Privacy and Cookie Policy

  1. Introduction
  2. Data Controller
  3. What personal information is collected?
  4. How the personal information is used
  5. Disclosures of personal information
  6. Data retention and storage of personal information
  7. Communications
  8. Cookies
  9. Your rights
  10. Access to information
  11. Updates and changes to Privacy Policy
  12. Contact details
  1. Introduction
    1. easyMoney is the trading name of E-Money Capital Ltd, a company incorporated in England and Wales with company number 04861007 whose registered office is: 5 Fleet Place, London, EC4M 7RD. We are committed to protecting and respecting your privacy.
    2. This privacy policy explains how we collect, use, share, processes and store your personal information. Please read this privacy policy carefully, data that we collect from you will always be in accordance with the European General Data Protection Regulation (“GDPR”).
    3. References in the Privacy Policy to “we”, “us” and “our” refer to E-Money Capital Ltd. References to “systems”, or “platform” means any online services provided by us and any data collected, managed and stored from you by us. References to “you”, “your” and “Customer” mean a registered user of the platform and the services provided via our website, whether as an individual or on behalf of an entity which meets the “Customer” criteria set out in the Privacy Policy and Lender Terms and Conditions.
    4. This Privacy Policy is to be read alongside the Lender Terms and Conditions. Together it explains what personal and non-personal information we collect, how we use this as data and how the data is securely stored and processed.
    5. The personal information we collect from you is used solely for the purposes of providing our services to you. We do not sell or share your personal information with any corporate entity or persons except where stated in this policy, or without your prior consent.
    6. Please read the document carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.easymoney.com you are accepting and consenting to the practices described in this policy.
  2. Data Controller
    1. For the purpose of the General Data Protection Regulation (“GDPR”) the data controller for this Privacy Policy is E-Money Capital Ltd. We are registered with the Information Commissioner’s Office (“ICO”) with registration number ZA163842.
    2. In accordance with the Privacy Policy E-Money Capital Ltd has appointed a data protection officer who can be contacted in the following way:
      Email: support@easymoney.com Post : easyMoney, 6th Floor, 52 Grosvenor Gardens, London, SW1W 0AU Telephone: +44 (0) 203 858 7269
  3. What personal information is collected?
    1. When you register as a user of the platform, you will be required to provide a valid e-mail address, full name and password.
    2. As part of the account sign-up process, and in line with identity checks you will also be required to provide your date of birth, phone number, full address and (if applicable) your National Insurance Number.
    3. In compliance with financial regulations and Anti-Money Laundering regulations (AML) we require your nominated personal bank account details and identification documents such as passport, driving licence and/or ID Card.
    4. Should you establish contact with us via telephone, online chat, in writing or via a contact form from the website you may be required to provide some or all of the details set out in 3.1-3.3.
    5. When visiting the website we may automatically collect the following information:
      1. Technical information, including the Internet Protocol (“IP”) address used to connect your computer to the internet, your login information browser type and version, internet service provider (“ISP”), time zone setting, browser plug-in types and versions, operating system and platform, referral source and length of visit;
      2. Information about your visit, including the full Uniform Resource Locators ("URL") clickstream to, through and from our site (including date and time); loan requests you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
    6. We may receive information from other sources. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
    7. We may also collect, store and process information regarding your mobile device or tablet and your visits to the app. This includes, but is not limited to, your Internet Service Provider (ISP), operating system, referral source, length of visit and hardware version information.
  4. How the personal information is used
    1. In addition to identity checks and security we may also use your personal information for the following purposes:
      1. To carry out our obligations in the Lender Terms and Conditions and to provide you with the information and services that you request from us;
      2. To improve our site to ensure that content is presented in the most effective manner for you and your computer;
      3. Updates to your experience of the platform, including removing or adding additional criteria;
      4. To issue you with promotional and marketing communications targeted at your interests. This includes information about other services we offer that are similar to those that you have previously enquired about. You have the choice to opt in and out of this facility as you require;
      5. To provide you with welcome e-mails with information you need to get started, legal information about borrowing and lending, alerts about your investments and updates on the progress of loans;
      6. To administer our site and for internal operations including troubleshooting, data analysis, testing and research. It will also assist us in dealing effectively with customer feedback, enquiries, complaints and requests directly from the customer or from service providers regarding customers;
      7. Providing statistical or transactional data regarding users to third parties or regulators. This will be anonymised except where requested from regulators;
      8. Anonymised transaction data published publicly regarding transactions and trades.
  5. Disclosures of personal information
    1. We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
    2. We may share your information with selected third parties such as business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
    3. We may disclose your personal information to third parties in the following events:
      1. If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
      2. If E-Money Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets
      3. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions; or to protect the rights, property, or safety of E-Money Ltd, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
      4. We may need to share your information with other lenders or borrowers if necessary to enforce a loan contract;
      5. To assist law enforcement or any other crime prevention or taxation authorities and regulators.
    4. We will not disclose your personal information to any third party other than those set out in 5.2-5.3, other than a regulator, government or other judicial or governing body or a service provider to enable continued compliant services or updates to services.
    5. In accordance with our Terms and Conditions, we also use third party software to carry out our identity and AML checks. In some instances we may require further information from you to complete these checks.
  6. Data retention and storage of personal information
    1. The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
    2. All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
    3. We will only retain personal information that is collected from you for as long as necessary in order to fulfil and facilitate the purposes for which it was collected. This includes for satisfying our legal requirements, accounting and reporting duties and to aid in resolving disputes.
    4. We will not store or retain ID documents or use them for any other purpose than identifying you. Copies of these documents will be disposed of securely within 72 hours.
    5. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our App; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
    6. On receipt of your personal information we will ensure that our rigorous security and risk controls protect your personal data and will use all reasonable restrictions to prevent unauthorised access.
  7. Communication
    1. We will contact you by electronic means, which will be via e-mail, in writing or by SMS (“Short Messaging Service” ie. Text message). We may contact you regarding our services, including updates and with any direct marketing in accordance with your preferences where you have offered consent.
  8. Cookies
    1. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
    2. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse our site, you agree to our use of cookies.
    3. We use the following cookies:
      1. Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
      2. Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
      3. Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
      4. Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website more relevant to your interests. We may also share this information with third parties for this purpose.
      You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

