By using the SnoopSpace forum you agree to our privacy policy below. We use a platform provided by a company called Discourse to host this forum - you can take a look at their privacy policy here .

We might update this Privacy Policy occasionally, but the latest version will always be available here.

Snoop Privacy Policy

We are Usnoop Limited (“Snoop”, “we”, “us” or “our”), and Snoop is a robot friend for your money that does three key things for you when you register with the Snoop App:

• Snoop organises your finances so you can see all your different online bank accounts, savings accounts and credit cards in our App, meaning you can always see where you are with your money. We do this by using technology to communicate with your third-party bank account providers in a secure way.
• Snoop automatically checks how much you are being charged for things by the banks and big businesses you deal with. If Snoop thinks you’re being taken advantage of, you’re overpaying for something, or it thinks there’s something you should know that will benefit you, Snoop will send an alert to tell you.
• Snoop scours the web, looking for super-smart ideas that it thinks could save you money, or help you more generally. Snoop will create a personalised list of these ideas just for you and communicate it to you. If Snoop finds any ideas that it thinks are particularly important, Snoop will send an alert to tell you.

We are constantly developing and improving the Snoop App, so we will also tell you about new features of Snoop that we’ve launched that you might not be aware of, as well as telling you about features of Snoop that we can see you’ve not used.

We recognise everyone will want something different from Snoop – so that’s why Snoop has been built to learn from each user, so we can provide you with a customised experience that will be the most help for you.

How does Snoop do that? Through the secure processing of your personal data. Without access to your personal data, and the right to process it as required and set out in this Privacy Policy, Snoop cannot perform the function for you that it has been designed for. Your privacy and security are our number one priority, and your data always is protected by bank grade security. This Privacy Policy sets out how and on what basis we collect information about you, and the ways in which you and your data are protected when your use our website and Snoop app.

To find out exactly what that means, read on to learn about our data protection principles and how we use your data. Before we get to that, please be aware that Snoop is a data controller of the personal data that you provide to us or that we collect. ‘Data controller’ refers to a company that collects or stores personal data and has the decision-making power to decide what to do with that personal data.

Please read this Privacy Policy carefully to understand how we handle your personal data. By engaging with us in the ways set out in this Privacy Policy, you confirm that you have read and understood the whole of this Privacy Policy, as it applies to you.

You have the right to object : You have various rights in respect of our use of your personal data as set out in the ‘Your Key Rights’ section below. The fundamental right to be aware of is that you may ask us to consider any valid objections which you have to our use of your personal data where we process your personal data on the basis of our, or a third party’s, legitimate interest.

What this Privacy Policy contains

• A summary of our data protection principles
• What personal data do we use and how do we use it?
• Cookies
• Personalised advertising
• Our legal basis for using your personal data
• Your key rights
• Where do we store your personal data?
• Protecting your personal data
• Who we share your personal data with
• How long do we keep your data?
• Using computers to make decisions about you
• Communicating the benefits of Snoop
• Links to other websites
• Children
• Our contact details
• Complaints to the Information Commissioner’s Office (ICO)
• Changes to our Privacy Policy

A SUMMARY OF OUR DATA PROTECTION PRINCIPLES:

Privacy and security are at the very heart of Snoop:

• We strongly protect and secure the personal data we hold about you.
• We will only use your personal data to allow us to deliver you our services.
• Where we track your use of our app and website, we do this to continuously improve and personalise your experience.
• Where we reuse your personal data, we do so to avoid asking you the same data twice.
• We may use suppliers to help us deliver our service, but we restrict their use of data to what you allow us to do and bind them to European data protection rules and to strict confidentiality. For more information, see the ‘Who we share your personal data with’ [ LINK ] section below.

Where you choose to use services provided by our partners on Snoop (for example, if you want to switch a subscription service like gas and electricity where we’ve identified you may be overpaying), they may receive relevant data about you, but this will only be done in accordance with our Terms (TO ADD LINK) and when it is clear to you what has been shared and for what purpose.

You are always in control:

• You decide whether to connect banks and other companies to our app or not. If you choose not to do that, there are other ways we can help you.
• You can disconnect a bank at any time in the Snoop app to stop data exchange with them. This will remove all data we have received from them from the Snoop app.
• You have the right to be forgotten: You can close your Snoop account through the app. We will then anonymise and archive all data we have about you 12 months later (we keep this data for 12 months in case of any subsequent queries and for audit requirements, unless you ask us to delete it immediately following closure which you can do by sending us an email at privacy@snoop.app
• You decide which Snoop partner services you use. If you disconnect a partner any data exchange with them will stop.
• Any data that a partner has received will still be available to that partner. You should request deletion of that data and your right to be forgotten directly with them if you want this to happen.

