Frequently Asked Questions
Sente Limited ( we or us ) are committed to protecting and respecting your privacy.
1. SCOPE OF POLICY
1.1 This policy together with the General Terms of Service and our Business Terms of Service and our Business Terms (as applicable) apply to your use of:
- a) our website at Pay24 (the " Site") including, without limitation, the Sente Dashboard available to Sente Dashboard Users pursuant to the Business Terms;
- b) the Sente Mobile App ( App ) once you have downloaded a copy of the App onto your mobile telephone or handheld device ( Device ); and
- c) any of the services accessible through the App or the Site (the Services ).
1.2 This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
2. INFORMATION WE COLLECT FROM YOU
2.1 We will collect and process the following data about you:
- a) Information you give us (Submitted information): This is information you give us about you by filling in forms on the App and/or the Site, or by corresponding with us (for example, by e-mail or via the chat functions on the App and/or the Site). It includes information you provide when you register to use the App, download or register the App, subscribe to any of our services, enter into any transaction on the App or the Site (such as a Top Up, Instant Transfer, Sente Bank Transfer, Electronic Money Exchange), participate in discussion boards or other social media functions on the App or the Site, enter a competition, promotion or survey and when you report a problem with an App, the Services, or the Site. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, address, date of birth, e-mail address, phone number, the Device's phone number, username, password and other registration information, financial, details of your bank account including the bank account number, bank sort code, IBAN, details of your debit and credit cards including the long number, relevant expiry dates and CVC, identification document numbers, copies of identification documents (for example, passport, driving licence and utility bill) personal description and photograph and any other information you provide us in order to prove your eligibility to use our services.
- b) Information we collect about you and your device. Each time you visit the App or our Site we will automatically collect the following information:
- (i) technical information, including the internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information and the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting (Device Information);
- (ii) information about your visit, including the full uniform resource locators (URL), clickstream to, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, device information and any phone number used to call our customer service number;
- (iii) transaction information including date, time, amount, currencies used, exchange rate, beneficiary details, details and location of the merchant or ATMs associated with the transaction, IP address of sender and receiver, sender's and receiver's name and registration information, messages sent or received with the payment, device information used to facilitate the payment and the payment instrument used.
- (iv) information stored on your Device, including if you allow Sente access contact information from your address book, login information, photos, videos or other digital content, check ins (Content Information). The App will periodically recollect this information in order to stay up-to-date;
- (v) details of your use of our App or your visits to our Site including transaction details relating to your use of our services, including who you have sent money or electronic money to, foreign exchange transactions you have entered into, the time, date and location of the place the transaction was entered into.
- c) Location information. We use GPS technology and your IP address to determine your location – this may be used when the App is running in the foreground and the background of your Device. This is used to prevent fraud, for instance if your mobile phone is saying that you are based in the UK but your card is being used to enter into an ATM Withdrawal or point of sale purchase in Spain, we may not allow that transaction to be processed. Our card protection and fraud-prevention measures require this personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by de-selecting "location based security" on the Card Security part of the App
4. USES MADE OF THE INFORMATION
4.1 We use information held about you in the following ways:
(a) Submitted Information: We will use this information:
- to carry out our obligations arising from any transactions you enter into with us, for example Top Ups, Instant Transfers, Sente Bank Transfers, Electronic Money Exchanges, ATM Withdrawals and Sente Card Purchases and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you.
- to verify your identity to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our products and services;
- to notify you about changes to our service;
- to facilitate social interactions through our services and to make you aware if any of your contacts who are Sente Users and have location services enabled, are in the same area as you; and
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
(b) Device Information: We will use this information:
- to administer our Site and the App for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our Site and the App to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our Site and the App safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our Site and the App about goods or services that may interest you or them;
- to verify your identity, protect against fraud, comply with anti-financial crime laws and to confirm your eligibility to use our products and services; and,
- to comply with our regulatory obligations.
c) Location Information: We will use this information:
- to deliver relevant advertising to you, for example, information on nearby merchants;
- to protect against fraud; and
- to make you aware if any of your contacts, who are Sente Users and have location services enabled, are in the same area as you.
d) Third Party Information: We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information:
- to help us better understand your financial circumstances and behaviour so that we may make decisions about how we manage your Sente Account;
- to process applications for products and services available through us including making decisions about whether to agree to approve any applications;
- for the purposes set out above (depending on the types of information we receive).
4.2 We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined. 4.3 We do not disclose information about identifiable individuals to our advertisers, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We will use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
5. DISCLOSURE OF YOUR INFORMATION
5.1 We will disclose the data we collect from you to the following third parties:
- a) business partners (including banking partners and banking intermediaries), suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- b) advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience;
- c) analytics and search engine providers that assist us in the improvement and optimisation of our site;
- d) third parties to verify your identity, protect against fraud, comply with anti-money laundering laws and to confirm your eligibility to use our products and services; and,
- e) credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you. 5.2 You agree that we have the right to disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006. 5.3 We will disclose your personal information to third parties:
- a) In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- b) If Sente Limited or substantially all of its 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.
- c) If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
- d) In order to:
- (i) enforce or apply the Standard Terms and/or the Business Terms and/or any other agreements between you and us or to investigate potential breaches; or
- (ii) protect the rights, property or safety of Sente Limited, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6. WHERE WE STORE YOUR PERSONAL DATA
7. YOUR RIGHTS
7.1 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us using the chat function on the App or the Site. 7.2 Our App and our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
8. ACCESS TO INFORMATION
8.1 The Data Protection Act 1998 gives you the right to access information held about you. Your right of access can be exercised in accordance with that Act. Any access request will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you. 8.2 You can access some of the information we hold about you on the App or the Site by visiting the relative page on the App or the Site. On these pages, you may edit the information we hold about you. For security reasons, you will not be able to change all the information we hold about you on the App and the Site. If you wish to change or delete information we hold about you which you cannot edit or delete from the App or the Site, please contact our customer support via the chat function on the App or the Site.