Privacy Notice

1. General

We are Mint FinTech Limited ('We', 'Our', 'Us') and operate under the name Mint Finance. We are registered with the UK data protection authority (the Information Commissioner's Office or ICO) under number 00015166354.

This notice describes how and why We collect and use your information when you use our service, card and app, or interact with us in other ways.

For information about what cookies are and how We use them, please read Our Cookie Notice.

2. Definitions

3. Contact us

If you have any questions about this notice or suggestions on any ways it can be improved, please contact Us however You prefer:

• Getting in touch through Our WeChat service account;
• Email Us at cs@mintfinance.app; or
• Write to Us at Mint FinTech Limited, Chase Business Centre, 39-41 Chase Side, London, United Kingdom N14 5BP.

We'll respond within a month in line with data protection laws, like the DPA 2018.

If Your application for a mint Wallet Account was rejected and You want Us to review that decision, please contact Us via the methods above.

4. Your rights

You have a right to:

• Access the personal data We hold about you, or to get a copy of it;
• Ask for a copy of Your personal data in a portable (machine-readable) format or make Us send it to someone else;
• Inform and request Us to correct any inaccurate data;
• Request Us to delete Your data, though for legal reasons We might not always be able to do it;
• Say no to Us using Your data for direct marketing and in certain circumstances 'legitimate interests', research and statistical reasons;
• Ask a member of staff to review an automated decision.

To do any of these things, please contact Us via the methods above.

5. Where We store or send Your data

We may store the data We collect from You outside the UK, or transfer it to organisations outside the UK. When We do this, We make sure that Your data is protected and that:

• The Information Commissioner (ICO) has deemed the country or organisation to provide an adequate level of protection for personal data; or
• We've agreed specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

If you'd like more information on how We transfer Your personal data out of the UK, please contact Us through in-app chat or by email cs@mintfinance.app.

6. Who We share Your data with

We use Your data in line with Our terms and conditions, which includes the potential consequences of third parties using Your data. Please refer to "The information We hold about you, and how We use it" section for further information.

7. How to make a complaint

If You have a complaint about how We use Your personal information, please contact Us through the App or send an email to help@mintfinance.app and we'll do Our best to fix the problem. You can also reach Our DPO at dpo@mintfinance.app.

If you're still not happy, You can refer Your complaint to the ICO's Office, the UK regulator for data protection issues. For more details, visit their website.

8. Changes to this notice

We'll post any changes to Our privacy notice on this page and if they're significant changes we'll let You know by email or in the app.

9. Information collection, processing, and storage

9.1 The information We hold about you

Information You give Us through the mint Finance App:

When You sign up for a mint Wallet Account:

• Personal details like Your name, date and place of birth;
• Contact details like Your home address (and previous addresses), email and phone number;
• Information about Your identity, such as a copy of Your ID document, personal description and photographs;
• Information about Your right to live in the UK and Your tax residency; and
• Financial details, such as Your employment status, annual income, residential status and monthly housing costs.

When You sign up for, or use, Our services:

• Details You give Us when You sign up for a specific service;
• Details You give Us which We pass to Our partners when You let Us know you're interested in their services;
• Information You give Us through chat, emails and in-App or on-Website forms; and
• Answers You give to surveys about mint Finance and Our services.

Information We collect or generate if You contact us:

If You contact Us another way, We collect the following information so We can help:

• The phone number you're calling from and information You give Us during the call (we record all calls);
• The email address You use and the contents of Your email (and any attachments); and
• Public details from Your social media profile (like WeChat) if You reach out to Us via any of these platforms, and the contents of Your messages or posts to us.

Information We collect or generate when You use the App and Our services:

We collect information about how You use the App to help improve features. This includes:

• Details about payments to and from Your mint Wallet Account;
• Details about who You send/receive money to/from (for example, the contact's name, email, phone number, and Transaction details);
• Details about services from Us and Our partners that You show interest in;
• Details about how You use Our app; and
• All the countries you're a tax resident in and Your Tax Identification Number for each one.

We may sometimes ask for information about Transactions through Our App to protect You and to help detect and prevent fraud and other suspicious activities.

Information We collect from Your phone:

We collect this information to keep Your data safe and to improve features for you. This includes your:

• Mobile network and operating system, so We can analyse how Our App works and fix any problems;
• IP address and device ID (we'll link Your mobile number with Your device);
• Mobile advertising ID, so We can share it with companies that help Us with advertising online (you can reset this ID or limit tracking in Your phone 'Settings');
• Location if you've authorised tracking, so We can help protect You against fraud; and
• Phone contacts who use mint Finance, if You have profile privacy settings turned on and they do too (we don't store Your full contact list).

