Customer Privacy Notice

1. About us

 

Ocean Money AG  (Ocean Money, the company or we,or us) is a financial services technologyplatform. We are a company registered in Switzerland under numberCHE-174.263.521 whose registered office is at Gubelstrasse 24 Zug, ZUG, 6300Switzerland. The company is known as the ‘controller’ of your personal data.

2. Why doI need to read this notice?


We collect your personal data when you use:

- our website at www.ocean.money

- the Ocean Money app

- any of the services available to you through the Ocean Money or website

We may also collect your personal data from other people or companies. We explain how this can happenin more detail in the What personal data do you collect aboutme?  section below.

When we say ‘personal data’, we mean information which:

- we know about you (for example, we know when you use your Ocean Money card to pay for things)

- can be used to personally identify you (for example, a combination of your name and postal address)

This notice explains what information we collect, how we use it, and your rights if you want to change how we useyour personal data.

If you have concerns about how we use your personal data, you can contact ourdata protection officer at [INSERT DPO EMAIL HERE].

3. What personal data do you collect about me?


The table below explains what personal data we collect and use.

Type of personal data

Details

Information you give us

We collect  information you provide when you:

·       fill in any forms

·       correspond with us

·       respond to any of our surveys

·       register to use the Ocean Money  app

·       open an account or use any of our services

·       give us access to your other  financial accounts (for example, through Open Banking)

·       take part  in online discussions or promotions

·       speak with a member  of our social  media or customer support teams  (either on the phone or through the Ocean  Money app)

·       enter a competition or share information with us on social media

·       contact us for other reasons

·       We will collect the following information:

·       your name, address, and date of birth

·       your email  address, phone number  and details of the device  you use (for example, your phone, computer or tablet)

·       your Ocean  Money username

·       your registration information

·       details of your bank account, including the account number, sort code and IBAN

·       details  of your Ocean Money debit cards and credit cards (or other debit or credit  cards you have registered with us) including the card number, expiry date and  CVC (the last three digits of the number on the back of the card)

·       copies  of your identification documents (for example, your passport or driving  licence) and any other information you provide to prove you are eligible to  use our services.

·       your  country of residence, tax residency information, and tax identification  number

·       information  you provide when you apply for credit, including details about your, or your  spouse’s, income and financial obligations.

·       records  of our discussions, if you contact us or we contact you (including records of  phone calls)

·       your image in photo or video form (where required as part of our Know-Your-Customer (KYC) checks, to verify your identity if you contact us when logged out of your  Ocean Money account, or where you  upload a photo  to your Ocean Money account)

Information collected

from your use of our  products and services

Whenever you use our website or the Ocean Money app, we collect the  following information:

·       technical information, including the internet protocol (IP) address used to connect your computer to the internet, your login information, the browser type and version, the time zone  setting, the operating system and platform,  the type of 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 and the type of mobile  browser you use

·       information about your visit, including the links you’ve clicked on, through and from our  website or app (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

·       and clicks), and methods used to browse  away from the page

·       information  on transactions and your use of our  Ocean Money products (for example,  payments into and out of your account), including the date, time,  amount, currencies, exchange rate, beneficiary details, details of the merchant  or ATMs associated with the transaction (including merchants’ and ATMs’  locations), IP address of sender and receiver, sender's and receiver's name and registration information, messages sent or received, details of device used  to arrange the  payment and the  payment method used

·       information stored  on your device,  including if you give us access to contact information from your contacts list.  The Ocean Money app will regularly collect this information in order to stay up to date (but only if you have given  us permission)

Information about your  location

If you turn location services on in the Ocean Money app, we track your location using

GPS technology.

Information from others

We collect  personal data from  third parties or other people, such as credit

reference agencies, financial or credit institutions, official registers and

databases, as well as joint account holders, fraud prevention agencies and

partners  who help us to provide our services.

This includes your credit record,  information about late payments,  information

to help  us check your  identity, information about  your spouse and family  

(if applicable in the context of an application for credit that you make) and

information relating to your transactions.

