MONEY MIND WEBSITE PRIVACY POLICY

  1. What this policy covers
    1. This privacy policy (the Policy) relates to your personal information in connection with your use of, and access to, the website at http://www.saladmoneymind.co.uk (our Website). Our Website enables NHS employees to benchmark their spending against fellow employees and the optional Benefit Entitlement Service which enables users to find out if they are entitled to any state benefits (the Service).

    2. The term “you” refers to individuals wishing to access and/or use the Website and/or the Service. When you use the Website or the Service, you trust us with your personal information. We take your privacy very seriously. Through this Policy, we seek to explain to you clearly what information we collect, how we use it and what rights you have in relation to it. It is important that you read this Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them. If there are any terms in this Policy that you do not agree with, you must discontinue use of the Website and the Service immediately.

  2. Who we are and how to contact us
    1. The Website is operated by, and the Service is provided by, OBWORKS LIMITED (we, us, our or Money Mind). We are a limited company registered in England and Wales under company number 12417206 and have our registered office at

      49 Greek Street, London, England, W1D 4EG

    2. Money Mind is an Account Information Service Provider (AISP). Money Mind is not a financial adviser and is not authorised to provide advice under the Financial Services and Markets Act 2000. If you require authorised financial advice, please contact an authorised adviser.

    3. Money Mind is the controller (also known as a data controller) of the personal information that we collect via the Website and for the performance of the Service. We determine the purposes for, and the way in which, your personal data is, or will be, processed. We are registered with the Information Commissioner's Office (ICO), which is the UK supervisory authority for data protection issues, with registration number ZA794973.

    4. To contact us, including if you have any questions or concerns about this Policy, or our practices with regards to your personal information, please email general@saladmoneymind.co.uk, telephone our customer service line 0203 092 0892 on or write to us at 49 Greek Street, London W1D 4EG. If your complaint is about how we store or process your personal information, you can also contact the ICO. We would, however, appreciate the opportunity to resolve your concern first.

  3. Changes to this Policy or your personal information
    1. We review this Policy regularly and it is your responsibility to check regularly and determine whether it has changed. If you do not agree to any change to this Policy then you must immediately stop using the Website and the Service. In the event we make any significant changes to this Policy we will use our reasonable endeavours to inform you of such changes in advance in writing.

    2. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes (for example, if you change your email address).

  4. Information we may collect about you
    1. Personal information that you disclose to us, either directly or through ASPSPs
      In summary: We collect personal information such as full name, employer’s name, contact information and date of birth.
      1. We collect personal information that you voluntarily provide to us when registering for and using the Service, or otherwise contacting us. The personal information that we collect depends on the context of your interactions, the choices that you make and the products and features that you use.

      2. When you use the Service, we will have access to:

        1. personal information that you submit to us directly when registering to use, and during the course of using, the Service; and

        2. personal transactional information (Transactional Information) from your personal bank account(s) (Personal Account(s)) held by Account Servicing Payment Service Providers (ASPSPs), which will be accessed through Open Banking. To use the Service, you must provide login details for your Personal Account(s) to Yapily Limited (Yapily), our trusted third party AISP. Subject to, and in accordance with, its own terms and conditions with you, Yapily will automatically download Transactional Information from your Personal Account(s) and will continue to do so at certain times until you withdraw your consent for it to do so. Yapily will share this Transactional Information with our sister company, SALAD TECHNOLOGIES LIMITED, who will pass that Transactional Information on to us. No payment(s) will be initiated from your Personal Account(s) at any stage of this process.

      3. When you register to use the Service and/or when you otherwise deal with us, we may collect the following information about you (your Personal Information):

        • Identity Data which includes title, full name, employer’s name, date of birth and gender.

        • Contact Data which means the data we use to contact you including your postal address, email address and contact number.

        • ASPSP Account Data which means the credentials you share with us to enable us to interact with your ASPSPs to obtain personal information through Open Banking, either directly by us or a member of our corporate group, or indirectly through Yapily, our trusted third party AISP.

        • Profile Data which includes your username (email address), your login data, feedback and survey responses.

        • Usage Data which includes information about how you use the Website and the Service. This includes your browsing patterns and information such as how long you might spend on one of our webpages and what you look at, the page that referred you to the Website and the click stream during your visit to the Website, page response times and page interaction information (clicks you make on a page).