      COOKIE

      NAME

      PURPOSE

      MORE INFORMATION

      Device

      Device

      Store device UUID which allows you to restrict account access to particular devices.

      Expires after 365 days.

      Affiliate

      Affiliate

      Stores ID of referring affiliate.

      Expires after 365 days.

      View-preference

      View-preference

      Stores view preference for data collections.

      Does not expire.

      easySession

      Session

      Identifies current session.

      Expires after session.

      referCode

      Refer a friend cookie

      Stores refer code for referrals.

      Expires after 30 days.

      intercom-session

      Intercom session cookie

      Stores session cookie for our CRM, Intercom.

      Expires after 7 days.

      AWSALB

      Load balancer cookie

      Allows sticky sessions on our load balancer.

      Expires after 7 days.

      _ga

      Google Analytics cookie

      Used to distinguish users.

      2 years

      _gid

      Google Analytics cookie

      Used to distinguish users.

      24 hours

    4. Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
    5. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
    6. Except for essential cookies, all cookies will expire after the periods set out in the table above.
  9. Your rights
    1. You have the right to withdraw your consent to the processing of your personal information collected via your consent at any time. This will not retrospectively affect the legality of collecting this data from your prior consent.
    2. You have the right to request the erasure or deletion of your personal information provided:
      1. It is no longer necessary for us to use this data to fulfil our responsibilities;
      2. Was collected on the bases you provided prior consent that you have now withdrawn, as per 9.1;
      3. You believe the collected data is not necessary and this is legally found to be the case.
    3. You have the right to restrict the processing of your data provided:
      1. You believe the information we hold is inaccurate and during our investigation this is proven to be accurate from our verification process;
      2. Where data is to be erased you propose to apply a restriction instead;
      3. Where we have declared we will erase data you have requested to restrict the data for the duration of the purposes you need to facilitate legal or defense claims.
    4. Under GDPR regulations you have the right to control your marketing preferences. You will therefore be required to opt-in to marketing updates rather than opt-out. You can change your preferences at your own leisure.
    5. Our website may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that they will have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data via their website.
  10. Access to information
    1. The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access requests may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
  11. Updates and changes to Privacy Policy
    1. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by your nominated e-mail address. Please check back frequently to see any updates or changes to our privacy policy.
  12. Contact details
    1. If you have any questions about these Terms and Conditions, or wish to contact us for any other reason, you can contact us on contactus@easymoney.com or 0203 858 7269.
    2. If you wish to complain about the service we provide, you should contact us on 0203 858 0785, email us at complaints@easymoney.com, or write to us at 52 Grosvenor Gardens, London, SW1W 0AU. A copy of our Complaints Handling Procedures is available on request.

Last updated: 10/10/2018