What does this Privacy Policy Cover?
This Privacy Policy demonstrates how mySolPay™ collects and processes your Personal Data, which may be either through your use of the mySolPay™ platform, including any data you may provide through this platform; or through your interaction with mySolPay™ through our website, social media, and marketing activities. The Privacy Policy is intended to meet our duties of Transparency under the “General Data Protection Regulation” or “GDPR”.
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. We will update any changes to this Privacy Policy on this page.
Who we are?
mySolPay™ Limited (referred to as either “mySolPay™”, “we”, “us” or “our” in this Privacy Policy) is registered in England & Wales (company number: 12031139); at registered address Unit 7, Salisbury House, Wheatfield Way, Hinckley, England, LE10 1YG.
mySolPay Limited is partnered with IFX (UK) Ltd which is authorised by the Financial Conduct Authority under the Electronic Money Regulations 2011 (FRN 900517) for the issuing of electronic money.
mySolPay Limited is registered with the Information Commissioner’s Office (“ICO”) (reference number: C1310908)
How to contact us
You can contact us through the mySolPay™ app or mySolPay™ website by emailing or writing to us.
E-mail: hello@mysolpay.com
Web Address: www.mysolpay.com
Address: Unit 7, Salisbury House, Wheatfield Way, Hinckley, England, LE10 1YG
The types of personal information we collect
All the Personal Data we collect from you directly via mySolPay™ platform, from your Employer and from any third-party providers of bespoke financial wellbeing content is set out below.
| Personal Data collected | Description |
|---|---|
| Identity Data | Includes Full name; Username (or similar identifier); Title; Date of Birth; Gender; Age; Nationality and language(s); Marital status and dependants; National Insurance number; Passport, Driving licence or other identity document; Pension and benefits information. |
| Contact Data | Includes your home address, email address and telephone numbers. |
| Profile Data | Includes your password, your interests, preferences, feedback, and survey responses. |
| Other Personal Data | Includes data provided to customer services support including about personal circumstances, which may include additional financial information such as household income; Financial income other than salary and financial liabilities. |
| Employment Data | Includes income; Employment status; Shifts and hours; Name of employer; Place of work; Leaving date and your reason for leaving. |
| Financial Data | includes sort code; account name; account number; salary and statutory payments. |
| Open Banking Data | Includes transaction history; Transaction amounts and descriptions; Account name; Account number; Account balance; Currency; Overdraft availability and Balance; Payment due dates and other information about your transactions, such as fees and account charges. |
| Transaction Data | Includes any details about payments to and from you; Other details of our services you have used and your transactions with 3rd parties. |
| Behavioural Data | Includes 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”. |
| Technical Data | Includes 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; Device language settings; 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. |
| Marketing and Communications Data | Includes your preferences in receiving marketing from us and third parties and your communication preferences. |
| Health Data | Includes data about your health included in your fit notes but only where you use our Insurance Services, and it is relevant to the specific insurance (e.g. Accident and Sickness Insurance). |
How we collect personal information and why we have it
Most of the personal information we process is provided to us directly by you for one of the following reasons:
Directly from you via in-App chat, website, by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
- Enrolling to mySolPay™ services.
- Creating a mySolPay™ account.
- You interact with mySolPay™.
- You request information about mySolPay™.
- You login or visit mySolPay™ or use the services and functionality available including-
- To register your interest in receiving bespoke financial well-being content.
- To register your interest in the mySolPay™ App.
- When you use a social media service- our Facebook, Instagram, LinkedIn, and Twitter page.
- You sign up for e-mails, newsletters, mobile messages, social media, or other marketing, communications, or notifications to be sent to you.
- Entering a competition, promotion, or survey.
- Giving us feedback or contacting us.
- Your Employer provides your Personal Data and information.
We also receive personal information indirectly, from the following sources in the following scenarios:
- Automated technologies or interactions
- When you interact with the mySolPay™ Platform, Technical Data about your equipment, browsing actions and patterns will automatically be collected. We collect this Personal Data by using cookies, server logs and other similar technologies. Please refer to the Cookies section for further details.
- Third party sources
- We may also collect required parts of your Personal Data from third party sources. These sources are broken down in the table below.