Information We get from external sources:

When You sign up for a mint Wallet Account, We search Your record at:

• Fraud prevention agencies, KYC (Know Your Customer) and AML (Anti Money Laundering) service providers to fulfil Our legal duties.

For more information about data We collect from and share with any of these agencies, see 'Who We share Your data with'.

We may also collect information about You from public sources for AML reasons or market research. This includes:

• Official public records, like the Electoral Register or Companies' House; and
• Information published by the press or on social media.

If You sign up to a service from one of Our partners through the mint Finance App, they may share detail with Us about Your deal.

9.2 Our reasons for using Your information

Data protection laws say We need to have a lawful basis for using Your personal data. At least one of the following must apply:

• Contractual or legal duty
• Legitimate interest
• Public interest
• Vital individual interest
• Consent

In this section We explain which one We rely on to use Your data in a certain way.

We need to use Your data for a contract We have with you, or to enter into a contract with you. We use details about You to:

• Consider Your application;
• Give You the services We agreed to in line with Our terms and conditions;
• Send You messages about Your Account and other services You use if You contact us, or We need to tell You about something;
• Exercise Our rights under contracts we've entered into with you, like managing, collecting and recovering money You owe us; and
• Investigate and fix complaints and other problems.

We need to use Your data to comply with the law. We:

• Confirm Your identity when You sign up or contact us;
• Check Your record at immigration and fraud prevention agencies;
• Prevent illegal activities like money laundering, tax evasion and fraud;
• Keep records of information We hold about You in line with legal requirements;
• Adhere to laws and regulations (these mean We sometimes need to share customer details with regulators, tax authorities, law enforcement or other third parties);
• Compare information We hold about Your Account with Your tax residency information to make sure We don't have a reason to doubt it.

We need to use Your data for Our legitimate interests, or those of a third party.

This means using data in a way that You might expect Us to, for a reason which is in Your and/or Our (or a third party's) interest and which doesn't involve overriding Your privacy rights.

We use Your data for product development and marketing. We don't sell any of Your information. We:

• Tell You about products and services through the App or other channels, like social media companies, based on how You use Our products and services and other information We hold about you;
• May also exclude ads on this basis. We do this so We can make sure Our marketing is useful. That includes instructing platforms to show or not show mint Finance adverts to existing customers;
• Share limited identifying information about You with social media companies, other communication platforms, and analytics and search engine providers, including Your mobile advertising ID and hashed versions of the email address and phone number You give us;
• May use the personal information You share with Us to test third party services;
• Track, analyse and improve the services We give You and other customers and how You respond to ads We show;
• May ask for feedback if you've shown interest in a service. We do this so that We can make Our products better and understand how to market them;
• Use the personal information You share with Us and data You create from using the App to suggest mint Finance features or products you'd find useful. If You don't want Us to do this, You can opt-out in the App; and
• Share insights with the public about spending or saving trends based on data that doesn't personally identify you.

We use Your data to maintain security and business management. We:

• Protect the rights, property or safety of us, Our customers or others;
• Carry out security and maintenance checks to make sure Our App, Website and other services run smoothly for you;
• Manage mint Finance's business risk and finances, and protect Our customers and staff;
• Share information with fraud prevention agencies; and
• Share Your name, title and Account number with other banks and building societies, so that people paying You can confirm the name they have matches the name We hold in Our records. This helps Us fight financial crime.

We share Your information with companies so they can help Us provide Our services (see 'Who We share Your data with'). We'll ask for Your consent to:

• Record any issues You want Us to know about so We understand how to best support You (if the information is sensitive, We need a second lawful basis, see 'Our reasons for using special category information');
• Tell You about our, or Our partners, products and services by email or push notification if We think they're of interest to you;
• Help protect You against fraud by tracking the location of Your phone if you've authorised it (iOS);
• Show Your profile picture in the App if You add one;
• Show Your profile picture and name to mint Finance contacts in their App if You have not turned off Your profile privacy settings.(If You pay someone, they'll see Your name regardless. It's Our legal duty to show this, so You can't opt out); and
• Share information about You with companies We work with when We need Your permission (see 'Who We share Your data with').

You don't have to share information about yourself. But if You don't, You may not be able to use some, or any, of Our services.

