wildcard Privacy and Cookie Policy
This Privacy and Cookie Notice (“Notice”) describes how Wildcard (also referred to as “Wildcard”, “we”, or “us”) will make use of your personal data when you are using our Services. This Notice comprises the following sections:
This Notice describes how Wildcard (also referred to as “Wildcard”, “we”, or “us”) will make use of your personal data when you are using our Services.
It explains the types of information we collect, the purposes for which we are using personal information and the legal grounds on which we rely. The Notice sets out how we share personal information with third parties, for how long we store personal information and how we use cookies.
It also describes your data protection rights, including the right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “Your data protection rights” section.
When we use capitalised terms in this Notice, these terms have the meaning explained in our Terms of Service or Competition Rules.
We are Wildcard, a company incorporated in England and Wales with company registration number 12712989 and registered address at International House, 36-38 Cornhill, London, England, EC3V 3NG We control the information we collect about you when you use our Services and we are the data controller for the purposes of data protection law.
Wildcard provides you with regulated account information services as an agent of Truelayer Ltd., an authorised payment institution regulated by the Financial Conduct Authority under the Payment Services Regulations 2017 (Firm Registration Number: 901096) for the provision of payment services, including account information services. Truelayer Ltd. registered offices are at Part Ground Floor (East), Floors 6 and 7, The Gilbert, 40 Finsbury Square, London, EC2A 1PX. Turelayer Ltd. (company registration number 10278251) is authorised by the Financial Conduct Authority under the Payment Services Regulations 2017 for the provision of payment initiation and account information services (firm reference number 901096). Truelayer Privacy Policy can be found here: Truelayer Privacy Policy.
When we refer to “personal data” or “personal information” in this Notice, we mean information that relates to you. We collect and process your personal data when you interact with us through our website and our app and when you use our Services. This includes:
We collect this information from you, when you provide it to us directly or when we collect it through our website or app using technical means, such as cookies. Sometimes, we also collect information about you from third parties, in particular:
| Purpose | Legal grounds |
|---|---|
| To allow you to create a Profile with us, set up an Electronic Money Account with our Partner Institution, use our Services and enter any of our Competitions, claim any prizes and have such prizes awarded to you. | Contractual necessity, to the extent the information we collect for these purposes is necessary to fulfil our contract with you; Our and our Partner Institution’s legitimate interests, to the extent the information is necessary to allow our Partner Institution to fulfil its contract with you and ensure the Partner Institution Terms are complied with. |
| To communicate with you about your Profile and your use of our Services, such as your entry in Competitions and to effectively manage your Profile (e.g. send you an account activation email, process any changes you make to your Profile, keep track of your Credit Balance and use of Credit). | Contractual necessity, to the extent the information is necessary to fulfil our contract with you (for example, to inform you about how you can claim your prize); Our legitimate interests, to the extent the information is necessary to process queries you make in relation to your Profile and account and to effectively manage our relationship with you as our user and your Profile to effectively manage your Profile, your Credit Balance, account expiry and cancellation. |
| If you communicate with us (for example, if you email or call us), we will use your information for dealing with your queries, training and customer service purposes. | Contractual necessity: where you provide information that is necessary for us to fulfil our contract with you and provide our Services. Our legitimate interests to handle your queries and provide you with requested information, to ensure high customer service quality and to train staff in responding to such requests. |
| To carry out identity and credit reference checks, to verify the bank account information you provide to us and to establish your eligibility to use our Services, in accordance with our Terms of Service and Competition Terms. | Our legitimate interests to protect the integrity of our Services and business operations and to ensure that our users are able to comply with our terms and do not misuse our Services. Legal requirements, to the extent we are required by law to verify any of your information in order to provide our Services to you. |
| To administer and effectively manage our Competitions, including selecting winners and disqualifying entries. | Our legitimate interests to ensure the effective management of our operations and the integrity of our Services. |
| To publish your information on our “winners” page of our website and app, when you win in any of our Competitions. This information may include your name, home city and photography. | We rely on our legitimate interests to publish this information. You can object to publishing your information at any time by emailing us at: [email protected] |
| To send you marketing communications about our Services (and the products or services of third parties that we make available through our Services), or to send you our newsletter when you sign up to receive this and to monitor whether you open our emails and/or click on URLs in our emails. | We rely on your consent, where this is required by law. Otherwise, we rely on our legitimate interest to keep you informed of products and services on our platforms, when we are allowed by law to do so. |
| To carry out market research and create marketing profiles about our users and understand their preferences in relation to our Services (including the products and services available through these). | Our legitimate interests to carry out marketing activities. |
| To display our advertisements to you on other platforms, such as social media platforms or to display on our website and app advertisement which we think you might like. | Your consent, where we obtain this information by using cookies or where otherwise required by law. Otherwise we rely on our and third parties’ legitimate interests to carry out marketing activities and inform you of products and services we think you might like. |
| To compile statistics and analysis about the use of our Services and use such statistics to enable us to provide a better service, features and functionality to you and other users. | Your consent, where we obtain this information by using cookies. Our legitimate interests (where consent is not required by law) so as to ensure the smooth and effective functioning of our Services, to make sound business decisions about our products and services and to design, inform and deploy our business strategies. |
| To protect the security of our Services, information systems and assets, to monitor compliance with our Terms of Service and Competition Terms, to prevent fraud and other prohibited or illegal activities in relation to our Services. | Our legitimate interests to protect our business assets against fraud, misuse, and illegal activities or security threats. |
| To respond to legitimate requests for the disclosure of information, made by public authorities, law enforcement or governmental bodies or under a court order. | Legal requirement, to the extent we are obliged under law to process such requests. Our legitimate interests to assist legitimate investigations carried out by official authorities. |
| To respond to complaints, to protect our legal rights and to establish, exercise or defend legal claims relating to our platforms and/or our products and services. | Our legitimate interests to protect our legal rights. |
| For tax, accounting, record keeping and audit purposes. | Legal requirements, to the extent the law requires that we use your information (for example, to comply with our tax obligations). Our legitimate interest to effectively manage our business, audit our business processes and make informed business decisions. |
We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out in the “Contact Us” section below.