        • Marketing and Communications Data which includes your preferences in receiving marketing from us and your communication preferences.

        • Financial Services Records, which is record-keeping information that we collect in order to meet our regulatory and statutory duties.

        • Benefit Entitlement Service Data, which includes additional information required to enable us to provide the optional Benefit Entitlement Service at your request, including whether you have a partner who normally lives with you, how many children live in your household, your rent or housing costs and the monthly take-home income of your household.

        • Other information relevant to services, customer surveys and/or offers.

      4. All Personal Information that you provide to us must be true, complete and accurate, and you must notify us of any changes to your Personal Information.

      5. We may collect the following information about you from your ASPSPs: your account details (including account number, sort code and account name); account features and benefits (including any present or historic overdraft facility); and present and historic account balance and transaction details (together, your ASPSPs Information).

      6. Your Personal Information and your ASPSPs Information shall together be defined as your Information.

      7. The manner in which we access, use, process and store your Information for the provision of the Services is set out below.

    2. Information collected automatically
      In summary: Some information – such as your IP address and/or browser and device characteristics – is collected automat.ically when you use the Website
      1. We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Website and other technical information. This information is primarily needed to maintain the security and operation of the Website, and for our internal analytics and reporting purposes.

      2. Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy

  5. How we use your Information
    In summary: We process your Information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.
    1. We use your Information collected via the Website to enable us to provide the Service and for a variety of business purposes described below. We process your Information for these purposes in reliance on our legitimate business interests (Business Purposes), in order to enter into or perform a contract with you (Contractual), with your consent (Consent), and/or for compliance with our legal obligations (Legal Reasons). We indicate the specific processing grounds we rely on next to each purpose listed below.

    1. We may process your Information for the following purposes:

      • To send administrative information to you for Business Purposes, Legal Reasons and/or possibly Contractual. We may use your Information to send you product, service and new feature information and/or information about changes to our Terms and policies.

      • To send you marketing and promotional communications for Business Purposes and/or with your Consent. We and/or our brand partners may use your Information for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails, see below for further details.

      • Administer promotions for our Business Purposes and/or with your Consent.

      • Request Feedback for our Business Purposes and/or with your Consent. We may use your Information to request feedback and to contact you about your use of the Website or Service.

      • To protect the Website and Service for Business Purposes and/or Legal Reasons. We may use your Information as part of our efforts to keep the Website and Service safe and secure (for example, for fraud monitoring and prevention).

      • To enforce our Terms and policies for Business Purposes, Legal Reasons and/or possibly Contractual.

      • To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

      • For other Business Purposes. We may use your Information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve the Website, the Service, products, services, marketing and your experience.

  6. How your Information will be shared
    In summary: We only share information to comply with Contractual obligations, fulfil our Business Purposes, or with your Consent.
    1. We only share and disclose your Information in the following situations:

      1. Compliance with Legal Obligations. We may disclose your Information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

      2. Vital Interests. We may disclose your Information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

      3. Third Party Service Providers. We may share your Information with third party vendors, service providers, contractors or agents who perform services and require access to such information to do that work. Examples include: data analysis, email delivery, hosting services, customer service, marketing efforts and professional services (including consultancy, banking, legal, insurance and accounting services). They will only have access to your Information to the extent that they need to perform those services. They are required to keep your Information confidential and may not use it other than as we ask them to and always in accordance with this Policy.

      4. Business Transfers. We may share or transfer your Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

      5. Business Partners. Provided you have given us Consent to do so we may share your Information with our business partners to offer you certain products, services or promotions.

      6. With your Consent. We may disclose your Information for any other purpose with your Consent.

    2. We may disclose anonymous information (i.e. information from which you cannot be personally identified), or insights based on that anonymous information, to selected third parties, including (without limitation): (a) our parent company SALAD PROJECTS LIMITED (Salad Projects) (company number 10988702), which passes that information on to the University of Edinburgh and NHS Trusts, to enable research into the financial resilience of NHS employees and to inform policy making for those responsible in employee financial health and well-being; and (b) analytics and search engine providers to assist us in the improvement and optimisation of the Service. In these circumstances we do not disclose any information which can identify you personally.

