Last updated November 04, 2024
Welcome to Money Owls, a marketplace that connects individuals seeking financial guidance to financial advisers within the United Kingdom. Please carefully read this Privacy Policy before accessing the website located at www.moneyowls.co.uk (“the Website”), Money Owls mobile application available for download at Google Play Store and Apple App Store (“the App”) or any services and content provided through the Website or the App, collectively referred to as the “Platform.”
This Privacy Policy applies to Clients or Advisers who sign up for an Account on the Platform, as well as to anyone visiting the Website or subscribing to Money Owls mailing list.
Money Owls processes all Personal Data that it collects from its Users in compliance with the UK General Data Protection Regulation (UK GDPR) as implemented by the Data Protection Act of 2018.
This Privacy Policy explains how Money Owls collects, uses, shares, and protects Personal Data when acting as the Data Controller. It provides Users with important information about our data handling practices for all interactions conducted on the Platform. Please be aware that this Privacy Policy does not extend to the processing of Client Personal Data by Financial Advisers who may access such data through the lead handling process outlined in the Terms and Conditions. Once a Client’s personal information is transferred to an Adviser via the lead handling process, the Adviser independently becomes the Data Controller for any data they receive, and Money Owls is no longer responsible for the handling of such data by the Adviser.
Please carefully read this Privacy Policy before accessing the Platform and/or signing up for a User account. If You disagree with this Privacy Policy, please do not access or use the Platform.
1. Definitions
The following words, whenever used in this privacy policy, shall have the meaning given hereunder:
| “Adviser” or “Financial Adviser” | refers to qualified individuals who register an Adviser Account on the Platform (as defined in clause 4 of the Money Owls Terms and Conditions) to provide Financial Guidance or Coaching services to Clients. |
| “Client” | refers to an individual who registers a Client Account (as defined in clause 4 of the Money Owls Terms and Conditions) on the Platform to receive Financial Guidance or Coaching. |
| “Call Monitoring” | refers to the practice of recording and reviewing calls between Clients and Advisers, with Client consent, for quality control and compliance purposes. |
| “Call Session” | refers to a prearranged video conference facilitated through the Platform, conducted between a Client and an Adviser. The duration of these Call Sessions may be selected by the Client at the time of their In-App Purchase. |
| “Controller,” “Data Subject,” “Personal Data,” “Processing,” “Processor,” and “Supervisory Authority” | shall have the same meaning as defined in the UK GDPR. |
| “Data Subject Request” | means the exercise by a Data Subject of their privacy rights in accordance with the UK GDPR. |
| “Financial Guidance or Coaching” | refers to general guidance provided by Advisers based on hypothetical scenarios or general principles, that does not fall within the ambit of a regulated activity as covered by the Financial Conduct Authority (FCA). |
| “In-App Purchases” | refers to the purchases as described in Clause 6 of the Money Owls Terms and Conditions. |
| “Lead Handling Process” | refers to the formal procedure that allows an Adviser to acquire a Client’s contact information from Money Owls, with the Client’s consent. |
| “Login Credentials” | means the username and password that enable a User to sign in to their Account and access the Platform features and functionality. |
| “Money Owls,” “We” “Us” or “Our” | refers to the operator of the Platform. |
| “Party” or “Parties” | refers to Clients and Advisers individually and collectively, as applicable. |
| “User” | refers collectively to all individuals who register and use the Platform, including both Clients and Advisers. |
| “User-Generated Content” | refers to the content submitted by Users on or through the Platform as defined in clause 10 of the Money Owls Terms and Conditions. |
| “You” or “Your” | refers to the individual User using the Platform, whether as a Client or a Financial Adviser, as applicable in the given context. |
2. Personal data collection and usage
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1. Types of Personal Data Collected
The Personal Data We collect varies depending on how You use the Platform, whether as an Adviser, Client, or Website Visitor. The Personal Data types We may collect include:
- Basic Identification Information: Full name, email address, phone number, and date of birth.
- Financial Information (Clients only): Details such as income, expenditure, assets, liabilities, and personal financial goals.
- Professional Information (Advisers only): Qualifications and certifications.
- Interaction Content: Content from call recordings, messages between Users, and any communication Users have with Money Owls.
- User-Generated Content: Any other content that Users upload or generate within the Platform such as public profile data, ratings and reviews.
- Transaction Data: Information related to In-App purchases, such as purchased Call Session / packages, scheduled Call Session dates, and times.