With an understanding of these two principles, it’s important that you recognise that the use of your personal data to personalise your app experience and to deliver you targeted insights that aim to help you is an integral part of the Snoop service that we offer to you as outlined in our Terms, and cannot be switched off. If you would prefer we did not use your personal data in this way then you should not use the Snoop service.

WHAT PERSONAL DATA DO WE USE AND HOW DO WE USE IT?

What do we mean when we say ‘personal data’?

Personal data is any data relating to a person who is identified or who can be identified from the data itself (so it would include things like a name, an identification number, or an online identifier).

You may give us personal data by interacting with the Snoop app, by visiting our website, or by corresponding with us.

We (or third parties on our behalf) may collect and use any of the following categories of personal data about you:

• Registration Information – mobile number, email, and preferred name.
• Account Information – information about connected accounts (for example provider name, product type, account numbers, sort codes) as well as the account held with Snoop (for example, account status, security data, preferences).
• Transactional Information – information about transactions and balances from connected accounts as well as any manually entered by you.
• Additional Personal Information – location (if permission given), address, postcode, device details, interaction tracking data and data customised by you (e.g. tags, updated categories), supplementary information we may ask you from time to time (for example, whether you are a student).
• Technical Information – your IP address and general processing or monitoring data for performance and technical purposes
• Contact Information – messages or emails you send us as well as any comments you may choose to make in the Snoop Family Forum.
• Unique Customer Identifier – a reference number which relates to you as an individual.
• Mandatory Information – data we’re obliged to keep for the purposes of Financial Conduct Authority (FCA) reporting or audit (e.g. complaints).

We use the above personal data for the following purposes:

As part of your Account Information, when we process your banking transactions we may process ‘special categories of personal data’. For example, if you have a payment for a membership to a particular political party, this could reveal your political beliefs. Other banking transactions you have made could contain data about your racial or ethnic origin, political opinions, philosophical beliefs or trade union membership, as well as health data or data concerning your sex life or sexual orientation. We will only use this data in strict accordance with the law and where you have made such data available to us and we will never use it for any other purpose (for example profiling or tailoring of our service).

COOKIES

Snoop uses cookies and similar technologies to provide the functionality of our website and app, to improve our website and app, and to personalise our website and app. For more information about cookies, please read our Cookie Policy [ LINK ].

PERSONALISED ADVERTISING

We also use personalised online advertising to tell you about our app and our products and services. This means that you may see advertising for our app, products and services when you are on other third-party websites, including social media platforms.

We use the Facebook Pixel on our website and app, which is triggered when you engage with one of our ads on Facebook. When you click on a Facebook ad and are redirected to our website or app, the Facebook Pixel tracks your behaviour on our website or app and if you take an action, the Facebook Pixel will report it to us. This allows us to measure the effectiveness of our Facebook ads for statistical and market research purposes and helps us target our ads.

Using the Facebook Pixel, the ads you see are personalised whilst you are using Facebook, through Facebook’s Custom Audiences tool. When you browse our website and app, information about your browsing session, along with a hashed version of your Facebook ID and the URL viewed, is sent to Facebook. When you then use Facebook, you will be shown personalised ads based on your experience whilst using our website or app.

You can find out more about how Facebook processes your personal data in its Data Policy here: https://www.facebook.com/about/privacy

You can opt-out of the collection of your personal data by Facebook Pixel, or to the use of your personal data for the purpose of displaying Facebook ads using Custom Audiences using this link or this link.

The Facebook Pixel and Custom Audiences are an offer from Facebook Inc., which is headquartered in the USA. Facebook Inc. has been certified under the EU-US Privacy Shield that has been approved by the European Commission. A current certificate can be viewed here: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active

We may use and support one or more Google tools, including Google Analytics (including Universal Analytics), Google AdWords (including Smart Pixel), Google Developer Console, Google Displaying Advertising and Google Customer Match which may include one or more of the following features:

• remarketing;
• Google Display Network Impression Reporting;
• the DoubleClick Campaign Manager integration; and
• Google Analytics Demographics and Interest Reporting.

We use these tools to better understand you and our other customers, to deliver personalised online advertising to you and others like you on Google properties (such as YouTube and Google Maps), and to measure the effectiveness of our Google ads for statistical and market research purposes so that we can better target our ads. Some of these tools also use cookies, so please see our Cookie Policy for further details [ LINK ].

You can opt-out of Google advertising by visiting the Google Ads Settings page.

OUR LEGAL BASIS FOR USING YOUR PERSONAL DATA

We consider the legal bases for using your personal data as set out in this Privacy Policy are as follows:

A. Contractual performance : If you download our app and want us to deliver you our services as outlined in our Terms [ LINK ], we can only perform these services if we can process your personal data for this purpose. Therefore, most of our processing of your personal data is necessary to perform the contract we have in place with you, as outlined in the ‘What personal data do we use and how do we use it?’ [ LINK ] section above.

