties holding your personal data are expected to apply the same level of security and controls.

Whilst we issue notifications for key changes in your profile, if you suspect anything suspicious please let us know.

If we become aware of unauthorised access to your data we will contact you promptly.

Read more on Coconut security

Selling information

We do not and will never sell your personal data.

Data retention

Your personal data are retained so long as you remain an active customer of Coconut, i.e. you have an open account with us.

In the event that you wish to close your Coconut account we don’t keep your information for longer than we need to, which is usually 7 years after the end of the relationship or upon termination of the contract, unless we are required to keep it longer (for example due to a court order or investigation by law enforcement agencies or regulators). This is so that we meet our legal obligations, e.g. the Money Laundering Regulations 2017.

After this time has elapsed your data will be deleted from all Coconut and 3rd parties systems.

Your rights

Under the General Data Protection Regulation 2018 you have enhanced rights in respect of your personal data and special category data.

• Right to be informed. This Privacy Policy constitutes our informing you of how we use your personal data and your rights.
• Right of access. You have the right to understand how we process your personal data and on which legal basis as provided in this Privacy Policy. You also have the right to request access to your personal data.
• Right to rectification. You have the right to correct any incorrect personal data we store about you. You can change your own personal data in most cases or else speak with our Customer Support team.
• Right to erasure. Also known as the right to be forgotten, you may ask for your personal data to be deleted. Please note that this will constitute an account closure in most cases. We are legally obliged to retain data however even after an account closure – see Data Retention.
• Right to restrict processing. You have the right to restrict our processing of your personal data.
• Right to data portability. You have the right for your personal data to be exportable in easy to use, open formats such as CSV.
• Right to object. You have the right to object to use of your personal data for direct marketing.
• Right to withdraw consent. You have the right to withdraw your consent to the processing of your personal data. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
• Rights related to automated decision making including profiling. We do not conduct any automated decision making.

To exercise any of your legal rights, you can email us at data@getcoconut.com.

For a more detailed explanation of each of these rights we would encourage interested readers to visit the Information Commissioner’s Office on GDPR.

How can I manage my Coconut Privacy?

You can use the Profile area of the app to view or update some of your personal data.

Big Data

Big Data means processing and analysis of large amounts of data to identify patterns, trends and associations that can be used to make decisions.

Coconut shall only ever perform such Big Data processing on anonymised data, i.e. data that is not linked to a specific person.

Example: we might want to understand how age groups of our customers relate to the usage of Coconut features so that we can tailor our product better.

Complaints

If you aren’t happy with how we’ve handled your personal information, please email us at complaints@getcoconut.com and we’ll try our best to make it right.

(For complaints relating to how our former e-money account services provider, PPS, have handled your personal information, you can contact their Data Protection Officer at dpo@prepaysolutions.com).

If you’re still not happy, you can contact the Information Commissioner’s Office

Closing your account

The expression of some of your rights such as erasure, restricting and objection may lead to a need for you to close your account with us.

If you want to close your account for any reason, just write to us and we will get this processed for you. Once your account is closed, you will lose access to your account. We’ll talk you through how to export your records before closing your account.

Changes

This policy may change from time to time and is effective from date of posting to our website and app. For significant changes we will also let you know by email or through the Coconut app.

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