Last updated 23rd November 2020
Thank you for choosing to be part of our community at Lean App Limited, doing business as Lean (“Lean”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please do not hesitate to contact us at email@example.com.
1. What information do we collect?
1.1 Personal information you disclose to us
We collect personal information that you provide to us such as name, email address, contact information, passwords and security data, payment information, and social media login data.
We collect personal information that you voluntarily provide to us when registering at the Sites or Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites or Apps or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Sites or Apps, the choices you make and the products and features you use. The personal information we collect can and may include the following:
Name and Contact Data. We collect your first and last name, email address and potentially your social media contact data if you choose to sign up to our app through third party social media login.
Credentials. We collect passwords and similar security information (such as Touch ID) used for authentication and account access.
Payment Data. We collect data necessary to process your payment if you make purchases through Apple / Android Pay channels. All payment data is not stored by us, but by third parties beneficiaries such as: Apple pay, Android pay or Stripe. You should review those third party privacy policies and contact the payment processor directly to respond to your questions.
Social Media Login Data. We provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called "How do we handle your social logins" below.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
1.2 Information automatically collected
Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Apps.
We automatically collect certain information when you visit, use or navigate the Sites or Apps. 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 our Sites or Apps and other technical information. This information is primarily needed to maintain the security and operation of our Sites or Apps, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
1.3 Data we receive from third parties
We use a range of third parties to collect data necessary for the functioning of our App / Services.
We use the third party TrueLayer to provide us with your banking transaction data. We do not store your banking login or passwords, nor do we store your full transactional data. We do store data related to your subscriptions and recurring payments, which we collect from the transactional information provided by TrueLayer.
We use Google Firebase for database sorting services and data storage protection. The database is both server-side encrypted, and client-side encrypted thanks to Google Cloud Key Management.
For more information on how these companies handle your personal data, please refer to their privacy policies. We rely upon your explicit consent to use and process the data described above.
1.4 Information collected through our Apps
If you use our Apps, we may also collect the following information:
· Subscription Payments. From the third party TrueLayer, we trace subscriptions and recurring payments from your designated bank accounts to uncover and display what you are currently paying for. We do not store your bank data, or your total transactional information. However, we do store the subscriptions recovered from our algorithms to provide you with our range of services related to subscription cancellation.
· Transaction data. From the third party TrueLayer, we trace some additional transactional information from your designated bank accounts to uncover insights that we believe enable us to provide value to users. We do not store your bank data, or your total transactional information. However, we do store the necessary transactional information to provide you with our range of financial insight services.
· Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off through the in-app settings.
1.5 Information collected from other sources
We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).
2. How do we use your information?
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.
We use personal information collected via our Sites or Apps for a variety of business purposes described below. We process your personal 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.
We use the information we collect or receive:
· To facilitate account creation and log-in process. If you choose to link your account with us to a third-party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below headed "How do we handle your social logins" for further information.
· To fulfill and manage your services.
· To enforce our terms, conditions and policies fairly and accurately to our customers.
Meeting international, regional or domestic requirements norms. To respond to legal requests and prevent harm. If we receive a legal request, we may need to inspect the data we hold to determine how to respond.
3. How We Secure Your Data
All of your personal information is protected and we have put in place appropriate physical, electronic, and management procedures to safeguard and secure the data we collect. Your information is stored on secure cloud databases, internal servers, and on third party software. Your information is only accessible by employees who have authorised access rights to encrypted information. All of your payment information is encrypted using SSL technology. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites or Apps is at your own risk. You should only access the services within a secure environment and not a vulnerable one, or open public for security measures.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We use third parties such as TrueLayer for access to banking data and Google Firebase for data storage and protection.
Your information will not be shared with unwarranted third parties.
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.
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.
4. Do we collect information from minors?
We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites or Apps, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites or Apps. If we learn that personal 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 our Data Protection Officer (DPO) at: firstname.lastname@example.org.
5. What are your privacy rights?
Under the GDPR, you have the right to:
· Withdraw your consent to the processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so (such as to comply with a legal obligation).
· Be informed of what data we hold and the purpose for processing the data, as a whole or in parts.
· Be forgotten and, in some circumstances, have your data erased by ourselves and our affiliates (although this is not an absolute right and there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it).
· Correct or supplement any information we hold about you that is incorrect or incomplete.
· Restrict processing of the information we hold about you (for example, so that inaccuracies may be corrected—but again, there may be circumstances where you ask us to restrict processing of your personal data but we are legally entitled to refuse that request).
· Object to the processing of your data.
· Obtain your data in a portable manner and reuse the information we hold about you.
· Challenge any data we use for the purposes of automated decision-making and profiling (in certain circumstances—as above, there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request).
· Complain to a supervisory authority (e.g. the Information Commissioner’s Office (ICO) in the UK) if you think any of your rights have been infringed by us. (We would, however, appreciate the chance to address your concerns, so please contact us prior to taking this step).
You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive or our practice. Alternatively, we may refuse to comply with your request in these circumstances or in exceptional measures of force majeure.
If you would at any time like to review or change the information in your account or terminate your account, you can:
· Log into your account settings and update your user account.
· Contact us by email at: email@example.com or by phone at: 0203 887 4546.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default.
If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites or Apps.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:
· Note your preferences when you register an account with the site.
6. How do we handle your social logins?
If you choose to register or log in to our websites using a social media account, we may have access to certain information about you.
Our Sites or Apps offer you the ability to register and log-in using your third party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address as well as other information you choose to make public.
7. How long do we keep your information?
Any data related to your bank account will be deleted after 3 months. We are a one time use service, as such, we do not need to keep your sensitive data once the service has been completed. We will give you a 3 month window before automatically deleting any information relating to your bank data. Equally, you have the right to delete that data at any time simply by clicking the "Remove" button next to each individual bank account.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize 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 or complete removal is possible.
8. Complaints Policy
If a user wishes to make a complaint with regards to Lean App Limited services and or data handling, the user can contact us at the following email: firstname.lastname@example.org.
Users should provide their: Name, Email address, and a description of the complaint. At Lean App Limited, we guarantee a response to your complaint within 15 working days. This is following the current practice from the Financial Conduct Authority (FCA) and the Financial Ombudsman Service (FOS), both pointing to an appropriate clear 15 days limit.
9. Do we make updates to this policy?
Yes, we will update this policy as necessary to stay compliant with relevant laws.
10. How can you contact us about this policy?
If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Luke Dugdale, by email at email@example.com, or by phone at - 0203 887 4546, or by post to:
64 Nile Street
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please see section 9- “How to Contact us” in this privacy notice. We will respond to your request within 30 days.