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1. About us
Ocean Money AG (Ocean Money, the company or we, or us) is a fnancial services technology platform. We are a company registered in Switzerland under number CHE-174.263.521 whose registered office is at Gubelstrasse 24 Zug, ZUG, 6300 Switzerland. The company is known as the ‘controller’ of your personal data.
2. Why do I 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 happen in more detail in the What personal data do you collect about me? 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 use your personal data.
If you have concerns about how we use your personal data, you can contact our data protection officer atdpo@ocean.money.
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:
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| 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:
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| 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. |
| 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 is your legal basis for using my personal data?
We must have a legal basis (a valid legal reason) for using your personal data. Our legal basis will 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 certain information about our customers).
- Legitimate interests
We sometimes collect and use your personal data because we have a legitimate reason to use it and this is reasonable when balanced against your human rights and freedoms.
- Substantial public interest
Where we process your personal data, or your sensitive 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 orservice, we’ll use your personal data to:
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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. |
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Marketing and providing products and services thatmight interest you We use your personal data to do the following:
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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:
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Helping with social interactions We use your personal data to help with social interactionsthrough our services, or to add extra functions in order toprovide a better experience. |
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Providing location-based services If you turn location services on in the Ocean Money app we use yourpersonal data to:
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Preparing anonymous statistical datasets We prepare anonymous statistical datasets about our customers’ spending patterns:
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 neverbe identifiable from it. Anonymous statistical data cannot be linked back to you as an individual. |
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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. |
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Meeting our legal obligations, enforcing our rights and other legaluses We use your personal data:
You can find out more in the Do you share my personal data with anyone else? section below.
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5. Do you make automated decisions about me?
Depending on the Ocean Money products or services you use, we may make automated decisions about you.
This means that we may use technology that can evaluate your personal circumstances and other factors to predict risks or outcomes. This is sometimes known as profiling. We do this for the efficient running of 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 account to detect fraud and financial crime
Our legal basis is one or more of the following:
- 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 you run credit checks on me?
We, and our lending partners, use credit reference agencies (or other providers of credit information insome countries) to run credit checks if you apply (or tell us you want to apply) for a credit product through Ocean Money.
If you give us access to other accounts you hold with other financial institutions, through Open Banking, where you agree, we’ll use available information to carry out credit checks on 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 changed over the course of the year.
The personal data we share with, and receive from, credit reference agencies (or other providers of creditinformation) 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 the following:
- 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)
- egitimate interests (to develop and, in the future, offer credit products to our customers).
7. How do you use my personal data for marketing?
If you sign up to our services, and where national laws allow, we’ll assume you want us to contact you by post, push notification, email and text message with information about Ocean Money products, services, offer and promotions. Where national laws require us to get your consent to send marketing messages, we’ll do so in advance.
We use your personal data to personalise marketing messages about our products and services so they are more relevant and interesting to you (where allowed by law). This may include analysing how you use our services and your transactions. You can object to profiling for direct marketing purposes. You can also adjust your preferences or tell us you don't want to hear from us at any time. Just use the privacy settings in the Ocean Money app or tap the unsubscribe 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 details on to any organisations outside the Ocean Money group of companies fortheir marketing purposes without your permission. You can find out more in the Do you share my personal data with anyone else? section below.
Our legal basis is:
- consent (where we are required by law to collect your consent); or
- egitimate interests (to send you marketing and to provide information relevant to your interests).
8. What are 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. |
| 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:
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 ask us to restrict how we use your personal data |
You can ask us to suspend using your personal data if
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| You can ask us to transfer personal data to you oranother company | If we can, and are allowed to do so under regulatory requirements, we’ll provide yourpersonal 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 dpo@ocean.money. |
| 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 sign if |
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 not apply to the particular information we hold about you).
9. How do I exercise my rights?
To exercise any of your rights set out in the previous section, you can contact us through the Ocean Money app or send us an email at dpo@ocean.money. For security reasons, we can't deal with your request if we’re not sure of your identity, so we may ask you for proof of ID.
If a third party exercises one of these rights on your behalf, we may need to ask for proof that they’ve been authorised 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 one month 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 unfounded or 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 Economic Area, our cross border data protection authority is the Federal Data Protection and Information Commissioner (FDPIC) in Switzerland (website).
10. Do you share my personal 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 | 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 share your personal data with our partners to provide certain services you’ve asked us 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 of our membership plans.
From time to time, we may work with other partners to offer you co-branded services or promotional offers, and we’ll share some of your personal data with those partners. We will always make sure you understand how 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 personal data with credit reference agencies to check whether you are likely to make repayments when due.
