1.  Scope

 

This privacy policy sets out how Sphere Partners uses and protects any information that you give Sphere Partners when you use this website.

 

Sphere Partners is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you will be assured that it will only be used in accordance with this privacy statement.

 

Sphere Partners may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from May 2022.

 

1. Data we collect from you

 

We collect different types of personal data that you may provide us with, including when you:

• fill in any forms

• correspond with us

• register to use the Sphere app

• open an account or use any of our services

• take part in online discussions, surveys or promotions

• speak with a member of our customer support team

• contact us for other reasons

 

We will collect the following personal data

• Name, address, and date of birth

• Contact information such as, email addresses and telephone numbers

• Job Title

• Details of your bank account, including the account number, sort code and IBAN

• Details of your Sphere debit cards, including the card number, expiry date and CVC (the last three digits of the number on the back of the card)

• Identification documents (for example, your passport or driving licence)

• Records of our discussions (including telephone recordings)

• Your image where you are required to upload your photo as part of our Know Your Customer (KYC) process

 

Information from your device

When you use our website, we will collect:

 

• technical information, including the Internet protocol (IP) address used to connect your computer or device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

• information about your visit, including the links you have clicked on, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling and clicks), and methods used to browse away from the page;

• information on transactions (for example, payments into and out of your account), including the date, time, amount, currencies, exchange rate, beneficiary details, details of the merchant or ATM’s associated with the transaction (including merchants’ and ATMs’ locations), IPS address of sender and receiver, sender’s and receiver’s name and registration information, messages sent or received with the payment, details of device used to arrange the payment and the payment method used;

• telephone log information, such as your phone number, calling-party number, forwarding numbers, time and date of calls, duration of calls, SMS routing information and types of calls, any phone number used to call us and the content of those calls;

• information about where you are located which is provided through our technology by using details like your IP address or GPS sensors;

 

Information from others

We collect personal data from third parties, such as credit-reference agencies, financial or credit institutions, official registers and databases, as well as fraud-prevention agencies and partners who help us to provide our services.

 

This includes your credit record, information about late payments, information to help us check your identity, and information relating to your transactions.

 

Information from social media

Occasionally, we will use publicly available information about you from selected social media websites or apps to carry out enhanced due diligence checks. Publicly available information from social media websites or apps may also be provided to us when we conduct general searches on you (for example, to comply with our anti-money laundering or sanctions screening obligations).

 

Information from publicly available sources

We collect information and contact details from publicly available sources, such as media stories, online registers or directories, and websites for enhanced due diligence checks, security searches, and KYC purposes for Sphere Partners Business customers.

 

Sphere Partners Limited Business Customers

If you are a Sphere Partners Business customer, we will need to confirm your identity as part of our KYC process. We will ask you to provide documents, and will also collect information from third parties, such as commercial registers, for this purpose.

 

1. How we use your information and what is the lawful basis

 

We must have a valid reason for using your personal data. Our legal basis will be one of the following:

 

Keeping to our contracts and agreements with you

We need certain personal data to provide our services and cannot provide them without this personal data.

 

 

 

To administer our business

Including troubleshooting, fraud detection, data analysis, testing, research, marketing, statistical and survey purposes, to identify and assist you if you are a vulnerable customer, and to keep our business, websites, the App, bank accounts and our systems safe and secure.

 

Legal obligations

To ensure that we comply with the law and regulations, for regulatory purposes generally as well as to help detect or prevent fraud or other crimes, and for tax, legal, reporting and auditing obligations.

 

Legitimate interests

We sometimes collect and use your personal data, or share it with other organisations, because we have a legitimate reason to use it and this is reasonable when balanced against your right to privacy.

 

Consent

Where you've agreed to us collecting your personal data, for example when you have ticked a box to indicate you are happy for us to use your personal data in a certain way.

 

Substantial public interest

Where we process your sensitive personal data (sometimes known as special category personal data) to adhere to government regulations or guidance, such as our obligation to support you if you are or become a vulnerable customer.

 

1. How we use your personal data

 

We use your information in order to carry out our operation as an e-money provider, and provide financial products and services, to make sure we do not breach any contracts, to keep Sphere and you secure, to give people information about products and services and to comply with the law.

 

Providing our services

Whenever you apply for a product or service, we will use your personal data to check your identity (as part of our KYC process) and decide whether or not to approve your application.

 

If you are already a Sphere customer, we use your personal data to meet our obligations relating to any transactions you make (for example, making payments into and out of your Sphere account, withdrawing cash or making payments with your Sphere Card). If you ask us to exchange the currency of the e-money or you hold in your Sphere account, we'll use your personal data to help us do that.

 

We use your personal data to give you details of our products and services and to help us develop new products and services.

 

We use your personal data to contact you by phone and provide you with information about our products or services, as well as customer support services. We may monitor or record any communications between you and us, including phone calls, to maintain appropriate records, check your instructions, analyse, assess and improve our services, and for training and quality control purposes.

 

Protecting against fraud

We use your personal data to check your identity to protect against fraud, keep to financial-crime laws and to confirm that you are eligible to use our services. We also use it to help us better understand your financial circumstances and manage fraud risks related to your Sphere account.