When you ask us to, we’ll  also collect personal data from accounts you hold with third  party financial institutions (when you create  a linked account by activating Open Banking in the Ocean Money app). If you  apply for our  credit products, when you allow us, we may use this information for credit checks to improve your experience.

Information  from social media

Occasionally, we’ll use publicly available information about you from  selected social media  websites or apps  to carry out  enhanced due diligence checks. Publicly available  information from social media websites or apps may also be provided to us  when we conduct general searches on you (for example, to comply with  our anti-money laundering or sanctions screening obligations).

Information from publicly available sources

We collect information and contact details from publicly available sources,

such as media stories, online registers or directories, and websites for enhanced due diligence checks,  security searches, and KYC purposes.

4. What isyour legal basis for using my personal data?


We must have a legalbasis (a validlegal reason) for using your personal data.Our legal basiswill be one of the following:

- Keeping to our contracts and agreements with you

We need certain personal data to provide our services and cannot provide them without this personal data.

- Legal obligations

In some cases,we have a legal responsibility to collect and store your personal data (for example, under anti-money laundering laws we must hold certaininformation about our customers).

- Legitimate interests

We sometimes collectand use your personal data because we have a legitimate reasonto use it and this is reasonable when balanced against your humanrights and freedoms.

- Substantial publicinterest

Where we process your personal data, or yoursensitive personal data (sometimes known as special category personal data),to adhere to government regulations or guidance, such as our obligation to support you if you are or become a vulnerable customer.

- Consent

Where you've agreed to us collecting your personal data, or sensitive personal data, for example when you tick a box to indicate you’re happy for us to use your personal data in a certain way.

What we use your personal data for

Our legal basis for using your personal data

Providing our services

Whenever you sign up with Ocean Money, apply for or use a product or service, we’ll  use your personal data to:

·       check your identity, and the identity of joint account holders

·       (as  part of our KYC process)

·        decide whether or not  to approve your application

·        meet our contractual  and legal obligations relating to any products or services you use (for  example, making payments into and out of your Ocean Money account,  withdrawing cash or making payments with your Ocean Money card)

·        help you understand  your spending behaviour, how you use Ocean Moneyproducts and services, and to  help you save money (for example, by providing you with product usage and  spending insights)

·        recover debt and  exercise other rights we have under any agreement with you

·       provide you with customer support services. We may  record and monitor any communications between you and us, including phone  calls, to maintain appropriate records, check your instructions, analyse,  assess and improve our services, and for training and quality control  purposes

·       Keeping  to contracts and agreements between you  and us

·       Legitimate interests (we need to be efficient about  how we meet our obligations, and we want to

·       provide you  with good products and services)

·       Legal obligations

Protecting against fraud

We use your  personal data to check your  identity to protect against fraud,  keep to financial crime laws and to confirm that you’re eligible to use our services. We also use it to help us better understand your financial  circumstances and manage fraud risks related to your Ocean Money account.

·       Legitimate  interests (to develop and improve how we deal with financial crime and meet our legal responsibilities)

·       Legal obligations

Marketing and providing products and services that

might interest you

We use your personal data to do the following:

·       to  personalise your in-app experience and marketing messages about  our products and  services so they’re more relevant and interesting to you (where allowed by law). This  may include analysing how you use our products, services and your  transactions

·       if you agree, provide you with information about our partners’ promotions or offers which  we think you  might be interested in

·       if you agree, allow our partners and other organisations

·        to provide you  with information about  their products or services

·       measure or understand the  effectiveness of our  marketing and advertising, and  provide relevant advertising to you

·       ask your  opinion about our products or services.

·       Remember,  you can ask us to stop sending you marketing information by adjusting your  marketing choices (the How do  you  use my personal data for marketing? section below explains how to do this).

