Last updated on July 25th, 2022
1. We don’t sell your personal data to anyone and never will.
2. What we know about you is what you tell us and what you share while using our website and our app.
3. When you use our services, we receive some personal information from you like the type of device you’re using and your IP address. We use this information for improving our services and for keeping our services functional and secure.
4. We may use other providers to help us deliver our service, but we restrict their use of data to what you allow us to do and bind them to data protection laws and to strict confidentiality. For more detail on the current providers we work with, see the 'Who we share your personal data with' section.
5. We use your answers to our personality tests and surveys to determine what content is relevant to you and to improve our understanding of money personalities.
6. We use your financial data from your connected bank accounts to give you an aggregated view of your finances and hep you track your spending.
7. You are free to opt in and out of our email communication and from push notifications on the app.
8. You have control over your data and can delete it all directly from within our app (in your settings page). You can also contact us to do this for you.
9. Under the Data Protection Act (2018) and the European Union’s General Data Protection Regulation 2016/679 (GDPR), you have new rights and we have new responsibilities in ensuring that your personal data is stored and managed properly. This policy is designed to meet the requirements GDPR.
10. If you have any questions or comments regarding this policy, get in touch at email@example.com
Who we are
How and why we collect data
We only ask for personal information when we truly need it to provide a service to you. When you visit our services or take our online personality test you provide us with or we collect different pieces of personal data. We collect the data in order to provide you with our customized service and to improve our service offering. When you download the Quirk app we collect additional information about your device model, operating system, and actions taken in the app. If you also connect your bank account with Quirk we collect your bank balance and transaction history.
In regards to financial data, Quirk provides you with regulated account information services as an agent of Plaid Financial Ltd., an authorised payment institution regulated by the Financial Conduct Authority under the Payment Services Regulations 2017 (Firm Registration Number: 804718)for the provision of payment services, including account information services.
Personal data that we are collecting
Personal data is any data relating to a person who is identified or who can be identified from the data itself (so it would include things like a name, an identification number, or an online identifier). You may give us personal data by using our app, by visiting our website, or by corresponding with us. We (or third parties on our behalf) may collect and use any of the following categories of personal data about you:
Registration information – email, first name, last name
Account and transaction information – when you connect an account we collect information such as provider name, product type, transaction information (such as date, value, merchant) and balance information.
Unique user ID: This is an ID number which we assign to you when you sign up to use our service, to create your own unique data record so we can manage any support request.
Custom categories: We will collect and save any custom categories that you may choose to create in order to categorize your transactions within the app.
Technical Information – your IP address and general processing or monitoring data for performance and technical purposes.
Partner Services Information – information provided by a partner when you sign up for their service through an affiliate link on our app, website, or newsletter. This relates to the date you accessed their website and created an account with them. We always inform you when we’re providing you with an affiliate link.
Financial Services Records: This is record-keeping information (e.g. complaints) which we collect for regulatory purposes.
Who we share your personal data with
In order to provide you with our services and communicate with you we work with certain providers. These companies are authorised to use your personal information only as necessary to provide these services to us, and via contractual agreements that establish their responsibilities to protect your data.
Google - is our database provider through the Google Cloud Platform. The data is stored in the EEA (Ireland).
Plaid – is our Open Banking service provider. The data is stored in the EEA, US, and the UK.
Hubspot – is our email marketing platform. All data is stored in the EEA (Ireland).
Mixpanel – is our app analytics and event tracking provider. All data is stored in the US.
Intercom –is our customer support and communications platform for live-chat. All data is stored in the EEA (Ireland).
Our legal basis for using your personal data
(A) Performance of a contract: We collect your personal data in the performance of a contract or to provide a service and to ensure that services are completed and can be sent out to your preferred address inline with your communication and consent preferences. If you download our App and want us to deliver our services as described in our Terms, we can only do so by processing your personal data. We cannot provide our service without processing your personal data.
(B) Legal obligations: We collect and store your personal data as part of our legal and regulated obligation for business accounting and tax purposes.
(C) Legitimate interest: We also process your personal data on the basis of our legitimate interest, or the legitimate interests of others. Our legitimate interests are to:
• operate our website and App;
• carry out market research;
• to help our users navigate our App better;
• provide good services to our customers;
• research and develop new features that will improve our services;
• understand our user demographic, preferences and behaviours so we can improve our services
• track the use of the App and website and identify areas where we can improve performance or functionality (business and technical);
• to help us grow and develop our business and help our customers with the account opening process;
(D) Consent: If we rely on your consent for us to use your personal data in a particular way, but you later change your mind, you may withdraw your consent by contacting us at firstname.lastname@example.org and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide our app and associated services to you.
How long do we keep information about you?
We retain your information no longer than needed to provide to you with our services. When you decide to delete your Quirk account, we delete all information about you from our servers immediately, except that which is required for fraud detection. Any connected bank account that has expired in Quirk, we will delete all the data associated with it within 60 days of the consent expiration. You can also find Plaid’s data retention and deletion policy here, which is part of our contract with them: https://plaid.com/legal/
When completing the personality test, you have to provide an email address to receive the result of the test. We use your email only to send you the test result.
When signing up for our weekly newsletter you are providing your email address. We use your email only to send you the newsletter.
When signing up for our app, you are providing your email address. We use your email to send you information about product updates, the availability of our services, and to send you our newsletter.
OPT OUT: You may always opt out at a later date. You have the right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes you can unsubscribe through the unsubscribe button within any marketing communication or email us at email@example.com to opt-out.
What are your data protection rights?
We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access- you have the right to ask us for copies of your personal data.
The right to rectification - you have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete information you believe is incomplete.
The right to erasure - you have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing - You have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing - you have the right to object to our processing of yourpersonal data, under certain conditions.
The right to data portability - you have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.If you make a request, we have one month to respond to you.
If you would like to exercise any of these rights, please contact us at our email firstname.lastname@example.org or write to us at 48 Lofting Road, London, UK, N1 1ET.
Changes To This Policy
Your right to lodge a complaint with the ICO
If you feel that we have not handled information relating to you properly, or if you have contacted us about how we use that information and are unhappy with our response, you have the right to lodge a complaint with the Information Commissioner’s Office. Our registration number is ZA766716.
By phone: 0303 123 1113.