Privacy Policy

This Privacy Notice explains what information we collect about you, how we use it, and the purposes for which we use it. It applies to all your interactions with us, including when you use our app or our website and when you apply for any of our products or services.

We are committed to collecting, protecting, and using your personal information fairly and in accordance with our obligations under the General Data Protection Regulation (‘GDPR’) and the Data Protection Act 2018.

Who we are:

We are JOHN BEAK LIMITED ("Beak", "our", or "us"), a company registered in England and Wales whose registered office is at 1 St. James's Street, London, England, SW1A 1EF, and whose registered number is 14947831.

We are committed to protecting and respecting your privacy and to providing clear information about the use of your data. We are the data controller for the purposes of the personal data we collect via our app and for the performance of the services listed under the usages of your personal data, below (together, the “Services”).

If you have a question or concern about this Privacy Notice or your data protection rights, please contact us by emailing us at [email protected].

What personal information do we collect about you?

We collect information from you directly when you apply for and use our services, or from relevant third parties.

(i) Information provided by you:

• Your name
• Email address

We will also collect information from you and about you when you interact with us:

• Electronically/Online: Where you use our website, information from any accounts you share with us, when and how you use our mobile application (‘app’), information we use to identify you, and other information obtained from your mobile device.
• In writing: Where you send us letters, forms, survey responses, emails, feedback online, or your social media posts about us.

Where you provide us with your personal information you should ensure that it is accurate and you should tell us without delay if it changes. You are required to do this as part of the Terms & Conditions you agree to.

(ii) Information we collect when you use our services:

We will collect the below information from your use of our website and app. We gather this data from the devices you use using other software. This includes location (based on the IP address you use) and configuration information about your mobile device, which is used for fraud detection and to help us fix bugs, such as app crashes, and to provide insights into your experiences so we can make improvements:

• Details of your device, such as the make and model of your phone;
• IP (‘internet protocol’) address of your device.
• Actions you perform when using our services, such as which screens in the app you visit.

(iii) Information provided by third parties:

When you use our Services, we will also use data from persons or entities. These third parties include:

• Salt Edge Limited - They are an Account Information Service Provider (AISP). This means that after you have given your consent in the app to use this service, they will provide us with information about the transactions you make with your banks and other financial institutions.
• Google - They provide us with a way of authenticating you as a user, and will provide us with your email address.
• Apple - They also provide us with a way of authenticating you as a user, and will provide us with your email address.
• Amplitude - They will provide the software to identify how you use our app, such as the make and model of your phone, your IP address, and the actions you perform when using our services.

We may also collect your personal data from organisations to which you have given permission to share it for specific purposes or who have another legal basis on which to share it with us.

Where relevant, we will also collect and use information from your representatives or a third party to whom you have given authorisation to do so.

How we will use your personal information

By law, we may use your personal information provided we have a lawful basis for doing so or we are under a legal duty to do so. This includes sharing it with third parties in certain circumstances as described below. We consider we have the following reasons (lawful bases) to use your personal information:

Entering into and performance of the terms and conditions agreement with you:
We need to use your personal information to be able to agree the Terms and Conditions with you and to provide you with products and services under that agreement. This will include:

• Providing you with personalised offers and discounts
• Customer Service Support
• Central Spend Tracking

Meeting our legal obligations:
We need to use your personal information so as to comply with legal requirements upon us. These include:

• Keeping business records.

Our legitimate interests:
We have a legitimate interest in using your personal information:

• To understand our customers’ use of our products and services, improve them, and develop and test new products and services;
• To offer new products and services to you (where you have agreed to this);
• To help prevent and detect fraud;
• For business analysis, data verification, and data enrichment purposes;
• To share your personal information with any person to whom we may transfer or consider transferring our rights under our agreement with you;
• To establish, exercise, and defend our legal rights; and
• To assist in complying with legal and regulatory requirements placed upon us.

Where we need your consent:
Where we have your consent or in the case of special category data where we have your explicit consent we may also use your personal information for additional purposes.

We will need your explicit consent when you use services provided by our AISP in our app for the purposes of retrieving information about your spending.

Recording our interactions with you:
We may monitor and record letters and emails with you to check we have carried out your instructions correctly, to resolve your queries or any disputes with us, to deal with any complaints you may have, to assess and improve the quality of our service, for training our staff, or for regulatory or fraud prevention purposes.