·       Legitimate interests (to send direct marketing, ensure our direct marketing is  relevant to your interests, develop our products and services, and to be efficient  about how we meet our legal and contractual  duties)

·       Consent  (where we’re legally required to get your consent to send you direct  marketing about our products or services, or partners’ promotions or offers,  or for you to receive marketing from other organisations)

To keep our services up and running

We use your personal data to manage our website and the Ocean Money app, (including troubleshooting, data analysis, testing,  research, statistical and survey purposes), and to make sure that content  is presented in the most effective way for you and your device.

We also use your personal data to:

·       verify your identity if you contact our customer support or social media teams

·       allow you to take part in interactive features of our services

·       tell you about changes to our services

·       help keep our website and the Ocean Money app safe and secure

·       Keeping  to contracts and agreements between you  and us

·       Legitimate interests (to be efficient about how we meet our obligations and keep  to regulations that apply  to us and  to present content as effectively as possible for you)

·       Consent (where required by law)

Helping with  social interactions

We use your personal data to help  with social interactions

through our  services, or to add extra  functions in order  to

provide a better experience.

For example, if you give  us permission, we'll  use the contacts list on your phone so you can  easily make payments to, or message, your contacts using the Ocean Money app.

·       Legitimate  interests (to develop our products and services and to be efficient in our  obligations)

·       Consent  (to access information held on your phone, for example,  contacts in your contacts list,  to track you when you have location  services switched on)

Providing location-based services

If you turn location services on in the Ocean Money app we use your personal  data to:

·        provide you with  products and services

·        provide relevant  advertising to you (for example, information about nearby merchants)

·        protect against fraud

·       Keeping  to contracts and agreements between you  and Us

·       Legitimate  interests (to develop and market our  products and keep to regulations that apply to us)

·       Consent (to  track you when  you have location services switched on)

Preparing anonymous statistical datasets

We prepare anonymous statistical datasets about  our customers’ spending patterns:

·       for forecasting purposes

·       to understand how customers use Ocean Money

·       to comply with governmental requirements and requests

These datasets may  be shared internally or externally with others, including non-Ocean Money  companies. We produce these reports using information about you and  other customers. The information used and shared  in this way  is never personal data and you will  never be identifiable from  it. Anonymous statistical data  cannot be linked  back to you  as an individual.

For example, some  countries have laws  that require us to  report spending statistics and how money enters or leaves each country.  We’ll provide anonymised statistical information  that explains the  broad categories of merchants that  Ocean Money customers in that  country spend their  money with. We’ll  also provide information about how Ocean Money customers top up their accounts and transfer money.  However, we won’t  provide any customer-level information. It will not  be possible to identify  any individual Ocean Money customer.

·       Legitimate  interests (to conduct research and analysis, including to produce  statistical research and reports)

·       Legal obligations

Improving our products and services

We use your  personal data to help us develop and  improve our current  products and services. This allows us to continue to provide products and services that  our customers want  to use.

·       Legitimate  interests (to understand how customers use our products so we can develop new products and improve the  products we currently provide)

Meeting our legal obligations, enforcing our rights and other legal uses

We use your personal data:

to share  it with other  organisations (for example, government authorities, law enforcement authorities, tax authorities, fraud prevention agencies)

to recover debts from you (for example, where you hold a credit product with  us or have  a negative balance in your account)

·       if this  is necessary to meet our  legal or regulatory

·       obligations

·       to  identify and support vulnerable customers by analysing your behaviour in the Ocean Money app, customer support communications and through transactions (for example,

we will try to identify  whether you are potentially vulnerable

so we can provide you with enhanced support. Identifying and supporting vulnerable customers is a legal  requirement for us in some  countries)

·       in connection with legal claims

·       to help detect or prevent crime

You can find out more in the Do you share my personal data with anyone  else? section below.