  7. Retaining your Information
    In summary: : We keep your Information for as long as necessary to fulfil the purposes outlined in this Policy unless otherwise required by law.
    1. We will only keep your Information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). We may retain such records for up to 12 months. If you cancel your account with us, these statutory records will be archived, and all other information will be deleted.

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

    1. Where we anonymise your personal data (i.e. so that it can no longer be associated with you) for further research or statistical purposes, then we may use this information indefinitely without further notice to you.

  8. Keeping your Information safe
    In summary: We aim to protect your Information through a system of organisational and technical security measures.
    1. We have implemented appropriate technical and organizational security measures designed to protect the security of any Information we process. However, please also remember that we cannot guarantee that the Internet itself is 100% secure. Although we will do our best to protect your Information, transmission of personal information to and from the Website is at your own risk. You should only access our Website and/or the Services within a secure environment.

  9. Lower age limit
    In summary: We take steps to ensure that the Service is only used by those over 18 years of age and we do not knowingly collect data from or market to children under 18 years of age
    1. We do not knowingly solicit data from or market to children under 18 years of age. By using the Service, you represent that you are at least 18 years of age. If we learn that Information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at general@saladmoneymind.co.uk

  10. Your Consent to processing
    1. You will be required to give Consent to certain processing activities before we can process your Information. Where applicable, we will seek Consent from you when you first submit Information to or through the Service.

    2. If you have previously given your Consent you may freely withdraw your Consent at any time. You can do this by emailing general@saladmoneymind.co.uk

    3. If you withdraw your Consent, and if we do not have another legal basis for processing your Information, then we will stop processing your Information. If we do have another legal basis for processing your Information, then we may continue to do so subject to your legal rights.

    4. Please note that if we need to process your Information in order for you to use the Service and you object or do not provide Consent to us processing your Information, the Service will not be available to you.

  11. Marketing and opting out
    1. If you have given Consent to marketing we may contact you about our products, services, promotions and special offers. If you no longer wish to receive this information you can withdraw your Consent at any time by sending an email to general@saladmoneymind.co.uk or unsubscribe from the communications.

    2. If you have given Consent, we may share your Information with carefully selected third party organisations and business partners and they may contact you directly. If you prefer not to receive direct marketing communications from the third party please contact them directly to withdraw the Consent.

    3. Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.

  12. Account information
    1. You may at any time review or change the information in your account by logging into your Money Mind account.

    2. If you wish to terminate your Money Mind account please contact us via general@saladmoneymind.co.uk and we can arrange this for you. Some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms and/or comply with legal requirements.

  13. Your privacy rights
    In summary: You have certain rights in respect of your Information.
    1. You have certain rights in relation to the Information that we hold about you. Details of these rights and how to exercise them are set out below. Please note we will require evidence of your identity before we are able to respond to your request. This is a security measure to ensure that your Information is not disclosed to a person who does not have the right to receive it. We may also contact you to ask you for further information in relation to your request to speed up your response. To exercise or discuss any of your rights please contact us at general@saladmoneymind.co.uk.

      • Right of Access. You have the right at any time to ask us for a copy of the Information that we hold about you and to check that we are lawfully processing it. Where we have good reason, and where data protection law permits, we can refuse your request for a copy of your Information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.

      • Right of Correction or Completion. If Information we hold about you is not accurate or is out of date and requires amendment or correction you have a right to have the data rectified or completed.

      • Right of Erasure. In certain circumstances, you have the right to request that the Information we hold about you is erased e.g. if the Information is no longer necessary for the purposes for which it was collected or processed or our processing of the Information is based on your consent and there are no other legal grounds on which we may process the Information.

      • Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your Information. For example, if we are processing your Information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You may also have the right to restrict our use of your Information, such as in circumstances where you have challenged the accuracy of the Information and during the period where we are verifying its accuracy.

      • Right of Data Portability. In certain instances, you have a right to receive your Information that we hold about you in a structured, commonly used and machine-readable format. In such circumstances, you can ask us to transmit your Information to you or directly to a third party organisation. While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation’s systems. We are also unable to comply with requests that relate to personal information of others without their consent.

    2. If we are relying on Consent to process your Information, you have the right to withdraw your Consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

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