We may need to process sensitive information about customers that data protection laws call 'special category' data. This is information that can reveal a person's:

• Racial or ethnic origin
• Political opinions
• Religious or philosophical beliefs
• Trade union membership
• Genetic or biometric data (if used for identification purposes)
• Information concerning a person's health, sex life or sexual orientation

Data protection laws say We need a second lawful basis to use special category data. This can be: explicit consent, exercising legal rights in connection with an employment relationship, protecting vital interests, establishing, defending or exercising legal claims or reasons of substantial public interest. In this section We explain which lawful basis We rely on to use Your special category data in a certain way.

We need to process information when it's necessary for reasons of substantial public interest:

• Use facial recognition technology to identify people who use Our services in the mint Finance App. We do this because it's necessary for reasons of substantial public interest to prevent or detect unlawful acts; and
• Record information about Your health if it's necessary to protect Your economic well-being if you're at risk, and seeking consent would be unreasonable or negatively impact Our ability to help you.

We may share information about You (generally with law enforcement in an emergency), when it's necessary to protect your, or another person's, vital interests, such as Your or another person's life. And You cannot consent.

We have Your explicit consent. We record any issues You want Us to know about relating to Your health, so We understand how to best support you.

9.3 Who We share Your data with

Companies that give services to us:

Here We mean companies that help Us provide services You use, and need to process details about You for this reason. We share as little information as We can and encrypt and/or make it impossible for the recipient to identify You where possible (for example, by using a User ID rather than Your name). These are:

• Companies that make Our mint Debit Cards;
• Card producers and networks, like Mastercard;
• Card processing partners;
• Analytical, Know Your Customer (KYC) and cyber security service providers that help Us with identity verification or fraud checks;
• Cloud computing power, storage and software providers;
• Our business intelligence and analytics platform provider;
• Companies that help Us with functional analytics (to help Us solve technical problems with the app, for example);
• Companies that help Us with marketing (we won't share identifiable personal data with third parties for their own direct marketing unless You give Us permission, and You can opt out any time);
• Software companies that We use to email you, or for processing and storing emails with you;
• Companies that help Us with customer support;
• Companies that help Us with fraud prevention;
• Companies that offer benefits or rewards through special programmes You sign up to in the app;
• Some merchants that We work with to offer You cashback, so they can confirm Your purchase qualifies for cashback. To find out how each merchant handles Your information, please read their privacy notices;
• Companies that print written statements and notices; and
• Companies that manage Our CCTV and security if You visit Our offices.

Fraud prevention agencies (FPAs):

When You apply for an Account, We check Your record with FPAs like Cifas. During the application process and after You become a customer, We may share information about You with them to help prevent fraud and money laundering when it's in Our 'legitimate interest'.

If We detect fraud, We may stop activity on Your Account or block access. Other organisations may use information We share with FPAs about fraud to refuse their services, finance or employment. For more information about the details We collect from and share with Cifas, and how they'll use Your data, see Cifas' Fair Processing Notice.

Anyone You give Us permission to share it with:

We tell You in the App when We need Your consent to share Your data with:

• Companies that introduce their own services via the mint Finance App, like insurance or e-commerce;
• Other apps; and
• People you've asked to represent you.

Law enforcement and other external parties:

We may share information about You with:

• Authorities that spot and stop financial crime, money laundering, terrorism and tax evasion if the law says We have to, or if it's necessary for other reasons;
• The police, courts or dispute resolution bodies if We have to;
• Local health authorities, such as Adult Social Services, to safeguard Your wellbeing;
• Other banks to help trace money if you're a victim of fraud or other crimes, or if there's a dispute about a payment; and
• Any other third parties where necessary to meet Our legal obligations.

Other Mint Group companies:

We may share Your details with people or companies if We change the structure of Our group of companies, merge with another company, or get bought by another company.

9.4 When We make automated decisions

We sometimes use computers to make decisions. We do this to decide if:

• We can give You a mint Wallet Account based on Your age, residency, nationality, financial position and other circumstances, like the results of anti-money laundering and sanctions checks;
• We need to take action, like freezing a Transaction or Account because We suspect fraud or money-laundering against mint Finance or a customer. Our computers decide this based on patterns in Our data, like an account or policy being used in a way that fraudsters work;
• We complete initial assessments for disputed Transactions You raise through the app; and
• Our services and products, or those of companies We work with, are suitable for You so that We can tailor Our marketing.

We'll tell You in the App once we've made these decisions. You can ask for a member of the team to review a decision through chat. If Your application for a mint Wallet Account was rejected and You want Us to review that decision, please contact Us using the details above.