PRIVACY POLICY This is the privacy policy for Saverd Limited trading as Bean, a company registered in England (company number 9904318) with a registered office at Saverd Limited, Pegasus House, Bakewell Road, Orton Southgate, Peterborough, England PE2 6YS. We are registered with the Information Commissioner with registration number ZA242214. We are registered by the Financial Conduct Authority (FCA) for the provision of payment services under, registration number 795761 and authorised and regulated by the FCA for the insurance distribution under registration number 785731. In this Privacy Policy “we” “us” and “our” means Saverd Limited. This policy relates to the use of personal information provided in relation to the use of the website, mobile application and online account and personal finance management services provided at www.usebean.com (the “Service”). References to “account provider” means an Account Servicing Payment Provider such as a bank, building society or credit provider. By “personal information” we mean all information that identifies or may identify you. Overview Please review this Privacy Policy carefully. This Privacy Policy should be read together with the Terms and Conditions posted elsewhere on our website/App. We may amend this Privacy Policy from time to time. Using our Service and providing any personal information to us after the date of any amendments constitutes acceptance of our amended Privacy Policy. We will publish any updates to the Privacy Policy on our website/App. Who is processing your data? We are the data controller of the personal data that you provide on the website/App and/or that we collect about you. This means that we are the company responsible for deciding how your data is processed. We are part of the BGL Group of Companies which provides products and services under various brands. If you want to know more about the BGL Group of Companies and its brands, you can find out more at www.bglgroup.co.uk. It may be necessary for us to share data with our group companies for the purposes set out in this Privacy Policy. In order for us to provide the Service to you, you will be invited to link accounts that you hold with account providers with your Bean account which will allow details of transactions that have been carried out relating to your accounts to be displayed in your Bean account. To link an account to your Bean account we will transfer you to your account provider to provide your log-in details directly to them to authorise us to receive your transactions. We do not have access to any log in details or security information you provide to your account provider. Any data that you provide to your account provider during the log in process will be subject to your account provider’s privacy policy. Where do we get the data from? From you Most of the data that we process will be data that we collect from you directly when you set up an account. We will ask you various questions to collect the data we need for the purpose of setting up your account. We will not be able to set up an account unless you answer the mandatory questions. Where questions are optional, we will explain what we need the data for. From your account providers when you link accounts If you link any of your accounts to your Bean account, your account provider will allow us read only access to the accounts you specify which will include the name, date and amount of any transactions. It will not include any of your account log-in information or passwords. The consent that you provide for us to have this read only access will last for a period of 90 days after which you will be asked to reconfirm your consent again.  From our partners We will from time to time provide links on this website/app to third parties who are able to offer you products and services. If you register with a third party or purchase any products or services through links on this website/app, our partners may provide us with information about you such as what product or service you purchased and when. From your use of the Website or App and our services We also collect data about you based on your actions, for example we collect data about how and when you use the website, our App or our Services so that we can build up a picture of you as a customer. This can include information such as how often you use your account, mouse clicks/taps, mouse movements, page scrolling and text entered into forms which we collect through software which monitors how customers use our website and our App. This helps us to provide you with a good service and to design improvements to our products and services (including changes to our website/app) but is also used to help us to prevent and detect fraud. We, and our partners collect some of this data by using cookies, web beacons and pixel tags. A cookie is a small file that is placed on your device, which enables a server to identify that device and allows us to offer the best services possible by allowing us to recognise you as a unique user and provide us with information about how you use our website. Cookies are commonly used on the Internet and do not harm your computer system. Web beacons and pixel tags are similar to cookies and allow us to collect information about how you use our website and help us to offer you the best service. You can read our cookie policy for more information. We may use web beacons and pixel tags alongside cookies both on our Website and App and in any emails we send to you. Information collected may include items such as the IP address of your computer, the time you visited our Website or App and what links you clicked on or when you opened our emails. We may also use information from cookies or tags when you click through from our Website or App to our partners’ websites to help us understand which links you have used. Further information about cookies, web beacons and pixel tags can be found at www.allaboutcookies.org. This website also uses Google Analytics to allow us to monitor how users use our Website. We use services provided by Google to do this including Google’s Remarketing and Advertising Reporting Features. The features that we use include Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting and integrated services that require Google Analytics to collect data for advertising purposes including the collection of the data via advertising cookies and identifiers. As part of this activity, if you have a Google account and have allowed Google to associate your web and app browsing history so that you may receive personalised ads then Google may collect a Google identifier which allows them to identify your Google account when you are using this Website (including where you use different devices to access this website). Google use this data alongside other data they may collect about you, which may include your location, search history, YouTube history and data from other sites that partner with Google, to provide us with aggregated and anonymised information which assists us in understanding how individuals are using our website. If you require further information or wish to opt out of Google Analytics Remarketing and Advertising Reporting Features then please visit Google’s currently available opt-outs. If you contact us electronically, we may collect your electronic identifier e.g. Internet Protocol (IP) address, or device ID or telephone number supplied by your service provider. This information may be used by us and/or shared with and used by our partners to aid in the detection of fraud. What do we use your data for? The data that we hold is used for the following purposes:- Part 1 – Providing you with our services The personal data that we use for the purposes set out in this Part includes: your name, contact details, date of birth, details of your payment transactions, account details, online payment account information and details of bills and other recurring contracts. We use the data set out above to:
    • Provide access to your payment transactions. From time to time we may ask you if you’d like to provide us with further information about your transactions (for example the nature of the service the transaction relates to), this will be optional and any additional data you provide will be used for analysis and research purposes to allow us to improve the Service;
    • To provide you with relevant information and tips about how you could save money by looking at the type of transactions you make;
    • Send you any reminders that you have set up;
    • Communicate with you about our services, for example sending you any service updates;
    • Manage, run and administer your account;
    • Help us build up a picture of you as a customer to ensure that we provide you with more relevant information, such as showing you the right content at the right time; and
  • Send you personalised communications.
