Maji Data Privacy Policy

Maji Financial Wellness Ltd. understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our platform at our website, www.maji.io (“Our Platform” or “Site”) and/or receives any services from us (“You”). 
 
It is important that you read this privacy policy (“Privacy Policy”) together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. Any changes to this Privacy Policy will apply when the changes are posted on Our Site. 

1. Who We Are and Contacting Us

1.1.  For the purpose of Data Protection Laws, the data controller is Maji Financial Wellness Services (“Maji/We/Us/Our”) and we are responsible for your personal data. Our ICO Registration Number is: ZA521090.

1.2.  Contact details: If you have any questions about this Privacy Policy, please contact us by post or email:
       1.2.1. Postal Address: 37 Oakfield Gardens, Beckenham, Kent BR3 3AY, United Kingdom. 
       1.2.2. Email: email at connect@maji.io. Please ensure your query is clear, particularly if it is a request for information about  the personal data we hold about you.

1.3.  You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

2. Definitions and Interpretation

2.1.   In this Privacy Policy, the following terms have the following meanings:

2.1.1.Account” means an account required to access and/or use certain areas and features of Our Platform, including a personal account which you set up with us where you are our client (“Personal Account”) and an employer account. A Personal Account on our Platform may either be linked to your employer’s account where your employer at the time you apply to register a Personal Account (“Employer”) has its own account with us in the name of the Employer (an “Employer Account”), subject to separate terms and conditions, or be set up and/or managed by you independently of and not linked to an Employer Account. 

2.1.2.Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in our Cookie Policy below, which forms part of this Privacy Policy; and 

2.1.3.Data Protection Laws” means any data protection and privacy laws in force in the UK from time to time as subsequently amended, extended, re-enacted or replaced from time to time including (i) the Data Protection Act 2018 (“DPA”) and the Privacy and Electronic Communications (EC Directive) Regulations (2003/2426) (“PECR”)
(ii) any legislation incorporating, transposing or preserving the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and any other directly applicable European Union regulation relating to privacy into force in the UK and (iii) any mandatory guidance or codes of practice issued by the ICO or any other regulator that has jurisdiction in the UK from time to time;
 

2.1.4.Personal data” and “Controller” have the meanings set out in Data Protection Laws; 

2.1.5.Services” are the services we provide to you directly or via your Employer.

3. What Is Personal Data and What Personal Data Do We Collect?

3.1.    Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

3.2.    We collect, use, store and transfer different types of personal data about you as follows:

3.2.1Identity Data includes first name, last name, date of birth, National Insurance number, employee reference number, Unique user reference assigned to you by us and gender;

3.2.2Contact Data includes address, email address; phone number;

3.2.3Financial Data includes payment card details, and valuation, transaction and account details of your pension  accounts when you add them to your Maji account;

3.2.4Transaction Data includes details about payments to and from you and other details of Services you have purchased from us;

3.2.5Technical Data includes internet protocol (IP) address, your login data, 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 Site.

3.2.6Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;

3.2.7Usage Data includes information about how you use our Site and Services.

3.2.8Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

3.3.    Direct interactions with you – You may give us your identity, contact and financial data by filling in forms or by  corresponding with us by post, phone, email or otherwise. This includes personal data you provide as follows: 

          3.3.1.your name and email address from you when you register your account with us;

3.3.2.We also collect your identity and contact data (your name and email address) if you complete our contact form.

3.4.    Interactions via your Employer – if your Employer has an Employer Account with us, your Employer also gives us your identity data and contact data in order to enable us to send you an email via your work email address, and to create a personalised pension video for you. This data includes your name, work email address, NI number, salary, pension contribution basis, contracted hours and pension contribution rate.

3.5.    Automated technologies or interactions. As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using Cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our Cookies. Please see our Cookie Policy below for further details.

3.6.    Aggregated Data – we also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy. 

3.7.    Special Category Data – we do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. 

4. How Do We Use Your Personal Data?

4.1.   Under Data Protection Laws, we must always have a lawful basis for using personal data.
The following lawful bases apply to our processing of your personal data:

       4.1.1. the processing is necessary for the performance o Services we provide pursuant to a contract we have entered into  with  you or your Employer; or

       4.1.2. it is in our legitimate business interests to use it and your interests and fundamental rights do not override those  interests; 

       4.1.3. where we need to comply with a legal obligation; or

       4.1.4you have consented to our use of your personal data.

4.2.  Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent
before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

4.3.   We have set out in the table below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

4.4.    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new customer(a) Identity (b) ContactPerformance of a contract with you
To provide and manage your Account with us and deliver our Services to you or your Employer organisation including:(a) Manage payments, fees and charges(b) Collect and recover money owed to us(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey(a) Identity (b) Contact (c) Profile (d) Marketing and Communications Performance of a contract with you (b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our Services)
To enable you to partake in a prize draw, competition or complete a survey(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our Services, to develop them and grow our business)
To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity(b) Contact(c) Technical(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation
To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) TechnicalNecessary for our legitimate interests (to study how customers use our Services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Site, Services, marketing, customer relationships and experiences(a) Technical (b) UsageNecessary for our legitimate interests (to define types of customers for our Services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and CommunicationsNecessary for our legitimate interests (to develop our Services and grow our business)

4.5.    Marketing – We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

4.5.1Promotional offers from us – We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased Services from us and you have not opted out of receiving that marketing.

