Privacy Policy

Privacy Policy

5th December 2023

Introduction

This is the Privacy Policy for “Direct Pay”. Direct Pay allows retailers to send payment requests to their customers, and for customers to make payments to retailers (which we refer to in this policy as our “service” or “services”).

Money Dashboard is owned and operated by IDN Group Limited. Our company number is SC791091. Our registered office is Summit House, 4-5 Mitchell Street, Edinburgh, EH6 7BD.

When we refer to our trading name “Direct Pay” or “we”, “us” or “our” in this policy, we are referring to IDN Group Limited. We are the data ‘controller’ in relation to the personal data you provide to us, which means we determine the purposes and the way in which your personal data is, or will be, processed.


Purpose of this privacy policy

This policy aims to give you information on how we collect and process any personal data we collect from you, or that you provide to us. We want you to be confident when you use our service that you know what your personal data is being used for, and that it is being kept safe.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

How to contact us

If there is anything you don’t understand or you’re not happy about, please get in touch with us by:

Emailing us at info@directpay.uk

If you have any concerns

You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner's Office. However, if you do have a complaint, we would appreciate the chance to deal with your concerns first, so please do contact us in the first instance.

How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your personal data by filling in forms or by corresponding with us in person, by email, by phone, by post or otherwise. This includes personal data you provide when registering to use our service.

  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see below on Cookies for further information.

  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.


Information Which We May Collect

  • We may collect and process the following information about you:

  • Registration Information: To register to use our service you will have to supply us with your name, email address, and contact telephone number. 

  • Unique user reference: This is a reference which we assign to you when you sign up to use our service, to create your own unique data record.

  • Technical Information: When you browse our website, we automatically collect some technical information about your visit to our website, including, but not limited to, information about the device you are using to access Direct Pay (for example, mobile device or web), your browser type and version and your browser plug-in types and version.

  • Customer Testimonials: This could include your name, social media handle and/or any testimonial, review or other comment on our products or services that you choose to provide to us.

How we use your information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you (i.e. when you sign up to our service). This includes billing you for our services, and contacting you about your account with us. 

  • Where we have your prior consent to use your personal data (for example, where you have consented to receiving marketing).

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

  • Where we need to comply with a legal or regulatory obligation.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Introduction

This is the Privacy Policy for “Direct Pay”. Direct Pay allows retailers to send payment requests to their customers, and for customers to make payments to retailers (which we refer to in this policy as our “service” or “services”).

Money Dashboard is owned and operated by IDN Group Limited. Our company number is SC791091. Our registered office is Summit House, 4-5 Mitchell Street, Edinburgh, EH6 7BD.

When we refer to our trading name “Direct Pay” or “we”, “us” or “our” in this policy, we are referring to IDN Group Limited. We are the data ‘controller’ in relation to the personal data you provide to us, which means we determine the purposes and the way in which your personal data is, or will be, processed.


Purpose of this privacy policy

This policy aims to give you information on how we collect and process any personal data we collect from you, or that you provide to us. We want you to be confident when you use our service that you know what your personal data is being used for, and that it is being kept safe.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

How to contact us

If there is anything you don’t understand or you’re not happy about, please get in touch with us by:

Emailing us at info@directpay.uk

If you have any concerns

You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner's Office. However, if you do have a complaint, we would appreciate the chance to deal with your concerns first, so please do contact us in the first instance.

How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your personal data by filling in forms or by corresponding with us in person, by email, by phone, by post or otherwise. This includes personal data you provide when registering to use our service.

  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see below on Cookies for further information.

  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.


Information Which We May Collect

  • We may collect and process the following information about you:

  • Registration Information: To register to use our service you will have to supply us with your name, email address, and contact telephone number. 

  • Unique user reference: This is a reference which we assign to you when you sign up to use our service, to create your own unique data record.

  • Technical Information: When you browse our website, we automatically collect some technical information about your visit to our website, including, but not limited to, information about the device you are using to access Direct Pay (for example, mobile device or web), your browser type and version and your browser plug-in types and version.

  • Customer Testimonials: This could include your name, social media handle and/or any testimonial, review or other comment on our products or services that you choose to provide to us.

How we use your information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you (i.e. when you sign up to our service). This includes billing you for our services, and contacting you about your account with us. 

  • Where we have your prior consent to use your personal data (for example, where you have consented to receiving marketing).

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

  • Where we need to comply with a legal or regulatory obligation.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Introduction

This is the Privacy Policy for “Direct Pay”. Direct Pay allows retailers to send payment requests to their customers, and for customers to make payments to retailers (which we refer to in this policy as our “service” or “services”).