If you are in the United Kingdom, we also share personal data with credit reference agencies, including Equifax and Experian, to verify your identity during onboarding. You can find out more about how Equifax and Experian handle your personal data here and here respectively.
Other financial institutions and Ocean Money customers
We may share your personal data with other financial institutions, or Ocean Money customers, if you ask us to. For example, if you have activated ‘Open Banking’ through an 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 other financial institutions, or Ocean Money customers, where you do not ask us to. For example, if a payment is made to your account by mistake, we can share your information 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 payments to your Ocean Money account.
For legal reasons
We also share your personal data with other financial institutions, government authorities, law enforcement authorities, tax authorities, companies and fraud prevention agencies to check your identity, protect against fraud, keep to tax laws, anti-money laundering laws, or any other laws and confirm that you’re eligible to use our products and 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 organizations or authorities:
- if we have to do so under any law or regulation
- if we sell our business or 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 marketing purposes, your personal data (limited to only your name, email address and app events) may be shared with the social media platforms so that they can check if you also hold an account with them. If you do, we may ask the advertising partner or social media provider to:
- use your personal data to send our adverts to you, because we think that you might be interested in a new Ocean Money product or service
- not send you our adverts, because the marketing relates to a service that you already use
- send our adverts to people who have a similar profile to you (for example, if one of our services is particularly useful to people with similar interests to the ones on your social media profile, we may ask our advertising partner or social media partner to send our adverts for that service to those people)
We may share your personal data with our advertising partners in the ways described above, but the personal data is hashed before we send it, and the social media platform we share it with is only allowed to use that hashed personal data in the ways described above.
Our legal basis is:
- legitimate interests (to ensure our advertising is as effective as possible)
You can contact us at any time, by emailing dpo@ocean.money, if you don’t want us to share your personal data for advertising purposes. You can also use the privacy settings in the Ocean Money app to opt out from having your personal data shared in this way.
Remember you can also manage your marketing preferences directly with any social media provider that you have an account with.
Where you ask us to share your personal data
Where you direct us to share your personal data with a third party, we may do so. For example, you may authorize third parties to act on your behalf (such as a lawyer, accountant or family member or guardian under a power of attorney). We may need to ask for proof that a third party has been validly authorized to act on your behalf.
11. Will my personal data go outside the United Kingdom or Europe?
As we provide an international service, we may need to transfer your personal data outside the United Kingdom or European Economic Area (EEA) to help us provide our services.
For example, if you make an international payment, we’ll send funds to banks outside of the United Kingdom or EEA. We might also send your personal data outside of the United Kingdom or EEA to keep to global legal and regulatory requirements, and to provide ongoing support services.
We may send your personal data outside of the United Kingdom or EEA to:
- keep to global legal and regulatory requirements
- provide ongoing support services
- 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 personal data 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 this contract.
If you would like more information, please contact us by sending an email dpo@ocean.money.
12. How do you protect my personal data?
We recognize the importance of protecting and managing your personal data. Any personal data we process will be treated with the utmost care and security. This section sets out some of the security measures we have in place.
We use a variety of physical and technical measures to:
- keep your personal data safe
- prevent unauthorized access to your personal data
- make sure your personal data is not improperly used or disclosed
Electronic data and databases are stored on secure computer systems with control over access to information using both physical and electronic means. Our staff receives data protection and information security training. We have detailed security and data protection policies which staff are required to follow when they handle your personal data.
While we take all reasonable steps to ensure that your personal data will be kept secure from unauthorized access, we cannot guarantee it will be secure during transmission by you to our app, a website or other services. We use HTTPS (HTTP Secure), where the communication protocol is encrypted through Transport Layer Security for secure communication over networks, for all our app, web and payment- processing services.
If you use a password for the Ocean Money app our website, you will need to keep this password confidential. Please do not share it with anyone.
When you use our public services, which includes our social network accounts do not share any personal data that you don't want to be seen, collected or used by other customers, as this personal data will become publicly available.
13. How long will you keep 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 local laws.
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 longer because of a potential or ongoing court claim, or for another legal reason.
14. How will you keep me updated 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 through our website.
15. Do you use cookies?
We use cookies to analyze how you use our website. Please read our Cookies Policy for more information about cookies.
We also use pixels or web beacons in 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 collect information such as your IP address, browser, email client type and other similar details. We use this information to measure the performance of our email campaigns, and for analytics. You can control whether you receive direct marketing emails through the privacy settings in the Ocean Money app.