Sometimes, we’re  legally required to ask you to provide information about  other people. For example, we might ask you  

to explain:

·       your relationship with a joint account holder or somebody

·       who  pays money into your Ocean Money account with us

·       how somebody got the money  in the first place  to pay it

·       into  your Ocean Money account with us

·       Legitimate interests (for example, to protect Ocean Money during  a legal dispute

·       Substantial  public interest (if we process your sensitive personal data to keep to legal  requirements that apply to  us)

·       Legal obligations

5. Do youmake automated decisions about me?

 

Depending on the OceanMoney products or servicesyou use, we may make automated decisions about you.

This means that we may use technology that can evaluateyour personal circumstances and other factors to predict risks or outcomes. This is sometimes known as profiling. We do this for the efficient runningof our services and to ensure decisions are fair, consistent and based on the right information.

Where we make an automated decision about you, you have the right to ask that it is manually reviewed by a person. You can find out more about this in the What are my rights? section below.

For example, we may make automated decisions about you that relate to:

Approving credit applications:

·      credit and affordability checks to see whether we can accept your credit application

·      setting credit limits

Monitoring credit agreements:

·       assessing how you’re repaying any credit product you hold with us

·       amending your credit limit

·       terminating your credit agreement

Opening accounts:

·      KYC, anti-money laundering and sanctions checks

·      identity and address checks

Detecting fraud:

·      monitoring your accountto detect fraud and financial crime

Our legal basis is one or more of thefollowing:

·      keeping to contracts and agreements between you and us

·      legal obligations

·      legitimate interests (to develop and improve how we deal with financial crime and meet our legal responsibilities)

6. Do yourun credit checks on me?

We, and our lending partners, use credit reference agencies (or otherproviders of creditinformation in some countries)to run credit checks if you apply (or tell us you want to apply) for a credit product throughOcean Money.

If you give us accessto other accountsyou hold with other financial institutions, through Open Banking, where you agree, we’lluse available information to carry out credit checkson you.

We’ll also share your personal data with credit reference agencies (or other providers of credit information) to:

·      confirm details you have provided when you apply for products or services

·      make an assessment about whether to accept your credit application

·      determine an appropriate credit limit for you

When you enter into a credit agreement with us, we may continue sharing information with credit reference agencies or other providers of credit information (for example, information about your repayments and whether you repay in full or on time).

We’ll carry out additional credit checks on you from time to time to make sure that your financial wellbeing hasn’t changedover the courseof the year.

The personal data we share with, and receive from, credit reference agencies (or other providers of credit information) when you apply for or use Ocean Money credit products will vary depending on the country you live in. We’ll provide full details when you apply for Ocean Money credit products.

Our legal basis is one or more of thefollowing:

·      consent (where we are required to collect your consent by law)

·      legal obligations

·      keeping to contracts and agreements between you and us (where you take out a credit product with us)

·      legitimate interests (to develop and, in the future, offer credit products to our customers).

7. How doyou use my personal data for marketing?

If you sign up to our services, and where nationallaws allow, we’llassume you want us to contact you bypost, push notification, email and text message with information about Ocean Moneyproducts, services, offer and promotions. Where national laws require us to get your consentto send marketing messages, we’ll do so in advance.

We use your personal data to personalisemarketing messages about our products and services so they are more relevantand interesting to you (where allowed by law). This may include analysing how you use ourservices and your transactions.

You can object to profiling for direct marketing purposes. You can also adjust your preferences or tell us you don'twant to hear from us at any time. Just use the privacy settingsin the Ocean Money app or tap theunsubscribe links in any marketing message we send you.

If you do not want to receive personalised marketing messages, and opt out from receiving them, you will not receive any marketing communications.

We won't pass your detailson to any organisations outsidethe Ocean Money group of companies for theirmarketing purposes withoutyour permission. You can find out more in the Do you share my personal datawith anyone else? sectionbelow.

Our legal basis is:

·      consent (where we are required by law to collect your consent); or 

·      legitimate interests (to send you marketing and to provide information relevant to your interests).

8. Whatare my rights?

Your right

What it means

You have the right to be told how we use your personal data

We provide this privacy notice to explain how we use your personal data.

