1. Definitions and Interpretation
- “Personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
- “Account” means an account required to access and/or use certain areas and features of Our Site;
- “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 Part 14, below; and
- “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003
- For the purpose of the Data Protection Act 2018 (Act), the data controller is Maji Financial Wellness Services (“Maji/We/Us/Our”) of 37 Oakfield Gardens, Beckenham, Kent BR3 3AY, United Kingdom. Our ICO Registration Number is: ZA521090
2. What Does This Policy Cover?
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
4. Your Rights
- Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of personal data. This document should tell you everything you need to know, but you can always contact us to find out more or to ask any questions;
- The right to access the personal data we hold about you;
- The right to have your personal data rectified if any personal data we hold about you is inaccurate or incomplete;
- The right to be forgotten – i.e. the right to ask us to delete or otherwise dispose of any of your personal data we have;
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability. This means that you can ask us for a copy of your personal data held by us to use with another service or organisation;
- The right to object to us using your personal data for particular purpose or purposes;
- Rights with respect to automated decision-making and profiling. For our Beta product we will not be conducting any automated decision making or profiling.
- For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details in Part 9.
- Further information about your rights can be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
- If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Data Do We Collect?
- We collect personal data (your name and email address) from you when you register your account with Maji.
- If you are an employee, your employer also gives us personal 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 and pension contribution rate.
- We also collect personal data (your name and email address) if you complete our contact form.
6. How Do We Use Your Data?
- Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for the performance of the service(s) we provide, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. We may process your data for any or all of these reasons. Your personal data may be used for one or more of the following purposes:
- Providing and managing your account.
- Supplying our services to you and/or to your employer or organisation.
- Communicating with you.
- We will not share any of your personal data with any third parties for any purposes. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
7. How and Where Do We Store Your Data?
- We will keep your personal data for as long as you have a registered personal account with Maji. You can terminate this account whenever you want to.
- Your data will be stored:
- on our secure servers located in the European Economic Area (“EEA”) for purposes of delivering Maji’s services;
- on an external service provider for the purposes of Maji providing the services you have signed up for and to service your account
- on Intercom for the purposes of data analytics and communications via our chat support function.
8. Data Security, Retention and Disposal
- Data security
- 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. 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 website; any transmission is at your own risk.
- Data retention
- We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. You can terminate this account whenever you want to.
- Your personal data will be securely held by Maji until such time as you choose to delete your account.
- You can unsubscribe from Maji emails at any time by clicking on the ‘unsubscribe’ button at the bottom of our emails.
- Data Disposal
- When you delete your account, your personal data will be erased, deleted, destroyed, or otherwise disposed of.
9. How Can You Access Your Data?
- If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such data is held). This is known as a ‘subject access request’.
- All subject requests should be made in writing and sent to the email or postal addresses shown in Part 9.
- There is not normally any charge for a subject request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a reasonable fee may be charged to cover administrative costs in responding, or we can lawfully refuse to deal with the request.
- We will respond to your subject access request within less than a month and, in any case, not more than one month from receiving it (calculated from the day of the week after the request is received). Normally, we aim to provide a complete response, including a copy of our personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be informed of progress.
10. How Can You Control Your Data?
- In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data.
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Can You Withhold Information?
- You may access certain areas of Our Site without providing any personal data at all.
- All Cookies used by and on Our Site are used in accordance with current Cookie Law.
- 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.
- 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.
- 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.
- 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.
13. Use of Intercom Services
- We use third-party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website or use our product.
- We may also use Intercom as a medium for communications, either through email, or through messages within our product(s).
- The Intercom Messenger Apps and Apps in Inbox products may also provide you with access to other third party applications such as Stripe. You should consult these third parties’ privacy notices for further information on their use of your personal data.
- As part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience.
14. Contacting Us