| Third party data sources | Personal data received | Purpose |
|---|---|---|
| Your employer (including their agents and service providers for example, workforce management systems providers) | Identity, Contact, Employment, Financial | To register you as a user and provide you with mySolPay™ services. |
| Analytics providers (such as Google based outside the UK) | Technical | To monitor issues that might be occurring on our systems and to understand and measure how users use our Platform to improve it and report relevant collected management information. |
| Your bank(s) (where you have authorised an Open Banking connection) | Open Banking | To provide you with account information services. |
| Our service providers | Identity, Contact | To perform identity checks and compliance monitoring |
How we use your Personal Data
| Purpose | Personal Data involved | Why do we do this? | Legal basis for this use of data |
|---|---|---|---|
| Account Creation | Identity, Contact | To register you as a new user | Performance of contract |
| Transfers and Service Provision | Identity, Contact, Profile, Employment, Financial | To provide you with the mySolPay™ services and related communications | Performance of contract |
| Open Banking | Open Banking | To provide our account information services | Performance of contract |
| Customer services | Identity, Contact, Profile, Employment, Financial, Customer Support, Technical, Marketing | To provide user support | Performance of contract |
| Compliance and Fraud Prevention | Identity, Contact, Behavioural, Technical, Financial | To keep our App, our services, and associated systems operational and secure. To keep your data and identity secure | Performance of contract, Legitimate Interest |
| Troubleshooting | Technical | To track issues that might be occurring on our systems | Performance of contract, Legitimate Interest |
| Optimisation and Analytics | Identity, Contact, Transactional, Technical, Behavioural, Open Banking | To understand and measure how users use our Platform to improve it and report relevant aggregated management information | Performance of contract, Legitimate Interest |
| Product Referrals | Identity, Contact, Financial, Open Banking | To allow mySolPay™ to refer to you, and for you to access, third party products and services | Performance of contract, Consent |
| Surveys | Identity, Contact, Profile | To improve our service | Legitimate interest |
| Research and Statistics | Identity, Contact, Profile, Employer, Financial, Open Banking, Transaction, Behavioural, Technical and Other Personal Data | We use a range of rigorous scientific methods to understand our users better and how to support them which also serves to further a general public interest. | Legitimate Interest |
| Service Improvement and Development | Identity, Contact, Profile, Employer, Financial, Open Banking, Transaction, Behavioural, Technical and Other Personal Data | To improve our existing mySolPay™ services and develop ancillary services where we think these would be of interest to our users. | Legitimate Interest |
Sharing your Personal Data
We may share this information with:
- Your employer(s). Engaged with mySolPay™ to provide the Platform and mySolPay™ services. We share your Personal Data with your employer(s) to provide them and you with such Platform and services.
- Members of our group of companies. For the provision of customer services support.
- Partners. Where partners provide elements of our, or ancillary, services.
- Service providers. For the provision of IT and system administration services, email service providers, customer services and other support services which allow us to run the business.
- Professional advisers. For the provision of consultancy, banking, legal, insurance, accounting, and similar services.
- HM Revenue & Customs, regulators and other authorities acting as processors who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Notice.
- We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
Marketing
We strive to provide you with preferences in Personal Data uses, predominantly around marketing and advertising.
Third-party marketing
We will get your prompt opt-in consent before we share your Personal Data with any third party for marketing functions.
Opting out
You can opt out of our marketing communications at any time by logging onto the mySolPay™ App or website by changing your preferences. Alternatively, by following the unsubscribe links in any of our marketing emails sent to you or by contacting us at any time using the contact details shown in “Who We Are and How to Contact Us” above.
Where you opt out of receiving these marketing communications, this will not apply to transactional or service messages. Please allow two working days for instruction to take effect in all our systems.Cookies
You can set your browser to deny all or some browser cookies, or to alert you when websites set or access cookies. If you disable or decline cookies, please take note of that some parts of the Platform may become inaccessible or may not function properly. Please click here for our Cookies Notice.
Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:
(a) Your consent. You are able to remove your consent at any time. You can do this by contacting compliance@mysolpay.com
(b) We have a contractual obligation.
(c) We have a legal obligation.
(d) We have a vital interest.
(e) We need it to perform a public task.
(f) We have a legitimate interest.
How we store your personal information and keep it secure
Your information is securely stored by ensuring appropriate security measures are in place to prevent accidental loss, unauthorised access including alteration or disclosure. The following measures include:
- Data Encryption
- Security Firewalls
- Intrusion Detection Systems
- Background checks for all employees accessing physical facilities.
We have implemented process and procedures to manage any actual or suspected Personal Data breach. In the event of any such breach, our systems are in place to work with applicable regulators. In addition, in certain circumstances (e.g. where 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 by contacting compliance@mysolpay.com
How long we keep your Personal Data
We only retain your Personal Data for as long as we reasonably require to use it for the purposes set out above in “How we use your Personal Data.” section of this document, unless a longer retention period is required by law (for example for regulatory purposes).
We will store your information for as long as you’re using mySolPay™ and for five years after that to comply with legal obligations. In some circumstances, like cases of anti-money laundering or fraud, we may keep data longer if we need to and/or legal requirements state we need to.
Information related with website visits and marketing activities are typically stored for three years.
Your data protection rights
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at compliance@mysolpay.com if you wish to make a request.
How to raise a complaint?
If you would like to raise a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at: compliance@mysolpay.com
We aim to respond with 48 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 a complaint is submitted, we both must first endeavour to resolve the issue directly between us. However, if you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact our lead supervisory data protection supervisory authority, which for the UK and Ireland is the Information Commissioner’s Office.
How to contact us?
You can contact us with any questions, comments and requests regarding this privacy policy or your personal data by emailing: compliance@mysolpay.com