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 the contents, please email us at privacy@audapio.com.

This Privacy Policy aims to clearly set out the information we collect from Audapio users, what we do with that information, how we securely protect that information and the choices Audapio users have to erase or amend that information.

Important information and who we are

Audapio Ltd is the controller and is responsible for your personal data (collectively referred to as “we”, “us” or “our” in this policy). We are registered as a data controller under registration number ZA678773 with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

  • Full name of legal entity: Audapio Ltd
  • Name of DPO: Dudley Gould
  • Email address: dudley@audapio.com
  • Postal address: 16 Gallery Apartments, 6 Lamb Walk, London SE1 3GL, 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.

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).

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these 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 these policies before you submit any personal data to these websites or use these services.

The data we collect about you

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

  • Identity Data
  • Contact Data
  • Financial Data
  • Transaction Data
  • Device Data
  • Content Data
  • Profile Data
  • Usage Data
  • Marketing and Communications Data
  • Location Data

We explain these categories of data below (“Description of categories of personal data”).

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 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 will collect and process the following data about you:

  • Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the Web App or our Website, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the Web App, subscribe to any of our Services, and when you report a problem with our Web App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.

  • Information we collect about you and your device. Each time you visit one of Our Sites or use our Web Apps 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.

  • Location Data. We also use GPS technology and WiFi to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.

  • 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 such as Google based outside the EU;

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

  • Identity and Contact Data from Identity Providers based inside the EU; and

  • Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

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 any of Our Sites and also allows us to improve the Web App and Our Sites. 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 you have consented before the processing.
  • Where we need to perform a contract we are about to enter or have entered with you.
  • 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.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

Purpose / ActivityType of dataLawful basis for processing
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 Transaction Device Marketing and Communications LocationYour consent Performance of a contract with you
To share income and expenditure analytics with financial services organisationsIdentity Contact Financial Company TransactionYour consent
To manage our relationship with you including notifying you of changes to the Web App or any ServicesIdentity Contact Financial Company Profile Marketing and CommunicationsYour consent Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
Storing and using Transaction and Financial Data to develop and improve our AI models and algorithmsFinancial Company Transaction Location DeviceNecessary 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)
To administer and protect our business and this Web App including troubleshooting, data analysis and system testingIdentity Contact DeviceNecessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the Web AppIdentity Contact Device Content Profile Usage Marketing and Communications LocationConsent Necessary for our legitimate interests (to develop our products/Services and grow our business)

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share 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”):

  • External Third Parties such as your accountants and/or external auditors.
  • Financial services organisations in the UK acting as processors.
  • 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 transfer your personal data outside the European Economic Area (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 Sites, 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.

In some circumstances you can ask us to delete your data by emailing privacy@audapio.com: see “Your legal rights” below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research, development or statistical purposes, in which case we may use this information indefinitely without further notice to you.

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:

  • Request access to your personal data
  • Request correction of your personal data
  • Request erasure of your personal data
  • Object to processing of your personal data
  • Request restriction of processing your personal data
  • Request transfer or your personal data
  • Right to withdraw consent

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at privacy@audapio.com.

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

Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.