If you ask, we’ll provide  a copy of the personal data we hold about you. We can’t  give you any  personal data about  other people, personal data which is linked to an ongoing criminal or fraud investigation, or personal data  which is linked  to settlement negotiations with  you. We also  won't provide you with any communication we've had  with our legal advisers.

You can ask us to correct  your

personal data if you think it's wrong

You can have incomplete or inaccurate personal data corrected. Before we update your file, we may need to check the accuracy of the new personal data you have provided.

You can ask  us to delete  your personal data

You can ask  us to delete  your personal data  if:

·       there's no good reason  for us to continue using  it

·       you gave us consent  (permission) to use your personal

·       data  and you have now withdrawn that consent

·       you have  objected to us using your  personal data

·       we have used your personal data  unlawfully

·       the law requires us to delete your personal data

Just to let you know,  we may not be able to agree  to your request. Pursuant to regulatory needs, we may  have to keep certain customer personal data even when you ask us to  delete it (we’ve explained this  in more detail  below). If you’ve closed your Ocean Money  account with us, we may not be able to delete your  entire file because  these regulatory responsibilities take priority. We’ll always let you know if we can't delete your  personal data.

You can object  to us processing your personal data for marketing purposes

You can tell  us to stop  using your personal data, including  profiling  you, for marketing.

You can object to us processing other personal  data (if we’re using it for  legitimate interests)

If our legal  basis for using  your personal data  is 'legitimate interests' and you disagree with us using it, you can object.

However, if there is an overriding reason why we need to use your personal data,  we will not  accept your request.

If you object  to us using personal data which we need in order  to provide our services, we may need to close  your account as we  won’t be able to provide  the services.

You can ask us to restrict how we  use your personal data

You can ask  us to suspend using your personal data if:

·       you want us to investigate whether it’s accurate

·       our use of your personal data is unlawful but you don’t want us to delete it

·       we no longer need your personal data, but you want us to continue  holding it for  you in connection with a legal  claim

·        you have objected to us using your personal  data (see above),

·        but we need to check whether we have an overriding reason  to use it.

You can ask us to transfer personal data to you or another company

If we can, and are allowed to do so under regulatory requirements, we’ll  provide your personal data in a structured,  commonly used, machine-readable format.

You can withdraw your permission

If you’ve given us the consent we need to use your  personal data, you can withdraw it at any time by changing your privacy  settings in the Ocean Money app or sending an email to [INSERT DPO EMAIL].

(Please note, it will have been lawful for us to use the personal data up to the point you withdraw your permission.)

You can ask  us to carry  out a human review of an automated decision we make  about you

If we make  an automated decision about you that  significantly affects you, you can  ask us to carry out  a manual review  of this decision.

 

Your ability to exercise these rights will depend on a number of factors. Sometimes, we won’t be able to agree to your request(for example, if we have a legitimate reason for not doing so or the right does notapply to the particular information we hold about you).

9. How do I exercise myrights?

To exercise any of your rights set out in the previoussection, you can contact us through the OceanMoney app or send us an email at [INSERT DPO EMAIL]. For security reasons, we can't deal with your request if we’re not sure of your identity, so we may ask you forproof of ID.

If a third party exercises one of these rights on your behalf, we may need to ask for proof that they’ve beenauthorised to act on your behalf.

When you exercise one of your rights, or update your privacy settings in the Ocean Money app,, it may take us up to onemonth to respond or implement your changes.

Ocean Money will usually not charge you a fee when you exercise your rights. However, we’re allowed by law to charge a reasonable fee or refuse to act on your request if it is manifestly unfoundedor excessive.

If you’re unhappy with how we’ve handled your request, you can complain to your local data protection authority. In the United Kingdom, this is the ICO (website). In the European EconomicArea, our cross-border data protectionauthority is the Federal Data Protection and Information Commissioner (FDPIC) inSwitzerland (website).