- Survey and Promotion Responses: Information provided by Users who participate in surveys, contests, or other promotional activities on the Platform.
- Log Data: Information about Users’ interactions with the Platform, including browser type, pages visited, visit times, and IP address.
- Device Information: Details about the User’s device, such as model, operating system, and unique device identifiers.
- Cookies and Tracking Data: Information collected through cookies and other tracking technologies to monitor User activity on the Platform.
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2. Collection and Use of Personal Data
Money Owls collects and processes Users’ Personal Data in two primary ways:
- Voluntarily Submitted Personal Data: This includes all data provided directly by Users when they interact with the Platform, such as during Account registration, profile completion, transactions (In-App Purchases), and use of specific Platform features.
- Data Collected Automatically: Data automatically gathered during a User’s interaction with the Platform, such as through cookies, device information, and log data.
Legal Basis for Processing Personal Data
Money Owls processes Personal Data only when there is a valid legal basis, which may include:
- Consent: Where Users have given their express consent for specific data uses.
- Performance of a Contract: To fulfil obligations related to the provision of the Platform.
- Legal Obligations: To comply with regulatory or legal requirements.
- Legitimate Interests: To support Money Owls’ business operations in a way that does not override Users’ data protection rights.
Refusal to Provide Personal Data
Users may decline to provide their Personal Data when requested by Money Owls. However, please be aware that declining to provide any mandatory Personal Data may limit Money Owls’ ability to offer specific Platform services to You.
Voluntarily Submitted Data
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2.1. Account Registration Data
When registering for an Account, either as an Adviser or Client on the Platform, You may be asked to provide certain Personal Data, which may include:
- Full name
- Email address
- Phone number
- Date of birth (for Clients)
- Financial information such as income, expenditure, assets, liabilities, and personal financial goals (for Clients)
- Qualification certificates (for Advisers)
Purpose of Collecting Account Registration Data
Money Owls processes the Account Registration Data to:
- Create and manage Your Account on the Platform
- Enable secure login and access to relevant Platform features and functionalities
- Facilitate Client-Adviser matching and interactions
- Communicate with You as needed, including for Account-related notifications or Platform updates
Legal Basis for Processing
The lawful basis for processing Your Account Registration Data is the performance of our contract with You, as the Personal Data specified above is essential for providing Our Platform effectively.
Retention Period
Money Owls will retain the Personal Data provided during Account registration only as long as necessary to fulfil the purposes for which it was collected, as outlined above. Upon Account termination, We will securely delete Your Account Registration Data within 90 days, unless required to retain specific data for a longer period to comply with legal obligations, or other lawful bases permitted under the UK Data Protection Act 2018.
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2.2. Transaction Data
When Clients make an In-App Purchase, Money Owls collects information related to the transaction, including:
- Details of the purchased Call Sessions, such as whether it is a one-off or recurring monthly Call Session, the duration of the purchased Call Session, the total amount paid.
- The dates and times of Call Sessions scheduled between Advisers and Clients and the Call Sessions completed in compliance with the Money Owls Terms and Conditions.
Purpose of Collecting Transaction Data
Money Owls processes Transaction Data for the following purposes:
- To provide scheduling information to both Clients and Advisers for purchased or booked Call Sessions.
- To calculate financial metrics, including Net Revenue and the Adviser’s share of earnings.
- To assist with support inquiries related to purchases, Call Session scheduling, or refund requests;
- For internal business operations, including reporting and compliance.
Legal Basis for Processing
The lawful basis for processing Transaction Data includes:
- Performance of a Contract: Processing this information is essential for fulfilling our contract with Users, as it enables the booking, scheduling, and delivery of Call Sessions on the Platform.
- Legal Compliance: Transaction Data is processed to meet Money Owls’ legal obligations, including accurate transaction management, internal accounting, and tax compliance. This data handling ensures that Call Sessions are delivered as scheduled and that all transactions are documented in compliance with relevant legal requirements.
Retention Period
Money Owls may retain Transaction Data for up to seven years from the date of the transaction, in accordance with tax regulations and legal obligations.
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2.3. Call Session Data
Money Owls records Call Sessions between Clients and Advisers for quality control and compliance purposes. Recordings are only made with the Client’s express consent prior to the commencement of each Call Session.