4.5.2Third-party marketing – We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

4.5.3Opting out – You can ask us or third parties to stop sending you marketing messages at any time by logging into the Site and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you OR by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of Service purchase, Service experience or other transactions.

4.5.4Cookies – You can set your browser to refuse all or some browser Cookies, or to alert you when websites set or access Cookies. If you disable or refuse Cookies, please note that some parts of this Site may become inaccessible or not function properly. For more information about the Cookies we use, please see our Cookie Policy below.

4.5.5Change of purpose – We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

4.5.6By law – Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law

5. Disclosures of personal data to third parties

5.1    We may share your personal data with third parties for the purposes set out in the table in Part 4 above.

5.2.    Your data will be stored:

5.2.1.on our secure servers located in the European Economic Area (“EEA”) for purposes of delivering our Services;

5.2.2.on an external service provider for the purposes of Maji providing the Services you have signed up for and to service your Account;

5.3.    We may also provide additional services in partnership with third parties such as pension providers that require us to share some or all of your Personal Data. We will always ask for your explicit consent to share your data if you would like to access any of these services.  

5.4.    We may also need to share your personal data with legal and regulatory authorities such as the FCA, which regulates our business.

5.5.    We may also share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

5.6.    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5.7.    Your personal data may have to be transferred outside the European Economic Area (EEA) to third parties for the purposes set out in the table in Part 4 above. If we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

5.7.1. The country has been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

5.7.2.If we use certain service providers based outside the EEA, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

5.7.3.If we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

5.7.4.In any other case, we will obtain your explicit consent before any transfer takes place.

5.8.    Our Platform may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

5.9.    Use of third parties

5.9.1.We use third party services for the purposes set out in the table in Part 4 above. A list of our external service providers can be found below: 

Service providerService
Google CloudInfrastructure service
Google DriveDocument repository
GmailClient email service
HubspotClient Management service
IntercomClient Management, Chat, Email and Customer Service
SendgridEmail and Customer Service service
StripePayment service
YodleePension account linking service
SegmentInfrastructure service
MixpanelInfrastructure service

6. Data Security, Retention and Disposal

6.1.    We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

6.2.    Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk.

6.3.    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6.4.    We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Usually that means we will keep your personal data for as long as you have a registered personal account with Maji. We may need to retain your personal data for a longer period in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect to our relationship with you or where we have to keep data for regulatory purposes.

6.5.    To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

6.6.    You can terminate this account whenever you want to. You can unsubscribe from Maji emails at any time by clicking on the ‘unsubscribe’ button at the bottom of our emails.

6.7.     When you delete your account, your personal data will be erased, deleted, destroyed, or otherwise disposed of.

7. Your legal rights

7.1.    Under certain circumstances, you have the following rights under Data Protection Laws in relation to your personal data:

7.1.1.Request access to your personal data.

7.1.2.Request correction of your personal data.

7.1.3.Request erasure of your personal data.

7.1.4.Object to processing of your personal data.

7.1.5.Request restriction of processing your personal data.

7.1.6.Request transfer of your personal data.

7.1.7.Right to withdraw consent.

7.2.    If you wish to exercise any of the rights set out above, please contact us using the contact details set out above at the beginning of this Privacy Policy.

7.3.    No fee usually required – You will not have to pay a fee to access your personal data (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 could refuse to comply with your request in these circumstances.

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

7.5.    Time limit to respond – We try to respond to all legitimate requests within one month. Occasionally it could 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. 

8. Cookie policy

8.1.    Our Site may place and access certain first-party Cookies, web beacons or similar analytics technologies on your computer or device. First-party Cookies and web beacons are those placed directly by us and are used only by us. We use Cookies and web beacons to facilitate and improve your experience of Our Site and to provide and improve our Services. We have carefully chosen these Cookies and web beacons and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

8.2.    We use the following first-party Cookies:

8.2.1Strictly necessary cookies. These are Cookies that are required for the operation of our Platform. They include, for example, Cookies that enable you to log into secure areas of our Site, use a shopping cart or make use of e-billing services.

8.2.2Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.

8.2.3Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

8.2.4Targeting cookies. These Cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests.

8.2.5Cookies We use -You can find more information about the individual Cookies we use and the purposes for which we use them in the table below:

Cookie NamePurposeClassification
__stripe_midThis cookie is necessary for making credit card transactions on the website. The service is provided by Stripe.com which allows online transactions without storing any credit card information.Necessary
__stripe_sidThis cookie is necessary for making credit card transactions on the web site. The service is provided by Stripe.com which allows online transactions without storing any credit card information.Necessary
https://q.stripe.com/This cookie is necessary for making credit card transactions on the web site. The service is provided by Stripe.com which allows online transactions without storing any credit card information.Necessary
mDetermines the device used to access the website. This allows the website to be formatted accordingly.Necessary
rc::aThis cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of our website.Necessary
rc::cThis cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of our website.Necessary
intercom.intercom-state-*, intercom-id-r376bbsr, intercom-session-r376bbsr, intercom.played-notificationsThese cookies are provided by Intercom and are necessary for the functioning of the chatbot shown on the website.Necessary
intercom.played-notificationsUsed by the website to determine which support notifications the user has been shown for Intercom.
elementorUsed in context with the website's WordPress theme. The cookie allows the website owner to implement or change the website's content in real-time.Necessary
_ga, _gid, _gatProvided by Google Analytics and used by Maji to track user activityAnalytical

8.3.    Before Cookies are placed on your computer or device, you will be shown a pop up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

8.4.    In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

8.5.    You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

8.6.    It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

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