 

Marketing and providing new products and services that might interest you

We use your personal data to do the following:

• provide you with information about other products and services we offer that are similar to those you have already used (or asked about, where allowed by law);

• provide you with information about our products or services which we think you might be interested in.

• measure or understand the effectiveness of our marketing and advertising, and provide relevant advertising to you;

• ask your opinion about our products or services;

• process applications for products and services available through us, and make decisions about whether to approve applications.

 

To keep our services up and running

We use your personal data to manage our website and the Sphere app, (including troubleshooting, data analysis, testing, research, statistical and survey purposes), and to make sure that content from our website is presented in the most effective way for you and your device.

 

We also use your personal data to allow you to take part in interactive features of our services, to tell you about changes to our services, and to help keep our website and the Sphere app safe and secure.

 

Helping with social interactions

We use your personal data to help social interactions through our services or to add extra functions in order to provide a better experience.

 

Providing location-based services

We use your personal data to provide relevant advertising to you (for example, information on nearby merchants), to protect against fraud, and to let you know when any of your contacts who are Sphere customers are in the same area as you (if they have location services switched on).

 

Meeting our legal obligations, enforcing our rights and other legal uses

We may need to share personal data about you:

• with other organisations (for example, fraud-prevention agencies);

• if this is necessary to meet our legal obligations or in connection with legal claims; or

• to help detect or prevent crime.

 

1. Who do we share your information with?

Sometimes we share your information with our affiliates, with those we do business with, with credit reference and fraud prevention agencies, with law enforcement bodies and regulators or if the information is aggregated (and so cannot identify you specifically).

 

1. Keeping your data secure

We generally process your information through servers in the UK and EEA and normally store it for six years.

• We process your information and store it on servers managed by our hosting providers.

• We use technical and organizational measures to safeguard your Data, for example

  • Access to your account is controlled by a password and a username that is unique to you.

  • we store your Data on secure servers

  • payment details are encrypted using SSL technology in your browser when we use this technology

• if you are outside the UK and EEA and make payments or send messages, or you are in the UK and EEA and make payments or send messages outside the UK and EEA, we may process payments through other institutions and payment systems. They may have to process and store information about you in connection with their own regulations; please note that the standards to which they adhere may not be as stringent as those in the UK and EEA.

• Unfortunately, the transmission of your information via the Internet can never be 100% secure. Although we will do our best to protect your information, we cannot guarantee the security of information about you transmitted to us and so 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.

1. Your rights

You have the right to be told about how we use your personal data.

• We provide this privacy policy to explain how we use your personal data.

• If you ask, we will provide a copy of the personal data we hold about you. We can’t give you any personal data about other people, personal data which is linked to an ongoing criminal or fraud investigation, or personal data which is linked to settlement negotiations with you. We also won't provide you with any communication we've had with our legal advisers.

 

You can ask us to correct your personal data if you think it's wrong.

• You can have incomplete or inaccurate personal data corrected. Before we update your file, we may need to check the accuracy of the new personal data you have provided.

 

You can ask us to delete your personal data.

 

You can ask us to delete your personal data if:

• there's no good reason for us to continue using it;

• you gave us consent (permission) to use your personal data and you have now withdrawn that consent;

• you have objected to us using your personal data;

• we have used your personal data unlawfully; or

• the law requires us to delete your personal data.

 

Just to let you know, we may not be able to agree to your request. As a regulated financial services provider, we must keep certain customer personal data even where you ask us to delete it (we've explained this in more detail below). If you've closed your Sphere account, we may not be able to delete your entire file because these regulatory responsibilities take priority. We will always let you know if we can't delete your personal data.

 

You can object to us processing your personal data for marketing purposes.

• You can tell us to stop using your personal data for marketing.

 

You can object to us processing other personal data (if we are using it for legitimate interests).

• If our legal basis for using your personal data is 'legitimate interests' and you disagree with us using it, you can object.

• However, if there is an overriding reason why we need to use your personal data, we will not accept your request.

• If you object to us using personal data which we need in order to provide our services, we may need to close your account as we won’t be able to provide the services.

 

You can ask us to restrict how we use your personal data.

 

You can ask us to suspend using your personal data if:

• you want us to investigate whether it is accurate;

• our use of your personal data is unlawful but you do not want us to delete it;

• we no longer need your personal data, but you want us to continue holding it for you in connection with a legal claim; or

• you have objected to us using your personal data (see above), but we need to check whether we have an overriding reason to use it.

 

You can ask us to transfer personal data to you or another company.

• If we can, and are allowed to do so under regulatory requirements, we will provide your personal data in a structured, commonly used, machine-readable format.

 

You can ask us to carry out a human review of an automated decision we make about you.

• If we make an automated decision about you that significantly affects you, you can ask us to carry out a manual review of this decision.

 

Your ability to exercise these rights will depend on a number of factors. Sometimes, we will not be able to agree to your request (for example, if we have a legitimate reason for not doing so or the right does not apply to the particular information we hold about you).

 

 

1. How we use cookies

 

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

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