Please be aware that if you do not want us to process your personal data for most of the purposes set out above, then we cannot deliver our services to you through the Snoop app. Without the use of your data there is no benefit to the Snoop app and so if you don’t wish your personal data to be processed in this way, then you shouldn’t use the Snoop app.

B. Legal obligations : We will also process your personal data where we are under a legal obligation to do so to. For example, to:

Prevent and detect fraud, money laundering, other crime, and security issues.

Comply with laws and regulations, as well as any sector-specific mandatory guidelines and regulations.

C. Legitimate interest : Where neither (A) nor (B) apply, we use your personal data on the basis of our legitimate interest, or the legitimate interests of others. Our legitimate interests are to:

• understand our user demographic, preferences and behaviours so we can improve the relevance of Snoop to individual customers;
• track the use of the Snoop app and website and identify areas where we can improve performance or functionality (business and technical);
• keep going as a business and continue to provide a free service, which means we may sell aggregated market research, from which all personal data is removed, in return for revenue;
• to help us grow and develop our business and help our customers with the account opening process;
• operate our website and app generally;
• carry out marketing, market research and business development;
• provide services to our customers;
• invest in and roll out new services to benefit our existing customers and to attract new customers; and
• for business purposes.

D. Consent : If we rely on your consent for us to use your personal data in a particular way, but you later change your mind, you may withdraw your consent by contacting us at privacy@snoop.app and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide our app and associated services to you.

YOUR KEY RIGHTS

You have the following rights in relation to your personal data:

Right to object: You have a right to ask us to consider any valid objections which you have to our use of your personal data where we process your personal data on the basis of our or a third party’s legitimate interest.

Right of access: All data that you have provided to us is accessible in the app. You can request a copy of all personal data you have provided us through the app or by sending us an email from the email address you use for your Snoop account. We can only give you the data we hold ourselves. Any data that a partner holds about you is with that partner. You should request access to that data directly with them. We will help you where we can.

Right to data portability: You have a right to ask us to provide your personal data to a third-party provider of services.

Right to rectification: You can control your data through the app. Where you cannot change this data through the app, you have the right to ask us to rectify inaccurate or incomplete personal data which we have about you.

Right to erasure: You have the right to ask us to erase your personal data. You can close your Snoop account through the app. We will then anonymise and archive all data we have about you 12 months later (we keep this data for 12 months in case of any subsequent queries and for audit requirements, unless you ask us to delete it as soon as possible following closure which you can do by sending us an email at privacy@snoop.app). Be aware that the partners you have used may still have data about you. You will need to contact them directly in order for them to delete this data.

Right to restrict use of your personal data: You have a right to ask us to restrict the way that we process your personal data in certain specific circumstances. We will also pass your request onto other recipients of your personal data unless that is impossible or involves disproportionate effort.

If you wish to exercise any of the rights set out above, please contact us through the Snoop app or email us at privacy@snoop.app. We aim to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.

Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.

WHERE DO WE STORE YOUR PERSONAL DATA?

Your data is stored in Europe: The personal data we collect from you is stored on secure computer systems located in the European Economic Area.

Partners are bound by the same European data protection rules as we are, but partners could decide to store your data in other countries or parts of the world than we do. That is not in our control and we recommend you read carefully their privacy policies. Upon connection to a partner, the partner or our app will give you easy access to these privacy policies.

PROTECTING YOUR PERSONAL DATA

We are committed to ensuring that your personal data is secure.

In order to prevent unauthorised access to, or disclosure of, your personal data, we have put in place suitable physical, electronic and operational procedures to safeguard and secure It. For example, we protect your personal data by deploying SSL and high standard encryption algorithms.

We also ensure that we meet security standards imposed by law that are applicable to the operation of Snoop.

Help us help you: to help us protect your personal data, you should comply with our security policies and procedures that we may notify you about in our Terms from time to time.

WHO WE SHARE YOUR PERSONAL DATA WITH

Partners

We may use your personal data to enable you to use or purchase the products or services of our partners.

You are in control:

• We only share your personal data where you have requested to connect a partner.
• Only after receiving such a request will we disclose or prefill your personal data to those third parties so that they can provide their services to you and give you a smooth user experience.
• We won’t disclose more than is needed for the products and services of that partner.

Please remember that the use of your data by our partners will be governed by their terms and conditions and their privacy policy – we do not control this.

Also remember that you can always de-activate a partner. This will stop any data exchange but be aware that a partner could retain certain personal data about you that has been exchanged before.

If you want a partner to delete your data, then you should contact them directly.

Providers, Regulators and Law Enforcement

Other than what is described above, we will only share your personal data in a very limited way. This will happen either where we need to use services, we cannot build ourselves or have a duty or legal obligation to disclose it.

