Audapio Privacy Policy

Introduction

Privacy and the security of data are of paramount importance to all of us at Audapio. Please read this document carefully, and if you have any questions or queries about its contents, please e-mail us at privacy@audapio.com.

This Privacy Policy aims to clearly set out the information we collect from Audapio users through this website (“Website”) and our online application (“Web App”), what we do with that information, how we securely protect that information and the rights granted to users concerning that information.

Important information and who we are

Audapio Ltd (collectively referred to as “we”, “us” or “our” in this policy) acts as a controller for any of your personal data which is collected or used via our Website and/or Web App. We are registered as a controller under registration number ZA678773 with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

If you access the Web App through an invitation triggered by an accountancy firm, that firm will be able to access personal data related to you which is made available on the Web App (including Identity Data, Contact Data, Financial Data and Transaction Data, as defined below). That firm will also act as a controller for any of your personal data which is collected or used via the Web App and which they use for their own client management purposes.

Contact details

Our full details are:

  • Full name of legal entity: Audapio Ltd
  • Email address: privacy@audapio.com
  • Postal address: Preston Park House, South Road, Brighton BN1 6SB, United Kingdom

You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance, at privacy@audapio.com.

Account Information Services

Truelayer is our Account Information Services provider. We use Truelayer to securely connect your accounts and credit cards to Audapio.

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 Audapio. 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.

Audapio is acting as an agent of TrueLayer, who is authorised by the FCA as an Authorised Payment Institution (reference number: 793171).

The Website and Web App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these third-party websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check the privacy policies of any third-party websites or services before you submit any personal data through them.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

Identity Data
  • Name
  • Date of birth
  • Gender
Contact Data
  • Address
  • E-mail address
  • Phone number
Financial DataBank account information:
  • Account type
  • Account name
  • IBAN/Account number/Sort code/SWIFT
  • Currency
Account balance information:
  • Current balance
  • Available balance (credit cards)
  • Interest rate
  • Payment due date (credit cards)
  • Next closing date (credit cards)
  • Minimum payment due (credit card)
Transactional DataFinancial transaction data:
  • Time
  • Description
  • Amount
  • Associated metadata
  • Any other relevant data shared by the open banking provider from time to time.
Device Data
  • IP address
  • Browser name
  • Device identifiers
Usage Data
  • Website pages visited
  • Time spent and actions performed on each Website page
  • Details on how you got to our Website (where available)
  • Links clicked on on our Website
  • Actions performed on the Web App

We also collect, use and share Aggregated Data such as statistical, demographic or transaction data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Web App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

How is your personal data collected?

We can collect personal data about Audapio users in the following ways:

  • Information shared with us by accountancy firms. An accountancy firm may ask us to send you an invitation to use the Web App, so that the firm can rely on our Web App to provide services to you more effectively. In this case, the firm will provide us with an e-mail address which we will use only to send you an invitation to start using the Web App.

  • Information you give us. You may decide to actively share personal data with us via the Web App or Website (for example, by registering to use the Web App or subscribing to any of our services), or by corresponding with us (for example, by reporting a problem with the Web App or the Website to us via e-mail or chat). If you contact us, we will keep a record of that correspondence.

  • Information we collect about you and your device. When you visit the Website or use the Web App, we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.

  • Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

  • Device Data from analytics providers;

  • Contact, Financial and Transaction Data from providers of technical, payment and banking services based inside the EU.

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the Web App and Website to remember your preferences. This helps us to provide you with a good experience when you use the Web App or browse the Website and also allows us to improve the Web App and Website. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

How we use your personal data

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

  • Where it is strictly necessary to use your personal data in order to provide our services to you, in accordance with the contract entered into by accepting our Terms and Conditions;
  • Where you have consented before the processing;
  • 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;
  • Where we need to comply with a legal or regulatory obligation.

We will only send you direct marketing communications by email if we have your consent. You have the right to withdraw that consent at any time by contacting us, at privacy@audapio.com.

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current, to ensure that it is used fairly and reduce the risk of harm being caused to you. Please keep us informed if your personal data changes during our relationship with you, by reaching out to us at: privacy@audapio.com.

Purposes for which we will use your personal data

We may use personal data which we collect on you, through the Website and/or Web App, for the following purposes:

Purpose / ActivityType of dataLawful basis for processingMandatory/optional
To provide you with the Services (categorised transactions, internal and external audit analysis) by linking your bank accounts and associated Transaction Data to the Web AppIdentity Contact Financial Company TransactionPerformance of a contract with youIt is contractually mandatory for you to share these data with us - otherwise, we will not be able to provide you with the services.
To share income and expenditure analytics with accountancy firms via the Web AppIdentity Contact Financial TransactionConsentIf you sign-up to use our Web App through an invitation made by an accountancy firm, these data will automatically be made visible to that firm on the Web App. You can avoid this by signing up autonomously to use the Web App instead (in which case, no data will be visible to any accountancy firms), or by withdrawing your consent (see below).
To manage our relationship with you including notifying you of changes to the Website, the Web App or any ServicesIdentity ContactPerformance of a contract with youIt is contractually mandatory for you to share these data with us – otherwise, we will not be able to correctly perform our contract with you.
Storing and using Transaction and Financial Data handled over the Web App to develop and improve our AI models and algorithms.Financial TransactionNecessary for our legitimate interests (to train and improve the accuracy of our AI models and analytics and to improve our categorisation of transactions, internal and external audit analysis)It is not mandatory for you to share these data with us - you can object to this activity (see below for more information).
To collect information on how you interact with our Website, such as the pages you visit and time spent on each page, in order to improve our Website and the services we offerDevice UsageConsentIt is optional for you to allow us to carry out this activity – you can do so by consenting to the use of analytics cookies on the Website.
To administer and protect our business and our Website and Web App, including troubleshooting, data analysis and system testingDevice UsageNecessary for our legitimate interests (for running our business, provision of administration and IT services, network security)It is mandatory for you to share these data with us, so that we can ensure the security of the Website and Web App.