It may also be necessary for the data described above to be shared with third parties or with other companies within the BGL Group of Companies for the following purposes:-
    • In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets, along with its professional advisers;
    • In connection with any proposed or actual financing, securitisation, insuring, assignment or other disposal of all or part of our business or assets, we may disclose your personal information to anyone whom we may transfer our rights and/or obligations for the purposes of evaluating and performing the proposed transaction;
    • If we or substantially all of our 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 required in order to obtain professional advice;
  • If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Saverd Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
Data protection law says that we have to tell you the legal basis on which we process your personal data. In relation to personal data used for providing you with a service and managing your account, we process this data because it is necessary to perform the contract that we have in place with you to provide you with our services. Part 2 – Fraud Prevention In order to prevent and detect fraud we may use the personal data set out above at any time to:
    • Check and/or share your details with fraud prevention and detection agencies; and
    • Share information about you with other organisations including the police, where necessary and proportionate; and
  • Carry out analysis on data that is held in order to assist the identification of fraud.
In relation to the personal data processed for fraud prevention, we process this we have a legitimate business interest in carrying out these activities to help minimise the risk of fraud or crime occurring and in its detection. Part 3 – Other Uses of Data Marketing When you provide your details you will be given an opportunity to confirm whether you are happy to receive marketing material from us. If you confirm you are happy to receive this material, we will use your postal address, email address and telephone number to send you marketing materials by post, email, telephone call or SMS. We do not pass your data to other companies for marketing purposes. You can change your mind at any time by logging into your account and updating your preferences. You can also unsubscribe from emails by clicking on the unsubscribe link on any marketing emails that we send you or updating your preferences in your account. This will not impact any communications that we need to send you for the purpose of your account, for example any necessary service updates. If you have agreed to receive messages from us, we will either use your device information to send you push messages (where you have opted in specifically to receiving push messages), or we will send in-app messages to you, for example to ask you to review the App. Market Research From time to time we may want to use your postal address, email address and/or telephone number to contact you to assist us with our research by asking you a few questions about the service you have received or by asking if you would like to complete a review of our services. We may sometimes ask market research companies to contact you on our behalf. If you would prefer us not to contact you for market research purposes then you can let us know by contacting us at support@usebean.com. Research and Analysis Activities We use data that is collected on the Website or the App for research and analysis activities. This includes information relating to your account, (including information about your payment transactions). We use this information to carry out various research and analysis activities to help us to regularly review and improve the products and services we or our partners provide and carry out research. We also share this data with our partners and with other companies within the BGL Group of Companies to enable them to use this data for these purposes. Where possible, data will be shared on an anonymised basis. The data will not be used to make any decisions that will affect you or any other individual and data will be deleted as soon as the relevant research and analysis activity is concluded. We also use the data that we collect about you through your Website/App usage to carry out research and analysis into usage and activities on our Website/App to enable us to continue to improve our Website/App and our products and services. In relation to personal data used for the purposes described in this Part 3, we process this data because we have a legitimate business interest in carrying out these activities to promote and improve our business. We have ensured appropriate safeguards to protect your rights when processing this data for these purposes. How long do we keep data? We’ll only keep your personal data as long as we need it and ensure it is securely destroyed when it is no longer required. We do however need to keep certain data after we have provided you a service as described below. If you have an account with us we will keep your data while your account with us is active and then if you stop using your account we will generally retain your data for a period of 6 years from that point (unless there is a requirement for us to keep the data for longer, for example if there are any ongoing queries or claims relating to your account). We keep data for this period as it plays an important part in allowing us to deal with any queries or complaints that may arise regarding service that has been provided, to assist us in any fraud detection or investigation and allow us to carry out research and analysis to help us improve our products and services (as described in the section headed “What do we use your data for?” above). Overseas Transfer of Data We use third party suppliers to process limited personal data about