Introduction
Your privacy is important to us. This Online Privacy Policy explains how we collect, share, use and
protect your personal information when you visit or use this and other online services offered by Xyrra
(Xyrra Ltd of 3 Waterhouse Square, 138-142 Holborn, London, EC1N 2SW) that link to or reference this
policy (collectively, our “online services”). Please note, however, that this Online Privacy Policy is
not an exclusive statement of our privacy principles across all products and services. Other privacy
principles or policies may apply depending on the financial products or services you obtain from us, or
the jurisdiction in which we are doing business with you. You can access many of these policies using
the links at the bottom of this page.
We protect your information. We take our responsibility to protect the privacy and
confidentiality of your information, including personal information, very seriously. We maintain
physical, electronic and procedural safeguards that comply with applicable legal standards to secure such
information from unauthorised access and use, alteration and destruction.
Information We Collect and Why
The types of personal information we may collect from you when you visit or use our online services
include: Identity Data such as your name, date of birth, email and address. Contact Data such as email
address, mailing address, telephone number(s). We may also collect your email and name details for our
newsletter forms, competitions or promotions.
In addition to the personal information described above, we may collect certain information about your
use of our online services. For example, we may capture the IP address of the device you use to connect
to the online service, the type of operating system and browser you use, and information about the site
you came from, the parts of our online service you access, and the site you visit next. We may also
collect information about you from additional online and offline sources including commercially
available third-party sources, such as credit reference agencies. We also collect marketing and
communications data such as your preferences in receiving marketing from us and your communication
preferences (which we may collect directly from you). We may also use cookies to collect information
about you. This helps us to provide you with a good experience while using our website and our App.
How we may use information. We may use the information we collect from you to help us
deliver our online services; to administer, evaluate and improve our business (including developing new
products and services, improving existing products and services, performing data analytics, and
performing accounting, auditing and other internal functions); manage our risks; market our services and
products; and to comply with and enforce applicable laws and regulations, relevant industry standards,
contractual obligations and our policies. We may also use data that we collect on an aggregate or
anonymous basis (such that it does not identify any individual clients) for various business purposes,
where permissible under applicable laws and regulations.
How Your Personal Information Is Protected
For your convenience, Xyrra offers you the ability to access some of our products and services through
mobile applications and mobile-optimised websites. When you interact with us through your mobile device,
we may collect information such as unique device identifiers, your screen resolution and other device
settings, information about your location, and analytical information about how you use your mobile
device. We may ask your permission before collecting certain information, such as precise geolocation
information. We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit
access to your personal data to those employees, agents, contractors and other third parties who have a
business need to know. They will only process your personal data on our instructions and are subject to
a duty of confidentiality. We have put in place procedures to deal with any suspected personal data
breach and will notify you and any applicable regulator of a breach where legally required to do so. Your
transactional data is encrypted at rest using disk-level encryption, as well as physically encrypting
the data using salted encryption keys. Data from our third-party banking provider is retrieved via their
SSL-encrypted API as background tasks on our servers. The process is inaccessible to users, and is
indirectly triggered by a task scheduler or the user performing an action from the web or mobile
application.
Disclosing your information
We do not share your information with third parties other than for providing our products or services to
you. We may share your information with the below selected third parties: analytics and search engine
providers that assist with optimisation of our services such as Google; and Facebook for our Single Sign
On and to analyse the App installs.
We require all third parties to respect the security of your personal data and to treat it in accordance
with the law. We do not allow our third-party service providers to use your personal data for their own
purposes and only permit them to process your personal data for specified purposes and in accordance
with our instructions. We provide you with relevant and appropriate choices regarding the sharing of
personal information. We may give you choices regarding the sharing of personal information with
affiliates and third parties. Choices you have about the sharing of your personal information will be
described in the privacy policies or notices you receive in connection with the financial products or
services you obtain from us.
Data from our third-party banking provider is retrieved via their SSL-encrypted API as background tasks
on our servers. The process is inaccessible to users, and is indirectly triggered by a task scheduler or
the user performing an action from the web or mobile application. We offer you the opportunity to access
and correct your information on file with us. Keeping your account information up-to-date is very
important. You may review or update certain account information by logging in and accessing the
“Profile” section. If you cannot change the incorrect information online, or you prefer to request
changes offline, please contact us using the contact information listed on your account statements,
records or other account materials.
Access to your personal data
You have the right to request access to your personal data. If you would like a copy of the information
held on you, please contact us (see details below)
Erasure of your personal data
You have the right to request erasure of your personal data. This enables you to ask us to delete or
remove personal data where there is no good reason for us continuing to process it. Note, however, that
we may not always be able to comply with your request of erasure for specific legal reasons which will be
notified to you, if applicable, at the time of your request.
Objection to processing of your personal data
You have the right to object to the processing of your personal data where we are relying on a
legitimate interest (or those of a third party) and there is something about your particular situation
which makes you want to object to processing on this ground as you feel it impacts on your fundamental
rights and freedoms.
Restriction of processing your personal data
You have the right to request restriction of processing of your personal data. This enables you to ask
us to suspend the processing of your personal data in the following scenarios: (a) if you want us to
establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase
it; (c) where you need us to hold the data even if we no longer require it as you need it to establish,
exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify
whether we have overriding legitimate grounds to use it.
Withdrawing consent to marketing
By submitting your personal information, you agree that Xyrra Ltd may use your information for
marketing purposes (including electronic marketing). Xyrra Ltd will not disclose your information to any
third party for marketing purposes, without your further consent. You have the right, at any time, to
ask us not to process your personal information for marketing purposes. You can do so by contacting us
(see below)
Changes to this policy
We may change this Online Privacy Policy from time to time. When we do, we will let you know by
appropriate means such as by posting the revised policy on this page with a new “Last Updated” date.
All changes will become effective when posted unless indicated otherwise.