Who we share your personal information with:

We may share your personal information with anyone who works for us or is contracted to work for us when they need it to do their job, and anyone you give us permission to share it with.

We will also share your personal information with organisations (including our subcontractors, agents, or service providers) that facilitate any of our services when they need it to provide their services. These include:

• Website and app hosting service providers
• Merchant Categorisation services
• Cashback, Offer and discount providers
• Customer Analytics providers

We will also share your personal information where it is necessary to comply with the law, to enforce our contract with you or other agreements, or to protect our rights, property, and safety and those of our customers or others.

For how long will we keep your personal information

We will keep your personal information for as long as you are a customer of John Beak Limited and for up to seven years afterwards to enable us to deal with any matters including disputes and legal claims that may arise subsequently. We may retain your information for longer periods for statistical purposes. If we do this, your information will be anonymised or pseudonymised to protect your privacy.

We may also retain your data for research and statistical purposes in which case we will ensure it is anonymised where necessary and used only for these purposes.

When your personal information is transferred overseas:

We will transfer and store your personal data outside the United Kingdom in specific circumstances, including making this information available for use by our development support teams. We may do this in order to perform our obligations under our contract with you, to fulfil legal obligations to which we are subject, to protect our legitimate interests and where the public interest may require it.

Wherever we, or any other party with whom we have shared your personal information as mentioned above, transfer your personal information outside the U.K., we, or they, will make sure that either the data protection laws of the country to which your personal information is to be transferred provide an equivalent level of protection to the standards required in the U.K or, if they do not, the organisations to which your personal information is to be transferred themselves apply a level of protection for your information equivalent to the standards required in the U.K.. This may include imposing conditions in the contracts we have with these parties.

We, or they, may also require the recipient of your personal information to subscribe to ‘international frameworks’ intended to enable the secure sharing of information.

In any other cases, if we transfer your personal information outside the U.K., for example because we have to do so to help prevent or detect a crime, we will only share it lawfully.

Your Privacy Rights:

The law which protects your personal information gives you the right to:

Access the personal information we hold about you, or to get a copy of it:

This can be a request for specific information you wish to access, or a general request to get a copy of all the personal information we hold about you that we are legally permitted to share.

Request that we amend, update or correct inaccurate information:

This also includes your right to request that we correct inaccurate information that we have shared with third parties.

Request that your personal information is erased:

The right to erasure is often referred to as the ‘right to be forgotten’. This request will be fulfilled unless and to the extent that we have a legal or contractual obligation to continue to hold or process your information.

Request that we restrict the personal information we use about you:

You can ask us to restrict the personal information we use about you where it is inaccurate, where you have asked for its erasure, or where you have objected to our using it. We may still use your restricted information where we need to bring or defend legal claims, to protect the rights and freedoms of others or for important public interest reasons.

Object to our controlling and processing your personal information:

This request will be fulfilled unless and to the extent that we have a legal or contractual obligation to continue to process your information.

Request that we transfer your personal information:

If you request it, we will transfer your information you have provided with your consent.

Object to our sharing of your personal information with others or with certain organisations:

In some cases, however, this sharing is required by legal or contractual obligations.

Request that we confirm what personal information we currently control and/or process in relation to you:

We will confirm all the data we control in relation to you that we are legally permitted to disclose.

Withdraw any consent you have previously given us:

To exercise any of these rights, or for further information, please contact us by emailing [email protected].

To withdraw consent for use of services provided by our AISP, you can do so by disconnecting your connected banks in the app.

You also have the right to complain if you are unhappy about how your personal information has been used.

To make a complaint, please contact us via email [email protected].

To complain to the Information Commissioner’s Office, which regulates the processing of personal data, you can contact them direct at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, on 03031231113, or by email to [email protected]. See also ico.org.uk/global/contact-us.

Closing your account

You may close your user account at any time. Extended periods of inactivity may also result in your account closure and the Service being unavailable to you. To close your account use the close account function in the app or use the following link: https://beakapp.co.uk/delete-account/

Changes to this Privacy Notice:

We will post any changes we make to our Privacy Notice on our website. If we make any significant changes, we will let you know by email. This Privacy Notice was last updated on 11th March 2024.