Crezco's Privacy Policy
Please read this privacy policy (“Privacy Policy”) and our terms and conditions (the “Terms”) very carefully. This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us in accordance with applicable data protection laws. We are committed to protecting and respecting your privacy as a user.
Who are We?
We are Crezco Limited (referred to as “we” or “us” or “our” or “Crezco”), a company incorporated and registered in England and Wales with company number 117521825 whose registered office is at 192F Campden Hill Road, Notting Hill Gate, W8 7TH.
Crezco is a payments app that enables registered users (“users”, “customers” or “you”) to request money instantly and subsequently receive money by way of linking their bank account securely, via Open Banking technology (“Open Banking” information can be found via their website). Consequently, Crezco is regulated by the Financial Conduct Authority (the “FCA”) as Authorised Payment Institution with the Firm Reference Number 925173. The Crezco platform (“Platform”) refers to both the mobile and web application (the “App”) and the website (the “Site”) and all the information provided within it.
Types of Data Collected
We will only collect the data that we need to provide the Service that we offer. We will not collect any data that is not needed to fulfil our Service. Such data includes, but is not limited to, the list below:
Identity Data
includes first name, last name, title, date of birth.
Contact Data
includes your current residential address, previous addresses, email address and telephone numbers.
Financial Data
includes bank account details.
Transaction Data
includes details about payments to and from you including dates, amounts and beneficiary details.
Technical Data
includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
Profile Data
includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data
includes anonymous analytical data about how you use our website, products and services.
Why do we Collect your Data?
Crezco will only collect the data that we need to provide the Service that we offer. We will not collect any data that is not needed to fulfil our Service. The following is a list of such Services and the adjoining data required for its performance:
Account Information Service
When we provide you with an account information service, we process data about you such as ‘Identity Data’, ‘Contact Data’, ‘Financial Data’, ‘Transaction Data’, and ‘Technical Data.’ We also process data needed for communication with the respective bank.
Payment Initiation Service
When you use our payment initiation service, we process data about you such as ‘Identity Data’, ‘Contact Data’, and ‘Financial Data’, a necessity in order to communicate with your respective bank. We also process information about your invoices to be paid or similar and information about the payee of the transaction you intend to initiate with our payment initiation service.
Fraud Monitoring, Account Monitoring, and Transaction Monitoring
We also process the following data to make certain automated decisions and comply with our legal obligations, for example to comply with anti-money laundering rules and to identify Politically Exposed Persons (so called PEPs): ‘Identity Data’, ‘Contact Data’, ‘Financial Data’, ‘Transaction Data’, and ‘Technical Data.’ This may lead us to suspend your use of the Service, either temporarily or permanently. If you have been affected by the automated decision making, you may request human intervention or challenge the decision of the algorithm, by sending an email to privacy@crezco.com. We will also use your personal information to help prevent fraud in a more general manner, by trying to stop you from becoming a victim of fraud and confirming you are eligible to use our services.
Third Parties
Crezco may provide or otherwise make available information relating to you to our collaboration partners and companies that process personal data on behalf of Crezco, i.e. data processors of Crezco, such as our IT-suppliers or suppliers engaged by Crezco for Crezco’s marketing efforts. However, Crezco will always be responsible for the correct processing of your personal data. Finally, your data may be disclosed to law enforcement authorities within the scope of our obligations under applicable anti-money laundering rules.
Where do we Process your Data?
We process all data within the UK and/or the EU/EEA. Potentially, your data may be transferred to or stored in countries outside of the UK and/or EU/EEA, provided that there is an adequate level of protection or that Crezco and its data processors have implemented appropriate safeguards.
Your Rights
Crezco is the data controller and is responsible for the processing of your personal data in accordance with applicable legislation. As a User, you may exercise certain rights regarding your data we process, including the following:
Right of access
You have the right to access information about what personal data we process about you, including the purpose of and legal basis for the processing.
Right to rectification
If you believe that we are processing inaccurate personal data about you, you can ask us to correct it.
Right to restrict processing
You can request that we restrict the processing of your personal data. As an example, this can be relevant if we have incorrect data about you and you do not want the processing to continue until we have corrected the data.
Right to be forgotten
You can request that we delete your personal data. Although we will comply with such a request to the extent required by applicable law, please note that we, despite your request, may continue to process certain data (such as data that we need to retain in order to protect our legal interests or that we are required to retain pursuant to legal obligations).
Right to object
In connection with the processing of personal data based on our legitimate interest, you have the right to object to the processing of your personal data. If your privacy interests outweigh our interests in processing certain data, we will stop processing such data.
Right to data portability
You may have the right to access personal data that you have provided to us, where we will provide your data in a structured, generally accepted and machine-readable format, and you may also have a right to transfer the personal data to another data controller.
While users can object to the processing of their personal data for direct marketing purposes at any time without providing any justification, users may at times have to justify their objection, say should their personal data be processed for a public interest. Any requests to exercise user rights can be directed to privacy@crezco.com. These requests can be exercised free of charge and will be addressed as early as possible and always within one month.
How long do we Store your Data for?
The data we collect for the provision of our Service is kept as long as is needed for the purposes for which the data was collected. The data is thereafter deleted or anonymized. Many types of data are in general deleted within one year from when we have fulfilled our obligations in relation to the respective Service, however some data may be kept longer than that, for example the data that is required for a legal process or data that we under applicable anti-money laundering rules must retain for five years.
Data Security
Processing of personal data is a responsibility of great importance to us.
We aim to ensure that you at all times remain confident in trusting Crezco with your personal data. In this respect, Crezco has implemented such security measures necessary to protect your personal data from unauthorized access, modification and deletion.
Contact Information
If you wish to contact us in writing, or if these Terms require you to give notice to us in writing, please contact us at: 192F Campden Hill Road, Notting Hill Gate, W8 7TH
Do not hesitate to contact Crezco if you have any questions on the processing of your personal data or any complaint by emailing privacy@crezco.com.