Purpose of Collecting Call Session Recordings
Money Owls processes Call Session recordings for the following purposes:
- To ensure the Call Session was delivered by the Adviser
- To monitor and improve the quality of the Call Sessions provided by Advisers through the Platform.
- To ensure that Financial Advisers adhere to Money Owls Terms and Conditions.
- To provide a record in the event of any disputes or complaints between the Parties.
Legal Basis for Processing
The lawful basis for processing Call Session recordings includes:
- Client’s Consent: The recordings are processed only after obtaining the explicit consent of the Client before the Call Session begins. Clients may refuse to grant their consent and in such cases the Call Session will not be recorded. Clients may also withdraw their consent at any time by notifying Money Owls, but this will not affect the legality of the processing prior to such withdrawal date.
- Legitimate Interests: Money Owls has a legitimate interest in maintaining the quality and compliance of its Platform, which is balanced against the Clients’ rights and expectations regarding their Personal Data.
Retention Period
Money Owls will retain Call Session recordings until such time that the Client withdraws their Consent. Please note that the Call Sessions may be retained by Money Owls if required for any ongoing legal proceedings.
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2.4. User-Generated Content Data
Money Owls enables Users to publish content on the Platform that is visible to other Users, such as the content displayed on User’s public profiles and Adviser ratings and reviews.
Purpose of Collecting User-Generated Content
Money Owls processes User-Generated Content for the following purposes:
- To enable prospective Clients to browse through Adviser profiles and make informed decisions before purchasing Call Sessions.
- To gather insights from Users to enhance and develop the Platform’s features and services.
Legal Basis for Processing
The lawful basis for processing User-Generated Content includes:
- User Consent: By submitting content such as ratings and reviews, Users consent to its collection and use as described in this Privacy Policy.
- Legitimate Interests: Money Owls has a legitimate interest in improving its Platform and the services offered by Advisers.
Retention Period
Money Owls may retain any ratings and reviews submitted by Clients on the Platform until the Client withdraws their consent. If a Client withdraws their consent, Money Owls may continue to use the content of the rating and review, provided that it can be anonymized to remove any identifying information.
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2.5. Support Request Data
Money Owls also receives Personal Data from Users when they send a support request to our customer support team. Support data may include a User’s name, email address, phone number and the content of the message (“Support Data”). Support data may also include any other Personal Data requested by Money Owls in order to service a User’s support request.
Purpose of Collecting Support Request Data
We use this data to understand and respond to Your support requests and to follow up with the User if required.
Legal Basis for Processing
The lawful basis for processing this information is our legitimate interest, which does not override Your privacy rights.
Retention Period
We will retain the support data for as long as You have an Account on the Platform or up to two years from the date of last communication. We may retain the content of the support request message by anonymising it for our internal business purposes.
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2.6. Marketing Data
We collect Your name and email address when You subscribe to receive marketing material from Us or participate in our surveys/promotions.
Purpose of Collecting Marketing Data
We use Your Personal Data to:
- Send You marketing material that We think You will find interesting;
- Create new service offerings and improve our Platform;
- Fulfil any other purpose specified at the time We collect Your information.
Legal Basis for Processing
The lawful basis for processing this Personal Data is Your consent, which You grant Us when You subscribe to receive marketing communication from Us or participate in our surveys or promotions.
Retention Period
We may process Your Personal Data for our marketing purposes until such time that You withdraw Your consent.
Automatically Collected Data
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2.7. Technical Data
We may automatically collect some technical data from You when You access our Platform, including but not limited to:
- Your Internet Protocol (IP) address,
- Your browser type and version.
We use this data for purposes including but not limited to:
- Making the Platform available on Your device;
- Maintaining and improving our Platform;
- Improving our User experience;
- Detecting and preventing fraud or other similar unauthorised activities;
- To send You system updates and alerts.
The lawful basis for processing this Personal Data is our legitimate interest, which does not override Your privacy rights.
Retention Period
We will delete this data within 30 days after the termination of Your User Account.
3. Sharing Your Personal Data
We will share and disclose Your Personal Data in the following situations:
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3.1. Client data with Financial Advisers
If a Financial Adviser identifies that You may benefit from FCA-regulated financial advice, Money Owls may reach out to You to obtain Your consent for sharing Your Personal Data with a regulated Financial Adviser. Upon receiving Your explicit consent, Your Personal Data will be shared exclusively with the Financial Adviser who purchases the lead from Money Owls. This sharing is intended solely to enable the Financial Adviser to contact You directly to discuss Your needs and provide You with regulated financial advice, should You choose to proceed.