Wherever we rely on consent, you will always be able to withdraw that consent at any time, although we may have other legal grounds for processing your data for other purposes, such as those set out above. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing purposes, at any time. You can do this by (i) clicking on the unsubscribe link in the relevant marketing communication, (ii) changing your marketing preferences through your Profile, or (iii) emailing us using the contact details under the “Contact Us” section below.
We do not use your personal information to make automated decisions about you which have a legal or similarly significant effect on you.
A cookie is a small text file that is saved in your computer or mobile device when you use the Services. It enables our website to remember your actions and preferences (such as language preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to our website or browse from one page to another. When we talk about cookies in this section, this term includes technologies that we are using which serve a similar purpose, for example web beacons, tags and tracking pixels or software development kits (SDKs) in our mobile apps.
How do we use Cookies and how long do they last?
| Cookie categories | Retention periods – Up to... |
|---|---|
| Essential Cookies: These are required to enable core functionality and provide you with the service you have requested. Without these cookies, services that you have asked for cannot be provided. For example, essential cookies enable us to remember the items you place it in the shopping basket so that you can order products. | These are usually session cookies and expire when you close the browsing session or your app, or shortly thereafter. |
| Performance Cookies (Audience measurement): To analyse the use, performance and design of our Services, detect errors and improve user experience. For example, this type of cookie enables us to understand how often you are using our Services, to recognize that you have visited our websites before and to identify which parts of our Services and which sections of our website are most popular, for example by allowing us to see which pages visitors access most frequently and how much time visitors spend on each page. | 30 days |
| Functional Cookies (Content customisation): To deliver a better user experience, and build up customer usage patterns and profiles. For example, this type of cookie ensures that the information displayed when you use our Services (e.g. on your next visit to our website) will match up with your user preferences (such as language preferences, font size or auto-fill options). | 30 days |
| Advertising Cookies (Behavioural advertising): To personalise our website, deliver customized advertisements to you, or contact you directly where you have separately consented to such communications, in a way which is relevant to you and which matches your interests by, for example, using information about products you have browsed or ordered on our website. | 30 days |
We use essential cookies by default, but we rely on your consent to use cookies that are not essential. Note that by disabling essential cookies, you will not be able to use our Services; by disabling functional or performance cookies your user experience may be disrupted but you will still be able to use our Services.
Third parties using cookies through our Services for their own purposes
Our Services use some cookies that are not controlled by us. This may occur when the part of the Services you are using makes use of a third-party analytics or marketing automation/management tool or includes content displayed from a third party. You should review the privacy and cookie policies of these parties to find out how they use cookies and the information they collect through cookies.
How to manage cookies?
We rely on your consent to use cookies that are not essential. We will seek your consent when you first access our Services (for example via our app or our website): you are free to refuse to consent to some or all of these non-essential cookies.
You can withdraw your consent at any time.
We do not provide the option to manage essential cookies – these are activated by default.
We will store your personal information for as long as it is required for us to fulfil the purposes for which we have collected it, as described in this Notice, and for such further period that is necessary to comply with our legal and regulatory obligations, to exercise our legal rights and to protect our business from legal claims.
We will share your personal information with third parties, as described below:
This may include sharing with social networks such as Facebook actions that you take on our Services such as your visits to our website, your interactions on our website, information collected from cookies or similar technologies and the ads you see. This allows us to measure the effectiveness of our advertising, improve our marketing practices, and helps us deliver more relevant advertising to you and people like you (including on social media). We are Joint Data Controllers with Facebook Ireland for this processing and have agreed with Facebook our respective responsibilities for complying with data protection law. In terms of this division of responsibility, in summary, Wildcard provides you notice but Facebook is the primary contact if you wish to exercise your rights under data protection law in respect of this processing. Further information, including how Facebook enables you to exercise your data protection rights, and subsequently processes your information as independent data controller can be found in Facebook Ireland’s Data Policy.
Where we need to transfer your personal data outside the European Economic Area (“EEA”), the United Kingdom or Switzerland, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses or a vendor’s Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided on request.
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions upon which we rely when responding to any request you make.
To exercise any of these rights you can get in touch with us using the details set out in the “Contact us” section below. If you have unresolved concerns, you have the right to complain to the data protection authority, which in the UK is the Information Commissioner’s Office.
We may from time to time update this Notice if there is a change to the way we use personal data or if this is required by a legal or regulatory change. Any new version of this Notice will be published on our website.
If you have questions in relation to this Notice or on how we use your personal data at Wildcard or if you would like to exercise your data protection rights, you can get in touch with us by writing to:
Wildcard