What is this document?

 

At Moorwand, we are committed to safeguarding your privacy. We want you to know how we collect, use, share, and keep information about you and the choices that are available to you when you request our products or services.

 

In this privacy statement, we describe how Moorwand, in its capacity as the data controller, collects, uses, shares, and keeps information about you in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the General Data Protection Regulation). For the contact details of our Data Protection Officer, please see the “Query or Complaint” section.

 

From time to time, we may change this privacy statement. Depending on the nature of the change, we will inform you of any such change through our written communications with you or through our website, www.moorwand.com

 

Information Collected

 

This privacy statement describes how we (and our Service Providers) collect, use, share, and keep information about you. The types of information we collect will depend on which product or service you request or use. We collect Personal Information about you from:

 

– the application form for a card account and other documents you provide to us;
– when you request or utilise products, goods or services (e.g., use your card to make transactions with merchants, ATM operators, use concierge services or book travel);
– you, through the way you communicate with us and use your account (e.g., telephone numbers provided during servicing calls);
– any research, surveys or competitions you enter or respond to or any marketing offers for which you register;
– third parties, such as in marketing lists which we lawfully obtain from Business Partners.

 

Use of Information

 

We use your Personal Information: (i) where it is necessary for the performance of a contract or compliance with a legal obligation (e.g., due diligence financial institutions are required to perform before approving card accounts); (ii) for our legitimate interests, such as to establish, exercise or defend legal claims, prevent fraud and/or enhance our products or services; or (iii) where we have obtained your consent, such as for marketing purposes. More specifically, we use your Personal Information to do the following:

 

Deliver products and services, including to:

 

– process applications for our products, including making decisions about whether to approve your application;
– administer and manage your account, such as whether to approve individual transactions;
– communicate with you through email, SMS or any other electronic methods about your accounts, products, and services and to update you about new features and benefits attached to the products or services that you requested;
– service and manage any benefits and insurance programmes provided along with the products or services that you requested;
– answer questions submitted to us by you and respond to your requests;
– advertise and market products and services for Moorwand and our Business Partners, including to:
– present content that is personalised in accordance with your preferences;
– help determine whether you may be interested in new products or services;
– communicate promotions and offers to you (by mail, e-mail, telephone, SMS, via the internet or using other electronic means) in relation to products and services that may interest you or which are similar to your existing Moorwand products and services;

 

Improve our products and services and conduct research and analysis, including to:

 

– better understand our customers, their needs, preferences and behaviours;
– analyse whether our ads, promotions and offers are effective;
– conduct testing (to ensure security and when we update our systems), data processing, website administration and information technology system support and development;
– allow you to give feedback by rating and reviewing our products and services and those of our Business Partners;
– produce data analytics, statistical research, and reports on an aggregated basis;
– monitor and/or record your telephone calls with us or our Service Providers to ensure consistent servicing levels (including staff training) and account operations;

 

Manage fraud, operational and security risks (using automated processes and/or manual reviews) including to:

 

– review and approve individual transactions including those you make through digital channels;
– detect and prevent fraud or criminal activity;
– safeguard the security of your information;
– develop and refine our risk management policies, models and procedures for applications and customer accounts, relying upon information in your application or relating to your creditworthiness and account history (if applicable);
– comply with laws and regulations, including to establish, exercise or defend legal claims and assist in dispute resolution;

 

Process your application (or personalise your offers) for our products and services (using automated processes and/or manual reviews) including to:

 

– help us better understand your financial circumstances and behaviour so that we can make decisions about how we manage your existing accounts and what other products or services can be extended to you; and

 

Information Sharing

 

We do not share your Personal Information with anyone except as described below. We will share your Personal Information only with your consent or as required or permitted by applicable law, such as with:

 

– regulatory authorities, courts, and governmental agencies to comply with legal orders, legal or regulatory requirements, and law enforcement requests;
– collection agencies and external legal counsel to collect debts on your account;
– our Service Providers, regulatory authorities, law enforcement, governmental agencies and third parties such as your bank, building society or other payment card issuers;
– our Service Providers who perform services for us and help us manage your account and/or operate our business;
– Business Partners, including co-brand partners, to provide, deliver, offer, customise or develop products and services to you, either jointly or separately. We will not share your contact information with Business Partners for them to independently market their own products or services to you without your consent. However, we may send you offers on their behalf with your consent. Please note that if you take advantage of an offer provided by a Business Partner and become their customer, they may independently send communications to you. In this case, you will need to review their privacy statement and inform them separately if you wish to decline receiving future communications from them;

 

Cookies

 

A cookie is a piece of data stored on the visitor to a website’s hard drive containing information about the visitor that can only be read by the server that placed cookie onto the visitor’s hard drive. Moorwand employs “cookie” technology.