Money Dashboard is owned and operated by IDN Group Limited. Our company number is SC791091. Our registered office is Summit House, 4-5 Mitchell Street, Edinburgh, EH6 7BD.

When we refer to our trading name “Direct Pay” or “we”, “us” or “our” in this policy, we are referring to IDN Group Limited. We are the data ‘controller’ in relation to the personal data you provide to us, which means we determine the purposes and the way in which your personal data is, or will be, processed.

Purpose of this privacy policy

This policy aims to give you information on how we collect and process any personal data we collect from you, or that you provide to us. We want you to be confident when you use our service that you know what your personal data is being used for, and that it is being kept safe.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

How to contact us

If there is anything you don’t understand or you’re not happy about, please get in touch with us by:

Emailing us at info@directpay.uk

If you have any concerns

You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner's Office. However, if you do have a complaint, we would appreciate the chance to deal with your concerns first, so please do contact us in the first instance.

How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your personal data by filling in forms or by corresponding with us in person, by email, by phone, by post or otherwise. This includes personal data you provide when registering to use our service.

  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see below on Cookies for further information.

  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.


Information Which We May Collect
  • We may collect and process the following information about you:

  • Registration Information: To register to use our service you will have to supply us with your name, email address, and contact telephone number. 

  • Unique user reference: This is a reference which we assign to you when you sign up to use our service, to create your own unique data record.

  • Technical Information: When you browse our website, we automatically collect some technical information about your visit to our website, including, but not limited to, information about the device you are using to access Direct Pay (for example, mobile device or web), your browser type and version and your browser plug-in types and version.

  • Customer Testimonials: This could include your name, social media handle and/or any testimonial, review or other comment on our products or services that you choose to provide to us.

How we use your information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you (i.e. when you sign up to our service). This includes billing you for our services, and contacting you about your account with us. 

  • Where we have your prior consent to use your personal data (for example, where you have consented to receiving marketing).

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

  • Where we need to comply with a legal or regulatory obligation.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose / activity

Purpose / activity

Our lawful basis for processing this data

Our lawful basis for processing this data

Type(s) of Data we use for this purpose

Type(s) of Data we use for this purpose

To register the business you are representing as a customer to our services

To register the business you are representing as a customer to our services

Performance of a Contract with the business you represent  (i.e. Contract)

Performance of a Contract with the business you represent 

Registration Information

Registration Information

To manage our relationship with the business you represent (including notifying you about changes to our service)

To manage our relationship with the business you represent

To manage our relationship with the business you represent

Contract; Legal obligation

Contract; Legal obligation

Email address

Email address

Requesting feedback on our product or services

Requesting feedback on our product or services

Consent

Consent

Email address

Email address

Posting customer testimonials and reviews on our website

Posting customer testimonials and reviews on our website

Registration Information

Registration Information

Customer Testimonials (we may contact you to ask if you are happy for us to include a testimonial).

Customer Testimonials (we may contact you to ask if you are happy for us to include a testimonial).

Registration To tell you about goods or services (marketing material) that we feel may be of interest to you

To tell you about services that we feel may be of interest to you

Consent

Consent

Email address

Email address

To create your personal data record, which we need to uniquely identify you

To create your personal data record, which we need to uniquely identify you

Contract

Contract

Unique User Reference

Unique User Reference

To provide user support and technical instructions regarding your account

To provide user support and technical instructions regarding your account

Contract

Contract

Registration information, unique user reference

Registration information, unique user reference

To monitor and improve our service

To monitor and improve our service

Legitimate interests (to track the use of our service and identify areas where we can improve service performance or service functionality.

Legitimate interests (to track the use of our service and identify areas where we can improve

Legitimate interests (to track the use of our service and identify areas where we can improve)

Registration information, Technical information,

Registration information, Technical information,

Use of necessary, functional and analytical cookies (see Cookies section for further information on specific purposes)

Use of necessary, functional and analytical cookies

Legitimate interests (in operating our website); Consent

Legitimate interests in operating our website)

Technical information

Technical information

To monitor usage to enable us to bill for our services

To monitor usage to enable us to bill for our services

Contract

Contract

Technical information

Technical information

You may unsubscribe from any marketing communication directly from any marketing email that you receive.