Please note that, if you have been invited to use the Web App by an accountancy firm, that firm may also process personal data related to you via the Web App for their own purposes (typically, to provide financial services to you).

The firm which invited you to use the Web App is solely responsible for their own use of your personal data – please reach out to them directly if you have any specific questions on how they are handling your information.

As noted above, if you would prefer to use the Web App without sharing information with an accountancy firm, you should instead sign-up to the Web App autonomously. You can also contact us at privacy@audapio.com to request that your data stop being visible to the accountancy firm which invited you.

Disclosures of your personal data

We may share some or all of your personal data with the third parties set out below for the purposes set out in the table above (“Purposes for which we will use your personal data”):

  • Truelayer (our Account Information Services provider);
  • Accountancy firms (namely, the specific accountancy firm which invites you to use the Web App, if applicable);
  • Individuals or organisations which provide us with advice or consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters in connection with our services, the Website and/or the Web App;
  • Individuals or organisations which help us provide our services, such as Website/Web App developers, hosting providers and e-mail platform providers;
  • Individuals or organisations which carry out technical or Website/Web App maintenance for us;
  • Individuals which we authorise to process personal data in order to perform activities related to the provision of our services, such as our employees and contractors (who are subjected to legally binding confidentiality obligations);
  • Public entities, bodies or authorities, to the extent that we may be strictly required to share personal data with them due to the applicable law;
  • 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 policy.

International transfers

We do not autonomously transfer or host your personal data outside the European Economic Area (EEA).

In the event that you consent to the sharing of your personal data through the Platform with an Accountancy Firm located outside the EEA, this will result in a transfer of personal data to outside the EEA. Any such transfer will be based on your explicit consent, and will be further safeguarded by the implementation of Standard Contractual Clauses between Audapio and the Accountancy Firm.

Accountancy Firms located outside of the EEA which accept the Platform’s Terms and Conditions are deemed as having entered into a written agreement (as data importer) with Audapio (as data exporter) containing the Standard Contractual Clauses, as laid out by European Commission Decision no. 2004/915/EC of 27 December 2004 (as may be amended from time to time). The Standard Contractual Clauses will apply to all transfers of personal data occurring via the Platform, from Platform users located in the EEA to Accountancy Firms located outside of the EEA.

Data security

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Website/Web App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your device using application data caches and browser web storage (including HTML5) and other technology.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

For example, we may use your Financial, Transaction, Location and Device Data to train artificial intelligence models to improve our Services of internal and external audit analysis (for our legitimate interests). We will retain this personal data for as long as reasonably necessary for this purpose.

For further information on specific retention periods applicable to your personal data, please e-mail us at: privacy@audapio.com.

Minors

Our Services are not intended for use by anyone younger than 18 years old. Please do not use our Services if you are under 18.

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

Right of accessAs a rule you are entitled to:
  1. Ask us to confirm whether or not we process personal data related to you;
  2. Ask us for information about how we process personal data related to you (for example, what kinds of personal data we use, why we use them, how long we store them, etc.); and
  3. Receive a copy of the personal data related to you which we process.
Right to rectificationAs a rule, you are entitled to ask us to correct or complete any inaccurate or incomplete personal data we hold on you.
Right to erasure (“right to be forgotten”)Under certain circumstances, you are entitled to ask us to delete or anonymise personal data we hold on you.
Right to restriction of processingUnder certain circumstances, you are entitled to ask us to restrict the use of personal data we hold on you, for a limited period of time.
Right to data portabilityAs a rule, you are entitled to ask us for a copy of your personal data in a structured, commonly used and machine-readable format. You can then transfer that copy to any other controller at will.

You can also ask us to transfer these personal data to another controller for you, if this is technically feasible for us.

Right to objectYou are entitled to object to any use of your personal data which is based on the performance of a task in the public interest, or based on our own legitimate interests. These objections should be based on your particular situation/circumstances.

You are also entitled to object to any use of your personal data for marketing or associated purposes, for any reason.

Right to withdraw consentIf you have given us consent to use your personal data for a specific purpose, you are entitled to withdraw that consent at any time.

You can exercise any of these rights at any time by contacting us at privacy@audapio.com. Objecting to marketing purposes can also be done by clicking on the relevant “unsubscribe” (or similar) link provided at the end of each marketing communication.

As noted in our cookie policy, you can change your cookie preferences at any time clicking on the side-banner (on the bottom-left corner of the Website).

Changes to the privacy policy and your duty to inform us of changes

This version of our Privacy Policy entered into force on 22nd September 2020. We may change all or some of this Privacy Policy at any time. Any changes we make to our Privacy Policy in the future will be posted on this page. We will inform you of any changes by placing a temporary pop-up banner on our Website, and by notifying users by e-mail. All changes will become binding as soon as they are published on the Website.