 

Most browsers are initially set up to accept cookies. You can set Your browser to block cookies entirely, delete cookies when You leave the website, notify You when You receive a cookie giving You the chance to decide whether or not to accept it, or limit the subsequent retrieval of cookies by the website. In addition, there are number of privacy-enhancing tools and software that You may purchase that will enable You to identify and block cookies on a selective basis. Please note that for some websites that require an authorisation, cookies are not optional. Users choosing not to accept cookies will probably not be able to access those websites where cookies are not optional.

 

International Transfer of Data

 

We process, transfer and access your Personal Information through our systems in the UK and outside the European Economic Area (EEA), to operate our business, process transactions on foreign purchases, administer your account or provide products and services to you.

 

Regardless of where we process your information, we will take appropriate steps to ensure the adequate level of protection for your information in other countries outside the UK or EEA including the USA, where data protection laws may not be as comprehensive as the UK or EEA.

 

Security

 

We use organisational, administrative, technical and physical security measures to safeguard your Personal Information and to help ensure that your information is processed promptly, accurately and completely. We require Service Providers to safeguard your Personal Information and only use your Personal Information for the purposes we specify.

 

Retention of Information

 

We will keep your Personal Information only as long as we need to deliver the products and services that you requested, unless we are required to keep it for longer periods because of law, regulation, litigation or regulatory investigation purposes. For example, your Personal Information will be stored by for 7 years after you close your account, due to Inland Revenue requirements. If your account is in default, and the balance remains unpaid or unsettled, in accordance with fair lending practices and our risk and debt recovery policies, this information could be retained by us for longer periods of time and considered if you choose to apply for products in the future.

 

When your Personal Information is no longer necessary for legal or regulatory needs, to administer your account or to deliver the products and services you have requested, we will take reasonable steps to securely destroy such information or permanently de-identify it.

 

Access to your Information

 

We encourage you to check regularly that all Personal Information held by us is accurate and up to date. If you believe that any information we hold about you is incorrect or incomplete, you may ask us to correct or remove this information from our records. We recommend that you email marketing@moorwand.com.

 

Your Rights

 

You have the right to access, update, erase, change or correct your Personal Information. More specifically, you have the right to:

 

– withdraw your consent for our use of your Personal Information at any time, where our processing is based on your consent;
– restrict and/or object to the use of your Personal Information;
– request a manual review of certain automated processing activities where your rights are affected; and
– request a copy of your Personal Information we have about you.

 

If you want to exercise any of your rights or if you have any questions about how we process your Personal Information , you can email marketing@moorwand.com. You also have the right to contact the Information Commissioner directly at www.ico.org.uk.

 

Marketing Choices

 

You can choose how you would like to receive marketing communications, including direct marketing – whether we send them to you through postal mail, email, SMS and/or telephone. If you wish to opt out of receiving marketing from us you can contact marketing@moorwand.com. If you choose to not receive marketing communications from us, we will honour your choice.

 

Please be aware that if you choose not to receive such communications, certain offers attached to the products or services you have chosen could be affected.

 

We may contact you to ensure that the information we hold about your marketing preferences is up to date. Also, we will still communicate with you in connection with servicing your account, fulfilling your requests, or administering any promotion or program in which you have elected to participate.

 

Query or Complaint

 

If you have questions about this privacy statement or how your information is handled or wish to make a complaint or exercise your rights email marketing@moorwand.com

 

Glossary

 

(we, our, us) – Moorwand as identified at the beginning of this privacy statement.

 

Business Partners – third parties with whom we conduct business and have a contractual relationship, such as processors, suppliers, distribution partners, co-brand partners, insurance and travel service providers, and parties that accept branded cards for payments of goods/services purchased by you (i.e., merchants).

 

Personal Information – any information relating to an identified or identifiable natural person, such as name, addresses, telephone number, and email address and other information specific to that individual such as demographic details and transaction information.

 

Service Providers – any vendor, third party and/or company that provides services or performs business operations on our behalf, such as printing, mailing, and other communications services (email, direct mail, etc.), marketing, data processing and outsourced technology, servicing, collections, ad management, auditors, consultants and professional advisors.