Privacy policy

Who are we?

We are Harbour Technologies Limited (company number 14077133) of 22-24 Church Street, Lancaster, England, LA1 1NP (“Harbour”). Registered with the ICO as a data controller with registration reference ZB434906. 

We’ll be the “controller” of the information you provide to us.

What does this Privacy Policy cover?

We at Harbour take the privacy of your personal data seriously. This policy:

• sets out the types of personal data that we collect about you;
• explains how and why we collect and use your personal data;
• explains how long we keep your personal data for;
• explains when, why and with who we will share your personal data;
• explains the effect of refusing to provide the personal data requested;
• explains where we store your personal data and whether we transfer your data outside of the UK;
• explains the different rights and choices you have when it comes to your personal data;
• explains how you can contact us.

What personal data do we collect about you?

We will collect certain personal information about you in the course of your relationship with us. This information may include:

• Registration Information: this includes your name, date of birth, address, email address, phone number and your username and password for accessing the app. 
• Financial Information: this includes your bank account details and details of your bank account transactions. 
• Transaction Information: this includes details relating to payments you have made and/or received.
• Technical Data: this includes your IP address, log-in data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, other technology on the devices you use to access the app and other metrics we may collect on the way in which you use the app.
• Marketing Preferences: this includes your preferences in receiving marketing from us and any third parties connected with us.

Where do we collect personal data about you from?

We may collect personal data about you from the following sources:

• Directly from you. This is information you provide to us when registering for and using our services.
• Directly from a third parties: Such as open banking services and compliance services so that we can provide the service and ID verification services so that we comply with necessary regulations.

How and why do we use your personal data?

Under data protection law, we can only use your personal information if we have a lawful reason for doing so. In order to use your personal information, we rely on the following legal bases:

• processing is necessary for us to be able to provide our service to you;
• processing is necessary to comply with our legal obligations;
• processing is necessary for the purposes of legitimate business interests pursued by us having properly considered the rights of all individuals to whom the processing relates;
• you have provided your consent to us using your personal information for a particular purpose.

In particular, we use your personal data for the following purposes:

• to provide our service to you;
• to carry out anti-money laundering checks and to verify your identity;
• to maintain and update our customer records;
• to prevent unauthorised access and modification to our systems;
• to undertake screening for financial and other sanctions or embargoes;
• to analyse the way in which our services are used and to further develop the way in which our services are used;
• to contact you to discuss the services you receive from us (and any changes to them);
• to respond to any questions or concerns you have raised;
• to comply with any obligations that the law imposes upon us;
• to otherwise carry out our obligations arising under our contract with you.

We will not use your information for any other purpose unless we are required to do so by law.

We also collect, use and share “aggregated data” such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law providing that it is effectively anonymised and does not directly or indirectly reveal your identity.

How long do we keep your personal data?

How long we keep your information will depend on the purpose for which we use it.

We only keep your information for as long as is reasonably necessary for the purposes set out in this Privacy Policy and to fulfil our legal obligations. We have internal rules that set out how long we retain information. 

We will keep your personal information while you have an account with us, or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law.
  

For example, we are obliged to keep most information relating to the service we provide to you for 6 years after you have stopped using our service. However, we will keep your Financial Information for as short a period as is reasonable after you have stopped using our service. Further details on this are available on request using the contact details set out in the “How you can contact us?” section below.

Who do we share your personal data with?

We may share your personal information with:

• third party service providers who perform functions on our behalf and who also provide services to us, such as our banking partners and technology service providers, professional advisors, IT consultants carrying out testing and development work on our business technology systems;
• other third parties: when we believe in good faith that an applicable law requires it; at the request of governmental authorities conducting an investigation; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, our business or the public.

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As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us, your personal information will be disclosed to such entity. These third parties will be required to comply with all our obligations under this privacy notice.

What happens if you do not provide us with the information we request or ask that we stop processing your information?

Where we need to collect personal information to comply with a legal obligation or in connection with the contract we have with you and you fail to provide that personal information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services).

Do we make automated decisions concerning you?

No, we do not carry out automated decision making or automated profiling.

Do we transfer your personal data outside the UK?

We do not generally transfer personal data out of the UK. Some of our third party service providers may transfer personal data outside of the UK or the EEA but only where our contract with them allows for it and they do so in a way that complies with the UK’s data protection laws.

How do we keep your personal data secure?

We have appropriate security measures to prevent personal information from being accidentally lost or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. 

In addition, we:

• implement proactive and defensive security measures on an ongoing basis throughout our software development lifecycle
• use data encryption, both at rest and in transit;
• have role based restricted access to data;
• carry out background checks on all employees in roles which may put them in contact with your personal information.

What rights do you have in relation to the personal data we hold on you?

Under data protection law, you have the following rights:

What does this mean?

1. The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Privacy Policy.

2. The right of access

You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy).This is so you’re aware and can check that we’re using your information in accordance with data protection law.

3. The right to rectification

You are entitled to have your information corrected if it’s inaccurate or incomplete.

4. The right to erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

5. The right to restrict processing

You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

6. The right to data portability

You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.

7. The right to object to processing

You have the right to object to certain types of processing, including processing based on our legitimate interests and processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).

8. The right to lodge a complaint

You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.

9. The right to withdraw consent

If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.

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How can you make a request to exercise your rights?

To exercise any of the rights above, or to ask a question, contact us using the details set out at the end of this Privacy Policy.

How will we handle a request to exercise your rights?

We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.  

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

• baseless or excessive/repeated requests,
• further copies of the same information.

Alternatively, the law may allow us to refuse to act on the request.

How can you contact us?

If you have questions on the processing of your personal data, would like to exercise any of your rights, or are unhappy with how we’ve handled your information, please contact us at help@harbour.fi

If you’re not satisfied with our response to any complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the UK Information Commissioner who may be contacted at ico.org.uk or by telephone on 03031231113.