At Muloot Money we take your privacy seriously. Please read our privacy policy below to find out how we use your personal details and keep it safe.
Who are we?
Aspire Commerce Group (Group) is made up of Aspire Commerce Group Limited and different legal entities which are subsidiaries of Aspire Commerce Group Limited. This privacy policy is issued on behalf of the Group so when we mention "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Group responsible for processing your data.
We will let you know which entity will be the controller for your data when you purchase a product or service with us. Aspire Payments Limited t/a Muloot Money is the controller and responsible for this website.
The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data
includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.Contact Data
includes your address, email address and telephone numbers.Financial Data
includes bank accounts, confirmation of payee information, credit searches and payment card details.Transaction Data
includes details about payments to and from your account and other details of products and services you have purchased using your account.Technical Data
includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.Profile Data
includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.Usage Data
includes information about how you interact with and use our website, products and services.Marketing and Communications Data
includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- set up payments or conduct foreign exchange transactions;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data is collected from the following parties:
- analytics providers such as Google based outside the UK; and
- search information providers such as Experian Limited based inside the UK.
- Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as Clear Bank based inside the UK.
- Identity and Contact Data is collected from data brokers or aggregators such as LexisNexis Risk Solutions based inside the UK.
- Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register based inside the UK.
How we use your personal data
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
Fraud prevention and money laundering checks
We may use your personal details in order to conduct identity checks as required by law as a measure to prevent money laundering.
The personal data we have collected from you at application or any stage may be shared with fraud prevention agencies. We are required by law to review transactions and report any which may be suspected of being related to money laundering activities.
Automated decision making
We may process your personal data without human intervention to evaluate your personal situation, such as transactional history and account-opening anniversary events. We may do this to decide what marketing communications might be suitable for you, to analyse statistics and to assess risks.
This is all done on the basis of our ‘legitimate interests’, to protect our business, and to develop and improve our products and services. If we use automated decision making including profiling activity to assess your application, this will be performed on the basis of it being necessary to perform the contract.
How long do we hold on to your information?
We keep your data whether you become a Muloot Money customer or not.
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.
Sharing your information
We will not sell, share, or rent your information to others except as set out in this policy.
We may share your information with:
- Organisations that provide operational services relating to the performance of the services that you use. Our strategic partners are, where required by law, authorised and regulated to the required standards.
- Suppliers, such as card producers, when it is necessary in order to fulfil our obligations to you in setting up and maintaining your account.
- The purchaser of the company or the purchaser of its assets in the event of the sale of the company or its assets.
While our website may contain links to other sites, we are not responsible for their privacy practices or content.
Transferring your information overseas
We might transfer your personal data outside of the UK and EEA (European Economic Area). In this event, we will always take all necessary steps to ensure the data is held securely and processed in line with applicable laws to the UK.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Opting out of marketing preferences
You are free to opt out of receiving all marketing communications from us and our strategic partners at any time by contacting us.
Should you be opted in to receive email correspondence, there is an unsubscribe link in each email we send out, if you use this, we will not send any unsolicited mail to your registered email address.
Communications regarding changes to existing products or services held, our terms, conditions and policies are important and sometimes critical. You may not opt out of receiving these communications.
Use of cookies
For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy.
Reviewing, correcting or updating your personal data
If any of your details are recorded incorrectly and need to be changed, please contact us with details of the required changes and the reasons for the change. Proof of change of address may be needed.
You can contact us in the following ways:
Email: customerservices@mulootmoney.com
Post: Muloot Money, PO Box 3968, Chester, CH1 9RR
Telephone: +44 345266 8758
Customer Services opening times:
Monday to Friday 09.00 – 17.30
If we make any changes to our privacy policy, we will notify you by email to your registered email address so you will always know what information we collect, how we use it and under what circumstances, if any, we disclose your personal data.
If we want to change the use of personal information we have already collected about you, we will notify you by email. If you have not provided us with your email address you must regularly check the website for an up to date version of the privacy policy. It is then up to you to decide whether you will let us use your information in this way. We will use information in accordance with the most recently published privacy policy.
What are your rights?
Under GDPR (General Data Protection Regulation), you have:
- The right to be informed
- The right of access
- The right of rectification
- The right of erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling
If you would like further information about data protection you can visit the Information Commissioner’s Office (ICO) at https://ico.org.uk/
The ICO is the UK’s independent authority set up to uphold information rights in the public interest and data privacy for individuals. We comply with all ICO regulatory and statutory requirements..
Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (https://ico.org.uk/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please do contact us in the first instance.