The information we may give to or share with somebody else

We may share your personal information in the following ways:

  • to companies that provide services to help us operate the application and communicate with users. These companies are authorised to use your personal information only as necessary to provide these services to us, and via contractual agreements that establish their responsibilities to protect your data;

  • to HMRC, regulators and other authorities or bodies who require reporting of processing activities in certain circumstances. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud;

  • to professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

  • if Direct Pay is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information;

  • to any other third party with your prior agreement to do so, where such agreement will be recorded by us, and retained in line with our data retention policy, and include the purpose, frequency and duration of the information sharing;

International transfers

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside of the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

  • In any other case, we will obtain your explicit consent before any transfer takes place.

Your rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

  • Access to your information

  • Request correction of your personal data

  • Request deletion of your personal data

  • Object to processing of your personal data

  • Request restriction of processing your personal data

  • Request transfer of your personal data

  • Right to withdraw consent

  • Right to review by an independent authority

If you wish to exercise any of the rights set out above, please contact us at info@directpay.uk. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We will respond to all legitimate requests within 30 days. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

How long we keep your data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will normally retain your information for a period of 90 days after your account is deactivated or 90 days after your information is no longer needed to provide you with our services. After this period, the data will be deleted from our systems and we will be unable to access it. In some circumstances you can ask us to delete your data sooner: see Deleting personal data above for further information. If you do wish to cancel your account or request that we no longer use your information to provide you services, please contact us at info@directpay.uk.

Cookies and Other Tracking Technologies

What are cookies?

A cookie is a text file containing a small amount of information that is sent to your browser when you visit a website. The cookie is then sent back to the originating website on each subsequent visit, or to another website that recognises it. Cookies are an extremely useful technology and do lots of different jobs.

We may collect information through the use of cookies.

What cookies do we use?

We have listed below all the cookies that we use. These fall into the following categories:

  • Essential 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.

  • Non essential cookies. These are not essential to the operation of our website, but help us to understand how people are using our product, and interacting with our website. 

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

You may unsubscribe from any marketing communication directly from any marketing email that you receive.


The information we may give to or share with somebody else

We may share your personal information in the following ways:

  • to companies that provide services to help us operate the application and communicate with users. These companies are authorised to use your personal information only as necessary to provide these services to us, and via contractual agreements that establish their responsibilities to protect your data;

  • to HMRC, regulators and other authorities or bodies who require reporting of processing activities in certain circumstances. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud;

  • to professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

  • if Direct Pay is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information;

  • to any other third party with your prior agreement to do so, where such agreement will be recorded by us, and retained in line with our data retention policy, and include the purpose, frequency and duration of the information sharing;

International transfers


Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside of the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

  • In any other case, we will obtain your explicit consent before any transfer takes place.

Your rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

  • Access to your information

  • Request correction of your personal data

  • Request deletion of your personal data

  • Object to processing of your personal data

  • Request restriction of processing your personal data

  • Request transfer of your personal data

  • Right to withdraw consent

  • Right to review by an independent authority

If you wish to exercise any of the rights set out above, please contact us at info@directpay.uk. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We will respond to all legitimate requests within 30 days. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

How long we keep your data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will normally retain your information for a period of 90 days after your account is deactivated or 90 days after your information is no longer needed to provide you with our services. After this period, the data will be deleted from our systems and we will be unable to access it. In some circumstances you can ask us to delete your data sooner: see Deleting personal data above for further information. If you do wish to cancel your account or request that we no longer use your information to provide you services, please contact us at info@directpay.uk.

Cookies and Other Tracking Technologies

What are cookies?

A cookie is a text file containing a small amount of information that is sent to your browser when you visit a website. The cookie is then sent back to the originating website on each subsequent visit, or to another website that recognises it. Cookies are an extremely useful technology and do lots of different jobs.

We may collect information through the use of cookies.

What cookies do we use?

We have listed below all the cookies that we use. These fall into the following categories:

  • Essential 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.

  • Non essential cookies. These are not essential to the operation of our website, but help us to understand how people are using our product, and interacting with our website. 

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Purpose / activity

Purpose / activity

Our lawful basis for processing this data

Our lawful basis for processing this data

Type(s) of Data we use for this purpose

Type(s) of Data we use for this purpose

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How do I change my cookie settings?

You 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.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.

How do I change my cookie settings?

You 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.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.

Made with love in Scotland 🏴󠁧󠁢󠁳󠁣󠁴󠁿

Direct Pay is a trading name of IDN Group Limited
Company Number (SC791091)
Summit House, 4 - 5 Mitchell Street,
Edinburgh, United Kingdom, EH6 7BD.