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3.2. Third-Party Service Providers
We may engage third-party service providers to perform some services on our behalf, including but not limited to Platform maintenance, marketing, and support services. Your Personal Data may be disclosed to such third-party service providers only to the extent required for them to perform relevant functions on our behalf. In no event will these service providers use Your Personal Data for any purpose other than those specified in this privacy policy.
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3.3. Commercial Transactions
In the event We enter into any commercial transaction, such as a merger, acquisition, sale, or purchase, all Your Personal Data may be disclosed or transferred as part of such a commercial transaction.
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3.4. Protection of Rights or Fulfilment of Legal Obligations
We will disclose Your Personal Data to third parties in situations where We believe such disclosure is necessary to investigate or remedy any violations of our Agreement with You or to protect our rights and the rights of others. We will also disclose Your Personal Data in situations where We are required to do so by applicable law/regulation or legal process, such as to comply with a subpoena.
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3.5. With Your Consent
We may share Your Personal Data with third parties with Your express consent.
4. Transfer of Personal Data
We process Your Personal Data within the United Kingdom and/or the European Economic Area. We may make use of some tools and services that are provided by entities domiciled outside of the United Kingdom and EEA, where data protection laws are not as stringent as those in the UK and EEA. When We use such tools/services, Your Personal Data may be transferred and processed outside of the UK and EEA. Whenever such data transfer takes place, We will ensure that it complies with the Data Protection Act of 2018 and other applicable local privacy legislation.
5. Your Privacy Rights
You have the following rights relating to Your Personal Data:
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5.1. Right to access Your Personal Data
You have the right to request access to Your Personal Data or a copy of Your Personal Data by contacting Us.
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5.2. Right to rectification
If the Personal Data We process for You is incorrect, outdated, or incomplete, You have the right to rectify, update, or complete it by accessing Your Account on the Platform.
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5.3. Right to withdraw consent
To the extent the lawful basis of Our processing of Your Personal Data is Your consent, You have the right to withdraw Your consent at any time. You may withdraw Your consent from receiving direct marketing communication from Us by clicking the unsubscribe link at the bottom of our marketing emails, and We will cease processing Your Personal Data for direct marketing purposes.
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5.4. Right to the erasure of Personal Data
In limited circumstances, You may exercise Your right to request the erasure of Your Personal Data, such as where Your Personal Data is being processed unlawfully.
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5.5. Right to file a complaint
If You believe that Your Personal Data rights are breached, You have the right to lodge a complaint with the Information Commissioner’s Office:
The Information Commissioner’s Office
Water Lane,
Wycliffe House
Wilmslow
Cheshire SK9 5AF
Please note that We may request that You provide proof of Your identity before servicing Your data subject requests.
6. Security of Personal Data
The security of Your Personal Data is important to Us. We take all reasonable and financially viable steps to safeguard Your Personal Data from any unauthorised access, use, modification, destruction, or loss. We have integrated various security measures into the design of our Platform and our day-to-day operations. Although We make our best effort to safeguard Your Personal Data, You acknowledge that no mode of transmission over the Internet is one hundred percent secure; therefore, We cannot offer You any guarantees as to the absolute security of Your Personal Data. By using the Platform, You understand and accept that the transmission of data through the Platform is carried out at Your own risk.
7. Third-party links
Our Platform may contain links that will redirect You to third-party websites. Such third-party websites are not owned or operated by Us. These third-party websites are governed by their own legal terms and conditions and privacy policy. We advise our Users to review all third-party legal agreements before making use of such websites. You understand that the presence of any third-party links on our Platform does not constitute an endorsement of such a third party, and We cannot be held responsible for such a third party’s actions. Your decision to visit these third-party sites is entirely at Your own risk.
8. Data Controller
Money Owls is the Data Controller of all Personal Data collected through the Platform. You can request information regarding Money Owls privacy practices or exercise Your privacy rights by sending Your request in writing to: hello@moneyowls.co.uk.
9. Amendments
We reserve the right to make changes to this Privacy Policy by inclusion, modification, or removal of any part at any time. When We make any material changes to this Privacy Policy, We will notify You by email or by changing the last modified date on top of this privacy policy. You agree that it is solely Your responsibility to review this privacy policy when You revisit the Platform. Your continued use of the Platform after We post the updated privacy policy will constitute Your acceptance of such changes.
