Ernest Limited ("We") are committed to protecting and respecting your privacy.
This policy (together with our terms and conditions and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting ernest.ai or by using our personal finance information management service that allows you to consolidate and track your financial information (the "Service"), you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 1998 (the "Act"), the data controller is Ernest Limited of 7/10 Chandos Street, 4th Floor, London, England, W1G 9DQ. We are registered with the Information Commissioner's Office (registration number ZA198396)
Information we may collect from you
We may collect and process the following data about you:
- Information you give us. You may give us information about you by accessing ernest.ai ("site"), by using the Service (by whether through Facebook Messenger or otherwise) or by corresponding with us by phone, e-mail or otherwise. The information you give us may include:
- Name, address and email address;
- Date of birth;
- Phone number;
- Country of residence; and
- Financial information.
- Information we collect about you. We may collect, store and use the following information about your computer, mobile device or other item of hardware through which you access the site or the Service:
- Your visits to and use of the site or the Service (including without limitation your IP address, browser/platform type and version);
- Internet Service Provider;
- Operating system;
- Referral source/exit pages;
- Length and frequency of visit
- Page views; and
- Service usage: frequency, number of questions, analytics most used, questions the service could not identify correctly.
- Information we receive from other sources. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. In particular, we receive the following personal information about you from our trusted partners, Salt Edge Inc. (“Salt Edge”) and Leetchi Corp S.A. (“Mangopay”) who assist us in providing some or all of the Service.
- Bank account balance and transaction history;
- Credit card information; and
- Direct debits or standing orders.
Please note: online banking login details are not received or stored by Ernest Limited. These are stored by SaltEdge that are guarded in line, with their privacy and security policy.
Salt Edge helps us to provide the Service by accessing your bank and e-money account information. By using the Salt Edge service, you agree to abide by their privacy and security policy. You also agree and grant Salt Edge permission to aggregate your personal data, which may then be stored outside of your own country to the extent permitted by applicable law.
Facebook Messenger helps us to communicate to you and provide you the Service. By using the Facebook Messenger service, you agree to abide by their messenger policy.
Uses made of the information
We use information held about you in the following ways:
- IInformation you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
- to provide you with information about other services we offer that are similar to those that you have already signed-up to or enquired about;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing user of the Service, we will only contact you by electronic means (e-mail, SMS or instant messaging service) with information about services similar to those which were the subject of a previous service provided to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you have not given such consent we will not use your data in this way, or pass your details on to third parties for marketing purposes;
- to notify you about changes to the Service; and
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
- Information we collect about you. We will use this information:
- to administer our site and the Service and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site and the Service to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our Service, when you choose to do so;
- as part of our efforts to keep our site safe and secure; and
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
- Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of your information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in a certain geographic location).
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
- We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets. However any such disclosure will not disclose information about identifiable individuals but only with aggregate information about our users (for example, we may inform them that we have X thousand customers that check weekly their spend on food).
- If Ernest Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms and conditions or our service terms and conditions and other agreements; or to protect the rights, property, or safety of Ernest Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where we store your personal data
Any payment transactions will be encrypted using SSL technology.
Access to your devices and their security is however outside of our control and you are responsible for the security of these.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com.
Our service may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Access to information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
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