Portify Privacy Policy

We at Portify care about your privacy. We collect and process personal information with your privacy in mind.

This policy describes how we collect and use your personal data when you use our services, and become a Portify user. It also outlines your rights and how to exercise them.

It is important that you read this policy before starting to use our services.

Scope of policy

This policy (together with our terms and conditions as set out here (T&Cs), together our Terms of Use) applies to your use of:

  • The Portify mobile application software (a copy of which you may download to your mobile telephone or handheld device (Device)) and, if We make a web application available, the web application software available on www.portify.co (our Site), (both mobile and web versions of the application being referred to as the App);
  • The service accessible through the App (Service).

This policy sets out the basis on which any personal data We collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

For the purpose of the Data Protection Act 1998,

Information we collect from you

We will collect and process the following data about you:

  • Information you give us (Submitted information): This is information you give us about you by filling in forms on the App or our Site, or by corresponding with us (for example, by e-mail or chat). It includes information you provide when you register to use the App, download or register the App, use our Service, share data via an App's social media functions, or enter a competition, promotion or survey and when you report a problem with an App, our Service, or our Site. If you contact us, We will keep a record of that correspondence. The information you give us will comprise your name, e-mail address and phone number, the Device's phone number, username, password and other registration information;
  • Information We collect about you and your device. Each time you visit one of our Sites or use one of our Apps We will automatically collect the following information:
    • technical information, including the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting (Device Information);
    • details of your use of the App or your visits to our Site including, but not limited to traffic data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access;
  • Information We receive from other sources (Third Party Information). We work with Salt Edge Inc who will, [once you tick the appropriate boxes to allow them to do so,] access your bank accounts using approved APIs. We will then query and copy that data onto our own secure databases. We also work closely with our service delivery partners (which may include, for example, sub-contractors in technical and payment services and analytics providers).

How we use your information

We use the personal data held about you in the following ways:

  • to register you as a user of the App or our Service, for correspondence, participating in online surveys and competitions, to help us enhance the App and our Service for you;
  • to allow us to ask security-related questions if you later ask us to reset your password;
  • for the purposes of analysing the data and suggesting products or services that may enable you to make savings or consider alternative or additional services to the ones you are currently using;
  • to allow us to customise your experience of the App and our Service and enable us to present your own information to you in a way that We believe is most useful for you (including identifying which transactions are, or are likely to be, work related);
  • to assist us in the preparation and filing of tax returns with HMRC, if you should request such a service (further terms are likely to apply); and
  • in anonymised form to allow us to analyse our users’ behaviour as a whole and produce statistics accordingly for use at our discretion, which may include licensing to, or sharing with, third parties).

We do not disclose information about identifiable individuals to our advertisers or third parties other than as expressly envisaged in the Terms of Use but We may provide them with anonymous aggregate information about our users (for example, We may inform them that 100 women aged over 40 have clicked on their advertisement on any given day or the fact that a specific age group tends to have more direct debits on their account than another age group). We may use the personal data We have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.

Disclosure of your information

You agree that We have the right to disclose your personal information to any member of our group from time to time, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

As well as disclosure as specified elsewhere within this Privacy Policy, We will disclose your personal information to third parties:

  • In the event that We sell or buy any business or assets, in which case We will disclose your personal data to the prospective seller or buyer of such business or assets.
  • If Portify or substantially all of Portify's assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If We are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
  • In order to:
  • enforce or apply the T&Cs, our Terms of Use and other agreements or to investigate potential breaches; or
  • protect the rights, property or safety of Portify, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store your personal data

We will store your data on servers based within the European Economic Area (EEA).

Please note however that Salt Edge and our other service deliver partners may transfer your data to, and store it at, a destination outside the EEA. While the processing of your personal data by those third parties is solely their responsibility and is subject to those parties’ own terms and conditions and privacy policies, by submitting your personal data, you agree to transfer, storing and processing of your personal data by those parties outside the EEA.

We will take all steps reasonably necessary to ensure that we treat your data securely and in accordance with this Privacy Policy.

All information you provide to us is stored on our secure servers. Data relating to your payment transactions will be securely encrypted using TLS (Transport Layer Security). 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.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the App or our Site; 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. We use the very latest framework releases. We use tried and tested modules, and apply fundamental security considerations to every aspect of software design and development. We also frequently review and externally test our software. We filter identifiable information from server logs, encrypt identifiable information in our secure databases, and we only communicate over encrypted protocols.

Personal data may be stored on your Device or web browsers using application data caches and browser web storage or similar technology.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if We intend to use your data for such purposes or if We intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms We use to collect your data. You can also exercise the right at any time by contacting us at [email protected].

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Service are advertised). If you follow a link to any of these websites, 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.

Access to your information and how to change it

The Data Protection Act 1998 and, with effect from 25 May 2018, the General Data Protection Regulation, gives you the right to access information held about you. Your right of access can be exercised in accordance with those pieces of legislation.

You can access much of your data on the App or on the Site itself where you can make corrections, updates or deletions.

Keeping your data

We strive to retain your personal data for no longer than is necessary.

General Data Protection Regulation

This regulation (the GDPR) came into effect on 25 May 2018 and We respect and comply with the new rights it brings into effect for the benefit of individuals. In particular:

Right to erasure: Also sometimes referred to as the “right to be forgotten”, We will comply with our obligation to erase your data promptly where you request us to do so in exercise of your rights under the GDPR.

Right of data portability: We will transfer your personal data to another data controller in a structured, commonly used and machine-readable format, upon request.

Complaints

Please know if you have any complaints of any kind. We will do our absolute best to resolve them. If we are unable to do so, remember that you have a right to complain to the UK data protection regulator, the Information Commissioner’s Office.

Changes to our privacy policy

We will give you at least 30 days’ notice of any change by sending you an SMS or email with details of the change or notifying you of a change when you next start the App or access the Service.

Our contact details

Portify Limited, trading as Portify, is a British company registered at Evolution House Iceni Court, Delft Way, Norwich, Norfolk, United Kingdom, NR6 6BB.

Portify is committed to protecting and respecting your data and privacy. We have a nominated Data Protection Officer in charge of this. Portify is the responsible entity for processing your personal data noted above, and is known as the “data controller” under applicable laws.

Questions, comments and requests regarding these terms are welcomed. You can reach us on [email protected].

Last updated: 30/08/2018