10. Do you share mypersonal data with anyone else?

Our group companies

We share your personal data within the Ocean Money group of companies to:

·      provide you with the best service

·      send you information about Ocean Money  products and services we think you’ll be interested in hearing about.

Suppliers

The table below explains which suppliers we normally share your personal data with:

Type of supplier

Why we share your personal data

Suppliers who provide us with IT,  payment and delivery services

To help us provide our services to you

Our banking and financial services partners  and payments networks, including  Visa and Mastercard

To help us provide our services to you. This includes banking  and lending partners, banking intermediaries and international payment  service providers

Card manufacturing, personalisation and delivery  companies

To create and deliver your personalised Ocean Moneycard

Analytics providers and  search information providers

To help us improve our website or app

Customer-service providers, survey  providers and developers

To help us to provide our services to you

Communications services  providers

To help us send you emails, push notifications and text messages

Debt collection agencies

To manage and  recover debts that  you owe or may end  up owing (including if you have  an Ocean Moneycredit product)

 

Partners who help to provide our services

We may shareyour personal data with our partners to provide certainservices you’ve askedus for.

We’ll only share your personal data in this way if you’ve asked for the relevant service or if it’s provided as part ofour membership plans.

From time to time, we may work with otherpartners to offeryou co-branded servicesor promotional offers, and we’ll share some of your personaldata with those partners. We will always make sure you understandhow we and our partners process your personal data for these purposes.

Credit reference agencies

As set out in the Do you run credit checks on me? section above, if you apply for a credit product, we'll share your personaldata with creditreference agencies to check whetheryou are likelyto make repayments when due.

If you are in the United Kingdom,we also sharepersonal data with credit reference agencies, including Equifaxand Experian, to verify your identity during onboarding. You can find out more about how Equifax and Experian handle your personaldata here and here respectively.

Other financial institutions and Ocean Money customers

We may shareyour personal data with otherfinancial institutions, or Ocean Money customers, if you ask us to. Forexample, if you have activated ‘Open Banking’ throughan account you hold with another financial institution and given them permission, we’ll share data from your Ocean Money account (such as your balance, payment transactions, account number and sort code) with that financial institution.

We may also share your personal data with otherfinancial institutions, or Ocean Money customers, where you do not ask us to. For example, if a paymentis made to your accountby mistake, we can share yourinformation with the financial institution, or Ocean Money  customer, the payment came from. This will help the payer and the other financial institution to try and get the payment back themselves.

Other third parties

We may share your personal data with other third parties where necessary to facilitate you receiving paymentsto your  Ocean Money account.

For legal reasons

We also shareyour personal data with otherfinancial institutions, government authorities, law enforcementauthorities, tax authorities, companies and fraud prevention agencies to checkyour identity, protect against fraud,keep to tax laws, anti-money laundering laws, or any otherlaws and confirm that you’re eligible to use our productsand services.

If fraud is detected, you could be refused certain services by Ocean Money or other companies.

We may also need to share your personal data with other third party organisations or authorities:

·      if we have to do so under any law or regulation

·      if we sell our businessor credit portfolio

·      in connection with criminal or fraud investigations

·      to enforce our rights (and those of customers or others)

·      in connection with legal claims.

Social media and advertising companies

When we use social media for marketingpurposes, your personaldata (limited to only your name, email address and app events)may be shared with the social mediaplatforms so that they can check if youalsohold an account with them. If you do, we may ask the advertising partner or social media provider to:

·      use your personaldata to send our advertsto you, becausewe think that you might be interested in a new Ocean Money productor service

·      not send you our adverts, because the marketing relates to a service that you already use

·      send our advertsto people who have a similar profile to you (for example, if one of our servicesis particularly useful to people with similar interests to the ones on your social mediaprofile, wemay ask our advertising partneror social mediapartner to send our advertsfor that serviceto those people)

We may shareyour personal data with our advertising partnersin the ways described above,but the personal data is hashedbefore we send it, and the socialmedia platform we share it with is only allowed to use that hashed personal datain the ways described above.

