CUSTOMER PRIVACY NOTICE


First Issued: 12th March 2021

Last updated: 30 September 2022

Version: 6

Introduction

Kroo Bank Ltd ("we", "us", and "ours" or “Kroo”) respects your right to privacy.  This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights.  If you have any questions or concerns about our use of your personal information please contact us using the contact details provided at the end of this Privacy Notice.

What does Kroo do?

Kroo is a company incorporated in England and Wales. It is authorised as a bank by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority (firm registration number 953772). Kroo is separately registered as a payment services / electronic money agent of Modulr FS Limited under registration number 902797 and also acts as an electronic money agent of Payrnet Ltd. At present Kroo provides a prepaid debit card to existing customers, and a banking app that enables customers to set up social groups of friends, flat mates, colleagues, family etc and split bills and settle directly with each other. It now also offers a current account.

Information that you provide voluntarily

We ask you to provide certain information voluntarily.  The types of information we ask you to provide, and the reasons why we ask you to provide it, include:

Types of personal information

Why we collect it

Name and contact details such as address, telephone number and email

For the purpose of processing applications for banking products and services, including ID, address, fraud and credit checks.  We may also use some of your data to :

  1. create a waiting list of customers who will shortly be invited to apply for a new product;
  2. provide those products and services to you and to communicate with you in connection with those products; and
  3. contact you to ask if you would be willing to participate in market research.

Types of personal information

Why we collect it

Personal data you may provide in communications

Where we are communicating with you, whether via the banking app or otherwise, you may provide personal data, for example in connection with an enquiry or complaint.

Age

To verify we are legally permitted to provide banking products and services to you.

Information such as copies of passports, driving licences, or other government-issued IDs, passport numbers, proof of address documents, signatures, tax identification numbers and utility bills and other evidence of transactions.

For identification purposes and to prevent fraud in connection with accounts and to comply with anti-money laundering requirements and tax reporting requirements.

We may also use all or some of the personal data you give us to analyse our customer base, for example to look at the age profile of customers and applicants. More generally we will use the information to administer the services you have requested.

If we ask you to provide any other personal information not described above, then the personal information we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect your personal information.

Information that we collect automatically

When you use a mobile phone or other similar electronic device to access our products and services, we may also collect certain information automatically from your device.  This will include your IP address.

Information that we obtain from third party sources

From time to time, we may receive personal information about you from third party sources (including credit reference agencies, World Checking services, CIFAS (a UK fraud prevention organisation that managers the National Fraud Database), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

The types of information we collect from third parties includes:

Types of personal information

Why we collect it

Criminal records and proceedings checks, immigration status checks and World Checking searches

To comply with anti-money laundering and other account opening and maintenance requirements

Account and loans information

To provide our products and services to you, for internal analytics and credit portfolio management and for the purpose of detection and prevention of fraud

Information to check creditworthiness such as financial history, income and outgoings, credit history and court judgements

To carry out checks to assess creditworthiness for credit facilities you have applied for, for internal analytics and credit portfolio management

An indicative credit score for you - we obtain this from one or more credit reference agencies.

To provide you with a service. This information is only held if you have requested our Credit Score Monitoring Service. Also used to let you know about our own credit products from time to time.

Information about claims and proceedings (or potential claims and proceedings) by or against you

To identify, exercise and defend contractual and other legal rights

In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information.  However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

Who does Kroo share my personal information with?

We may disclose your personal information to the following categories of recipients:


Legal basis for processing personal information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.  In some cases, we may also have a legal obligation to collect personal information from you or from third parties (such as to comply with anti-money laundering or immigration laws and fraud prevention) or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided at the end of this Privacy Notice.

How does Kroo keep my personal information secure?

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you.  The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.  Specific measures we use include:


International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which it was originally collected and other than the one in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, our servers are hosted by AWS in Ireland. Our third party service providers and partners operate around the world. This means that when we collect your personal information we or our data processors may process it outside the UK or the European Economic Area (EEA).When we export your personal information to a different country, we will take steps to ensure that such data exports comply with applicable laws.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.  

Automated decision-making

Automated decisions are decisions concerning you which are made automatically by a computer using software algorithms, without human review.  We do not use automated decision-making except:

Your data protection rights

You have the following data protection rights:

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments.  When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.  We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the date displayed at the top of this Privacy Notice.

How to contact us

If you have any questions or concerns about our use of your personal information, please contact our Data Protection Officer using the following details: dataprotection@Kroo.com. 


© Kroo Bank Ltd 2021 - 2022