Ducit.ai Ltd (we) are committed to protecting your personal data and respecting your privacy.
We are committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure to it, we have put in place suitable physical, electronic and operational procedures to safeguard and secure the personal data we collect about you. In particular, we protect your personal data by deploying SSL and high standard encryption algorithms. We also ensure that we meet security standards imposed by law that are applicable to the operation of Ducit.ai.
Ducit.ai Ltd is the controller and is responsible for your personal data (collectively referred to as “we”, “us” or “our” in this policy). We are registered as a data controller under registration number ZA494747 with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We are authorised and regulated by the Financial Conduct Authority under registration number 816952.
Our full details are:
You have the right to make a complaint at any time to the ICO (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.
This version was last updated on Thursday August 29, 2019. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email or when you next start the App or log onto one of the Services Sites. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
We may collect, use, store and transfer different kinds of personal data about you as follows:
We explain these categories of data below (“Description of categories of personal data”).
We will collect and process the following data about you:
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
Please see below (“Glossary: Lawful Basis”) to find out more about the types of lawful basis that we will rely on to process your personal data.
We will only send you direct marketing communications by email if we have your consent. You have the right to withdraw that consent at any time by contacting us.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
|Purpose/activity||Type of data||Lawful basis for processing|
|To install the App and register you as a new App user||Identity|
|To provide you with the Services (categorised transactions, affordability data, fraud detection) by linking your bank accounts and associated Transaction Data to the App||Identity|
Marketing and Communications
Performance of a contract with you
|To share income and expenditure analytics with financial services organisations||Identity|
|To manage our relationship with you including notifying you of changes to the App or any Services||Identity|
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
|Storing and using Transaction and Financial Data to develop and improve our AI models and algorithms||Financial|
|Necessary for our legitimate interests (to train and improve the accuracy of our AI models and analytics and to improve our Services of income and expenditure assessment, credit risk monitoring, affordability data and fraud detection)|
|To administer and protect our business and this App including troubleshooting, data analysis and system testing||Identity|
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)|
|To deliver content and advertisements to you|
To make recommendations to you about goods or services which may interest you
To measure and analyse the effectiveness of the advertising we serve you
To monitor trends so we can improve the App
Marketing and Communications
Necessary for our legitimate interests (to develop our products/Services and grow our business)
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table above (“Purposes for which we will use your personal data”):
We do not transfer your personal data outside the European Economic Area (EEA).
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
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. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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.
For example, we may use your Financial, Transaction, Location and Device Data to train artificial intelligence models to improve our Services of credit risk, affordability and fraud detection (for our legitimate interests). We will retain this personal data for as long as reasonably necessary for this purpose.
In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research, development or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
Please click on the links below to find out more about these rights:
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at firstname.lastname@example.org.
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External third parties such as debt advice charities and financial services organisations acting as joint controllers.
Service providers acting as processors based in the UK who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
You have the right to: