We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact:

*One.io UK Limited is registered as a data controller with the ICO (ZA795316).

**One.io Cyprus Limited is a registered Electronic Money Distributor (“EMD”), authorised to distribute and redeem e-money on behalf of Sureswipe E.M.I. PLC (“Sureswipe”), an Electronic Money Institution licensed by the Central Bank of Cyprus (authorisation number 115.1.3.26). When you engage in services provided by ONE acting as Sureswipe’s EMD, ONE is obliged to disclose your personal data to Sureswipe. ONE and Sureswipe will process your personal data as independent controllers. By accepting this Privacy Policy, you are implicitly accepting Sureswipe’s Privacy Policy.

Changes to the privacy policy

We keep our privacy policy under regular review. Historic versions can be obtained by contacting us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data will not directly or indirectly reveal your identity.

We use different methods to collect data from and about you including through:

1. Direct interactions

You may give us your personal data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.

2. Automated technologies or interactions.

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

3. Third parties or publicly available sources.

We will receive personal data about you from various third parties and public sources as set out below:

• Identity and Contact Data from social media, where we are conducting enhanced due diligence if you’ve applied for our product. Publicly available information from social media websites or other sources may also be provided to us when we conduct general searches on you (for example, to comply with our anti-money laundering or sanctions screening obligations).
• We collect personal data from third parties, such as credit-reference agencies, financial or credit institutions, official registers and databases, as well as fraud-prevention agencies and partners who help us to provide our services.
• This includes your credit record, information about late payments, information to help us check your identity, information about your spouse and family and information relating to your transactions.

We use your personal data so we can provide the best service, tell you about products and services you may be interested in, and to meet our legal obligations. Most commonly, we will use your personal data in the following circumstances:

• Whenever you apply for a product or service, we will use your personal data to check your identity and decide whether or not to approve your application;
• where it is necessary for our legitimate interests; and/or
• where we need to comply with a legal obligation.

Where you have given us consent to use your personal data (for example for marketing purposes), you have the right to withdraw consent at any time by contacting us.

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

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 notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may share your personal data with the following parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

• Internal third parties. This includes members of the ONE group of companies.
• Specific external third parties relevant to our business such as business and banking partners, suppliers and subcontractors, fraud prevention and KYC partners, regulators, tax authorities, law enforcement bodies, or other related service providers when needed for the performance of a contract or the processing according to the table Purposes for which we will use your personal data above.
• 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.

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.

Some external third parties we use to provide our services may be based outside of the United Kingdom or the EEA and so we may need to transfer your data outside the United Kingdom or the EEA.

Whenever we transfer your personal data out of the United Kingdom or EEA, we take all reasonable steps to ensure that a similar degree of protection is afforded to it by the third party.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the United Kingdom or EEA.

We take all reasonable steps to 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.

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 we are legally required to do so.

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.

Details of retention periods for different aspects of your personal data are available on request by contacting us.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include the right to:

• 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 of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at dataprotection@one.io.

Costs

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

Response time

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You have the right to make a complaint at any time to the relevant supervisory authority indicated below: