Privacy Policy – Hastee Card
Contis Financial Services Limited (“we”, “us” or “our”) is committed to protecting and respecting your privacy.
This policy together with our Cookie Policy, our Terms of Use and any other documents referred to in them, sets out the basis on which any personal data we collect from you, or that we collect about you, on the Hastee website (the “Website”), on the Hastee App (the “App”) or when you communicate with us by email, telephone or post will be processed by us.
We will be the data controller of your personal data which you provide to us or which is collected by us about you. This means that we are responsible for deciding how we hold and use personal data about you and that we are required to notify you of the information contained in this policy. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
We may be provided with this data by a client of ours, Hastee Technologies Ltd (“Hastee”), who provides the Website and App for the purposes of applying for the account and providing some account services. Hastee is an independent data controller and will also be acting as a processor of ours. For further information as to the type of personal data we share with Hastee and the uses made by them of that data see the data sharing section of this policy below. You should also read the Hastee Privacy Policy which is available on the website and app.
If you have any queries, you can contact us using the details provided at the end of this policy in the “Contacting Us” section.
Ensuring the lawful use of your personal data
We will only use your personal data where we have a lawful basis to do so. We will usually only use your data:
Further details of how we will use your personal data are provided below.
What information we collect from you and how we use it
When you apply to create an account
When you apply to create an account, we will need to collect the following details about you:
We will use this information for the purposes of processing your application and, if your application is successful, creating and managing your account and providing any products or services you request to you.
You will not be able to apply to create an account or order products or services from us without providing this information.
Fraud and money laundering checks
In order to process your application and before we fulfil your order and provide services, goods or financing to you, we will use the information you provided to create your account to undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. This may involve sharing your personal data with fraud prevention agencies. We will continue to carry out these checks on a regular basis while you are a customer of ours.
When we and fraud prevention agencies process your personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.
We, and fraud prevention agencies, may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
Automated decisions
As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if:
You have rights in relation to automated decision making: if you want to know more please contact us using the details below.
Consequences of processing
If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested or we may stop providing existing services to you.
A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details below.
Other than the automated processing set out above, we shall not carry out solely automated decision-making using your personal data.
When you contact us
When you contact us, we will need to collect personal data about you to verify your identity before we disclose any information to you for data security purposes. We will be unable to deal with your query unless you provide the information we request. We may also collect any other personal data you choose to provide to us when communicating with us. We will only use that personal data for the purposes of dealing with your enquiry.
In the event you contact Hastee for support in relation to a query about your card, Hastee will be acting as a processor of ours in the event it has to share that support query (and any personal data contained within it) with us so that we may resolve it for you.
How we use data about you, for what purpose and legal basis
We use your personal data for various purposes connected with your use of the account and services. We will only do so where we have a lawful basis to do so. We will usually only use your data:
We use your personal data for the following purposes :
The table below sets out further information about the purposes for which we use data about you, with the corresponding methods of collection and legal basis that we rely upon for its use.
Purpose | Lawful basis for processing |
Creating and managing your account
• to apply and create your account • to administer and manage your account • to retain your account profile information |
To fulfil our contractual obligations to you in providing the account and services.
Our legitimate interests in operating and improving our services to you. Our legal obligations to comply with regulations that apply to us. |
Carrying out identification and fraud checks
• to carry out the required checks on your identity and enable you to use your account and card |
To fulfil our contractual obligations to you in providing the account and services correctly.
Our legitimate interests in operating and improving our services to you and how we deal with financial crime. Our legal obligations to comply with regulations that apply to us. |
Facilitating your use of your account and card
• to administer your financial transactions (e.g., payment, refunds, cashback, transfers, etc.) • to provide details of your transactions • to retain records of your transactions and spending activities |
To fulfil our contractual obligations to you in providing the account and services.
Our legitimate interests in operating and improving our services to you. Our legal obligations to comply with regulations that apply to us. |
Monitoring your use of the account and card to detect fraudulent behavior
• to detect, and prevent financial crime • to satisfy our legal and regulatory obligations • to manage risk for us, you and our other users |
To fulfil our contractual obligations to you in providing the account and services correctly.
Our legitimate interests in operating and improving our services to you and how we deal with financial crime. Our legal obligations to comply with regulations that apply to us. |
Communicating with you and providing you with customer support
• to investigate your complaint or query • to inform you of important information or changes to your terms and conditions |
To fulfil our contractual obligations to you in providing the account and services.
Our legitimate interests in operating and improving our services to you. Our legal obligations to comply with regulations that apply to us. |
Sharing data with our suppliers and other third parties (such as banking institutions, payment facilitators, and card operators) where required
• see the section Disclosures of your information section for more information |
To fulfil our contractual obligations to you in providing the account and services.
Our legitimate interests in operating and improving our services to you. Our legal obligations to comply with regulations that apply to us. |
Sharing data with Hastee in order for Hastee to:
• administer, manage & provide the App / Website, manage their relationship with you and deliver relevant content to you • analyse and develop other products and services • provide customer support to you regarding the account, card and payments |
To fulfil our contractual obligations to you in providing the account and services.
Our legitimate interests in operating and improving our services to you. Our legal obligations to comply with regulations that apply to us. |
The information we receive from other sources
We are also working closely with third parties (including, for example identity verification agencies, payment schemes and fraud prevention agencies) and we may receive information about you from them for the purposes of identity verification and fraud prevention.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will usually notify you and we will explain the legal basis which allows us to do so.
Disclosures of your information
We will disclose your information to:
in order to allow us to manage our business and to provide the products and services to you.
Protecting your information
Your data is secured by encryption, firewalls and Secure Socket Layer (SSL) technology. This is industry standard encryption technology which manages the security of messages transmitted across the internet. When we receive your data, we store it on secure servers which can only be accessed by us. We store your passwords using one way encryption which means we do not know what your password is.
Storing your data within and outside the EEA
Our third party data host provider uses servers located in the US to store personal data. As a result your personal data will be transferred to the US which is located outside of the European Economic Area and so is not governed by European data protection laws.
However, we have entered into the standard contractual clauses (Model Clauses) adopted by the European Commission with OrcsWeb Inc, in order to safeguard personal data when it is accessed from outside of the European Economic Area.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy when it is transferred, stored or processed in this way.
Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose the standard contractual clauses (Model Clauses) adopted by the European Commission on the recipients of that data in order to safeguard personal data when it is accessed from outside of the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.
More information about the Model Clauses is available here http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX:32010D0087.
Future changes
Any changes we make to our policy will be put on the Website and/or App as applicable and, where appropriate, notified to you by e-mail. Please check for updates from time to time.
Retention of your Data
We will retain your personal data for as long as you continue to use our services. Thereafter, we may retain your information for an additional period as is permitted or required under applicable laws. For example:
Your rights
Data protection laws provide you with the following rights to:
You also 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. You also have the right to object where we are processing your personal data for direct marketing purposes.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights above). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
If you are unhappy about how your personal data has been used please refer to our complaints policy which is available by contacting us. You also have a right to complain to the supervisory authority, which in the United Kingdom is the Information Commissioner’s Office https://ico.org.uk/, which regulates the processing of personal data.
Contacting us
If you have any questions about this policy, you can contact us in the following ways:
By post at:
Data Protection Officer
Contis Financial Services
Navigation House
Belmont Wharf
Skipton
North Yorkshire
BD23 1RL
By email at: DPO@contis.com
By telephone at: +44 (0) 202 3645