Privacy Policy

  1. Introduction

CNDA is dedicated to safeguarding and respecting your privacy. This Privacy Policy elucidates how we gather, utilize, and divulge your personal data when you engage with our website or utilize our services.

  1. Definitions

"Personal data" refers to any information that can uniquely identify an individual, such as name, email address, phone number, or IP address. "We" or "us" pertains to CNDA Limited, a company registered in England and Wales with company number 14161688. "You" or “your" refers to the user of our website or services.

  1. Collection of your Personal Information

We may collect personal data from you, such as your email address, name, address, or telephone number. Additionally, we may gather anonymous demographic information, such as postal code, which is not personally identifiable. Personal data encompasses any information capable of identifying an individual, excluding anonymized data. We may process the following categories of personal data about you:

We may utilize Customer Data, User Data, Technical Data, and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and measure or understand the effectiveness of the advertising we serve you. Our lawful basis for this processing is legitimate interests, which is to grow our business. We may also utilize such data to send other marketing communications to you. Our lawful basis for this processing is either consent or legitimate interests (namely to grow our business).

If we're required to collect personal data by law, or under the terms of the contract between us and you, and you don't provide us with that data when requested, we may not be able to perform the contract (e.g., deliver goods or services to you). If you fail to provide requested data, we may have to cancel a product or service you've ordered, but we'll notify you at the time.

  1. Collection of Personal Data

We may collect personal data from you in the following ways:

  1. Purpose of Data Collection

We collect your personal data for the following purposes:

  1. Lawful Basis of Processing

We process your personal data on the following lawful bases:

We'll only use your personal data for the purpose it was collected for or a reasonably compatible purpose if necessary. If we need to use your details for an unrelated new purpose, we'll inform you and explain the legal grounds for processing. We may process your personal data without your knowledge or consent where required or permitted by law. We don't engage in automated decision-making or any type of automated profiling.

  1. Use of Technical and Anonymous Data

We may use technical and anonymous data, such as details about your browser, visit duration, page views, navigation paths, frequency of website usage, time zone settings, and device technology details.

  1. Controlling Information about You

When you fill in a form or provide your details on our website, you're agreeing to:

If you've consented to us using your information for marketing purposes, you can easily change your mind through one of the following options:

  1. Marketing Communications

Our lawful basis for processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business). Under the Privacy and Electronic Communications Regulations, we may send you marketing communications if (i) you've made a purchase or requested information from us about our goods or services or (ii) you've agreed to receive marketing communications and haven't opted out of receiving such communications. Before we share your personal data with any third party for their own marketing purposes, we'll obtain your express consent. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at info@cndapay.com. Opting out of receiving marketing communications doesn't apply to personal data provided as a result of other transactions, such as purchases or warranty registrations, etc.

  1. Recipients of Personal Data

We may share your personal data with the following third parties:

  1. Retention Period for Personal Data

We'll retain your personal data for the following periods:

  1. Rights of the Data Subject

You have the following rights in relation to your personal data:

You can exercise your rights by contacting us at info@cndapay.com. Any request for access to the data may be subject to a fee to meet our costs in providing you with the details of the information we hold about you. Please submit your request in writing via email to: info@cndapay.com. Please note you may be asked to verify your identity before the request can be accepted.

  1. Security of your personal information

The data we collect is primarily stored within the European Economic Area (“EEA”). However, there may be occasions during technical maintenance and security updates when the data we collect from you may be transferred to and stored at a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA. By submitting your personal information, you agree to this transfer, storage, and processing. We'll take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy. All information that you provide to us is stored on our secure servers. All data captured will be encrypted using SSL technology. We have implemented security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also grant access to your personal data only to those employees and partners who have a business need to access such data. They'll process your personal data only on our instructions, and they must keep it confidential. We have procedures in place to deal with any suspected personal data breach, and we'll notify you and any applicable regulator of a breach if we're legally required to do so. Unfortunately, the transmission of information via the internet is not 100% secure. While we'll do our best to protect your personal information, we can't guarantee the security of your information transmitted to and from our website – it's at your own risk. Once we've received your information, we'll use strict procedures and security features to protect it.

  1. International Transfers of Data

Countries outside of the UK or European Economic Area (EEA) don't always offer the same levels of protection for your personal data, so UK and European law has prohibited transfers of personal data outside of the UK and EEA unless the transfer meets certain criteria. Many of our third-party service providers are based outside the UK and European Economic Area (EEA), so their processing of your personal data will involve a data transfer outside the UK and EEA. Whenever we transfer your personal data out of the UK and EEA, we'll do our best to ensure a similar degree of data security by ensuring at least one of the following safeguards is in place:

  1. Contact Information of the Data Controller

The data controller for your personal data is:

CNDA Limited, 167-169 Great Portland Street, London, UK. W1W 5PF. info@cndapay.com

 

The data controller for your personal data in relation to card programme management services is:

Payload Limited, a limited company registered in England and Wales with Registration Number 14606631 and registered office Epworth House, 25 City Road, London, England, EC1Y 1AA.

 

The data controller in relation to any personal data which you submit in relation to the CNDA Debit Mastercard and electronic money account is:

Transact Payments Limited (“TPL”). TPL is an e-money institution, authorised and regulated by the Gibraltar Financial Services Commission. TPL’s registered office address is 6.20 World Trade Center, 6 Bayside Road, Gibraltar, GX11 1AA and its registered company number is 108217. When you apply for a CNDA Debit Mastercard, you accept TPL’s Privacy Policy which is provided to you when you sign up for a card, is available within the CNDA Pay mobile application and is available in this document below here. We encourage you to read the TPL Privacy Policy.

 

  1. Complaint Procedure

If you have any complaints about the way we handle your personal data, you can contact the UK Information Commissioner's Office (ICO) at https://ico.org.uk/.

  1. Updates to this Privacy Policy

We may update this privacy policy from time to time. Any changes to this Privacy Policy in the future will be published on this page. It's your responsibility to check periodically to see any updates or changes and to be informed of how we're protecting your information. If we make any material changes, we'll notify you by email.

  1. Cookies

Our website uses cookies. Cookies are small text files that are stored on your computer by your web browser. They're used to remember your preferences and settings when you visit our website. You can disable cookies in your web browser settings. However, disabling cookies may limit your ability to use some of the features on our website.

  1. Additional Information

For more information or questions, please contact us at info@cndapay.com.

 

Version 2.0

Last updated: [25/04/2024]

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CNDA Pay are a co-brand of Payload Ltd, who act as a Programme Manager under Transact Payments Limited (TPL), a company which is incorporated and registered in Gibraltar with company number 108217 and registered office is at 6.20 World Trade Center, 6 Bayside Road, Gibraltar, GX11 1AA. Transact Payments Limited is a licensed payments and electronic money institution. Your account and related payment services are provided by Transact Payments Limited. Whilst Electronic Money products are not covered by the Financial Services Compensation Scheme, your funds will be held in one or more segregated accounts and safeguarded in line with Part 4 of the Financial Services (Electronic Money) Regulations 2020.