you. Some of these suppliers may be located in countries outside the UK which may not have equivalent laws in place to protect your personal data. For example, we use third party software suppliers such as Microsoft to process data such as your IP address and email address, which Microsoft stores in the USA. Whenever we do use third party suppliers to process personal data about you outside the UK, we will ensure that your personal data is kept securely, is only used for the purposes set out in this Privacy Policy and is afforded equivalent protection as it would be if it were processed in the UK. We do this through various mechanisms, for example making sure that European Commission approved contractual clauses are in place with the supplier or ensuring that suppliers who process personal data in the USA are signed up to the Privacy Shield arrangement. If you are concerned about our use of third party suppliers to process personal data outside the UK, or if you would like any further information about any of these suppliers, please contact us using the details set out under “Contacting us” below. Your Rights Data protection law gives you various rights in relation to your personal data. All the rights set out below can be exercised by contacting us using the contact details set out under the “Contacting us” section below. Please note that we can only deal with requests to exercise these rights where they relate to personal data that we process as data controller. If you send us a request which relates to personal data processed by your account provider, we will direct you back to your account provider to make the request to them directly. Your rights include:-
    • You have the right to ask us to provide a copy of the personal data that we hold about you. This is called a Data Subject Access Request or “DSAR”. You can access much of your information directly by logging into your account. If you want to receive other personal data that we hold then you can make a DSAR. When contacting us please describe the information you require and include the following: your full name, your date of birth and your full address. For security purposes we can only deal with requests where the contact details you provide match the details we have on file and we may need to ask you for further information to verify your identity. If you have changed your contact details or you require information sending to different contact details please include a copy of your passport or driving licence and proof of address such as a recent utility bill to assist us in verifying your identity. We might also need to ask you for additional information to help us locate the data that you are looking for. Once we have all the information that we need to process your DSAR, we will respond within one month unless your DSAR is very large or complex, in which case we may need to extend this period. If we need to do this we will let you know.
    • You have the right to ask us to correct inaccurate personal data that we hold about you. If you think any of your personal data is inaccurate, please contact us and, provided we can verify your identity and are satisfied as to the accuracy of the correction requested, we will correct the relevant personal data as soon as we can. If the inaccurate data relates to the payment transactions received from your account provider, we will let you know and you will need to contact your account provider directly regarding this. We are not responsible for the accuracy of the information your account provider provides.
    • You have the right to request that we provide a copy of your personal data in a machine readable format or to ask us to send your personal data to another company. This applies to personal data that you have provided to us, which we have processed electronically, such as personal data you entered on our website when you obtained a quote.
    • You also have the right to ask us to delete personal data that we hold about you. We are obliged to delete personal data in some circumstances, such as where it is no longer needed. However, data protection laws allow us to keep the personal data if we need to, for example if the data is needed for fraud prevention. In any case, we will retain your personal data in line with the retention periods detailed under “How long do we keep data?” above.
    • You have the right to ask us not to do anything with your personal data except store it in limited circumstances, such as if you and we do not agree on the accuracy of personal data and steps are required to validate it.
    • You have the right to object to us processing certain personal data about you. However, where we need to continue to process the personal data, for example for fraud prevention purposes, we are not obliged to stop processing it.
  • You have the right to ask for significant decisions that have been made about you wholly by automated means to be reviewed however, we confirm that we do not make any significant decisions about you wholly by automated means.
Contacting us
    • If you would like to contact us about one of your data rights set out under “Your Rights” above, then please contact support@usebean.com.
  • If you would like to contact our Data Protection Officer, you can email dpo@bglgroup.co.uk  or write to the Data Protection Officer at Saverd Limited, Pegasus House, Bakewell Road, Orton Southgate, Peterborough, PE2 6YS.
Information Commissioner’s Office
  • If you have a complaint regarding how your personal data has been processed processed by us then please contact us first using the complaints procedure set out at section 11 of the our Terms and Conditions. You also have the right to complain to the Information Commissioner’s Office, which regulates data protection compliance. You can find more information by visiting their website www.ico.org.uk.
This Privacy Policy was last updated on 29 November, 2019.