We may share your personal information with:

• Our service providers (including their sub-contractors). This may happen where they help us to run our service or the technology systems that are needed to operate our website, app and services. This includes:
  • Data storage providers to safely and securely store your data.
  • Bank data providers who sit between us and your bank and aggregate your account information and pass it over to us at your request so it can then be used in our app.
  • Companies that assist us in our marketing, advertising and promotional activities, such as to help us with our mobile marketing and to track, measure and analyse the success of our marketing.
  • Social media platforms (for further details, see the ‘Personalised Advertising’ section above) so that we can provide relevant content to you (and others like you) on social media.
  • Social media management service providers that help us form relationships with new customers and deepen our relationship with existing customers like you.
  • Customer relation management providers to provide you with customer support services.
  • Forum providers to enable us to invite you to enable you to participate in group conversations about the Snoop service.
  • Website and app analytics providers that enable us to give you the best experience when using our website and app.
• Regulators in connection with their duties.
• Fraud prevention agencies and law enforcement agencies, where we’re required to help them do their job.

HOW LONG DO WE KEEP YOUR DATA?

We are only allowed to keep your personal data for as long as it’s still necessary for the purpose we initially required it. Where we no longer need your data to allow us to perform our service, we delete or anonymise it.

USING COMPUTERS TO MAKE DECISIONS ABOUT YOU

Snoop is designed to process your personal data to make suggestions designed to save you money, or help you manage your life more effectively. We store information about you on our systems in order to make decisions on what products and services to suggest to you.

We do not currently use automatic processing or profiling to make automated decisions about you that could significantly impact you (like refusing you financial products or credit profiling). If this ever changes in future, we will let you know.

COMMUNICATING THE BENEFITS OF SNOOP

We want to share the benefits that Snoop can bring to all UK consumers, so the data we collect might be used anonymously in communications such as:

• Blog posts and infographics
• Emails
• Social media posts
• Marketing campaigns

Any data we use in support of the above is always anonymised and aggregated and can never be tracked to you personally.

LINKS TO OTHER WEBSITES

Our app contains hyperlinks to and from the websites of our partners and other third parties. Any hyperlinks we provide are there to help you access the services of our partners and are for your reference and convenience only. They don’t imply any endorsement of the activities of those third-party websites or any association with their operators. This Privacy Policy only applies to the personal data that we collect or which we receive from third party sources, and we aren’t responsible for personal data about you that is collected and stored by third parties. Third-party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal data to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of third-party websites or third-party terms and conditions or policies.

CHILDREN

You must be aged 16 or over to use our Snoop service. Our website and app are not directed at children under the age of 16 and we do not knowingly collect any personal data from visitors in this age group.

If you are under the age of 16 and we learn that we have inadvertently obtained personal data from you from our website, app, or from any other source, then we will delete that information as soon as possible.

Please contact us at privacy@snoop.app if you are aware that we may have inadvertently collected personal data from a child under the age of 16.

OUR CONTACT DETAILS

Snoop is a registered trademark of Usnoop Limited. Our registered office is Usnoop Ltd, 10 Norwich Street, London, United Kingdom, EC4A 1BD.

If you have any questions about our privacy policy or our collection, use or storage of your personal data, please send an email to privacy@snoop.app

COMPLAINTS TO THE INFORMATION COMMISSIONERS OFFICE (ICO)

You have the right to complain to the ICO if you believe we might have broken data protection rules.

The ICO can be contacted at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 0303 123 1113 (local rate) or 01625 545 745. Email: {to be added}

CHANGES TO OUR PRIVACY POLICY

We may update our Privacy Policy from time to time. Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, provided to you by email or in another appropriate manner.

COOKIE POLICY

What cookies are used by Snoop?

Snoop uses third-party cookies (meaning the cookies are provided by third parties and are not proprietary to Snoop) to track when you visit our app or website and what you look at. By understanding which areas of our app or website are the most popular and where visitors spend their time, we can improve the performance for everyone.

We also use third-party cookies to allow us to:

• Find out whether our advertising encourages people to download our app or visit our website.
• Show you advertising and content relating to Snoop. For example, if you visit snoop.app and look at a page giving information about being part of our beta launch but don’t sign up, we could use cookies to show you advertising in the future to remind you about Snoop, as it may be something you’re interested in.

The table below shows the third-party cookies Snoop uses and why we use them:

Tracking (Third Party Cookies)

Advertising (Third Party Cookies)

In relation to our website, you can turn off or manage your cookie preferences at any time here. You can also delete cookies if you would like to by using your browser or mobile phone settings.

If you turn off or delete cookies you may still see advertising for Snoop but these adverts will be general and not tailored to you based on your visits to snoop.app.

Snoop Privacy Policy - Version 1:0 December 2019