Our legal basis is:

·      legitimate interests (to ensure our advertising is as effective as possible)

You can contactus at any time, by emailing [INSERT DPO EMAIL], if youdon’t want us to share your personaldata for advertising purposes. You can also use the privacysettings in the Ocean Money app to opt out from havingyour personal data shared in this way.

Remember you can also manage your marketing preferences directly with any social media provider that you havean account with.

Where you ask us to share your personal data

Where you directus to share your personaldata with a third party,we may do so. For example, you mayauthorise third partiesto act on your behalf (such as a lawyer,accountant or family member or guardianunder a power of attorney). We may need to ask for proof that a third party has been validly authorised to acton your behalf.

11. Will my personaldata go outside the United Kingdom or Europe? 

As we provide an international service, we may need to transfer your personal data outside the United Kingdomor European Economic Area (EEA) to help us provide our services.

For example, if you make an international payment, we’ll send funds to banks outsideof the United Kingdom or EEA. We might also send your personaldata outside of the United Kingdom or EEA to keep to globallegal and regulatory requirements, and to provide ongoingsupport services.

We may send your personaldata outside of the United Kingdom or EEA to:

·      keep to global legal and regulatoryrequirements

·      provide ongoing supportservices

·      credit reference agencies, fraud prevention agencies, law enforcement authorities

·      enable us to provide you with products or services you have requested

If we transfer your personal data to another country that doesn’t offer a standard of data protection equivalent to the United Kingdom or EEA, we will make sure that your personaldata is sufficiently protected. For example, we’ll make sure that a contract with strict data protection safeguards is in place before we transfer your personal data.In some cases,you may be entitled to ask us for a copy of thiscontract.

If you would like more information, please contact us by sending an email to [INSERT DPO EMAIL],

12. How do you protectmy personal data?

We recognise the importance of protecting and managing your personal data. Any personaldata we process will be treatedwith the utmostcare and security. This section sets out some of the securitymeasures we have in place.

We use a variety of physical and technical measuresto:

·      keep your personal data safe

·      prevent unauthorised access to your personal data

·      make sure your personal data is not improperly used or disclosed

Electronic data and databases are stored onsecure computer systems with control over access to information using both physicaland electronic means. Our staff receives data protection and informationsecurity training.We have detailed security and data protection policies which staff are required to followwhen they handle your personal data.

While we take all reasonable steps to ensure that your personal data will be kept secure fromunauthorised access, we cannot guarantee it will be secure duringtransmission by you to our app, a website or other services. We use HTTPS(HTTP Secure), wherethe communication protocolis encrypted through Transport Layer Security for secure communication over networks, for all our app, web andpayment-processing services.

If you use a passwordfor the Ocean Money app our website,you will need to keep this passwordconfidential. Please do not share it with anyone.

When you use our publicservices, which includesour social networkaccounts do not share any personaldata that you don't want to be seen, collected or used by other customers, as this personaldata will becomepublicly available.

13. How long will youkeep my personal data for?

We’ll generally keep your personal data for six years after our business relationship with you ends, or such period as may be required by applicable locallaws.

We’re required to keep your personal data for this long by anti-money laundering and e-money laws.We may keep your personal data for longerbecause of a potential or ongoing courtclaim, or for another legal reason.

14. How will you keep meupdated about how you use my personal data?

If we change the way we use your personal data, we’ll update this notice and, if appropriate, let you know by email, through the Ocean Money app or throughour website.

15. Do you use cookies?

We use cookiesto analyse how you use our website.Please read our Cookies Policy for more informationabout cookies.

We also use pixels or web beaconsin the direct marketing emails that we send to you. These pixels track whether our email was delivered and opened, and whether links within the email were clicked. They also allow us to collectinformation such as your IP address, browser,email client type and othersimilar details. We use this information to measure the performance of our email campaigns, and for analytics. You can control whetheryou receive direct marketing emails through the privacy settingsin the Ocean Money app.