Privacy policy 

Nudge Global Limited is committed to protecting and respecting your privacy. This Privacy Policy sets out the basis on which your personal information will be used by us.

We collect and process your personal information to enable you to receive information from your contacts relating to the financial education content we have within our platform.

Our legal status under UK data protection law is therefore that of a “Data Controller”. This is a legal term used in the UK Data Protection Legislation to signify the person who controls what to do with any given personal information.

Please read the following Privacy Policy carefully to understand how we will use and what we will do with your personal information.

What is the ‘Legal Basis’ that we are holding and processing data?

Under the current Data Protection Legislation we are currently storing and process personal data under the legal basis of ‘Legitimate Interest’. Our online Financial Education services has been designed to enable people to share some of the content we have within our application with their friends and family so that more people can benefit. As a result, we have a Legitimate Interest in processing this data.

Whose personal information do we collect?

Nudge Global Limited needs to collect and use certain types of personal information in order to operate our web-based online Financial Education system. We collect information from individuals who are part of the nudge service and decide to add additional details to share content.

What personal information do we collect?

We collect the following personal information:

  • Name

  • Email Address

  • Mobile number

In addition, it may occasionally be required by law to collect and use certain types of personal information of this kind to comply with the requirements of government departments for business data.

How is your personal information used?

We will use personal information provided to:

  • Provide content to you that somebody feels you would benefit from

  • Administer our business and comply with laws and regulations

  • Aggregate information for management information purposes and reporting at a high level to nudge, however, this is only done at a generic level and your personal data is not shared with anybody.

How long is personal information kept?

We keep the data for as long as your contact(s) are with nudge and there is a contract to provide services on their behalf.  If they leave the scheme then your access to nudge will cease and your data will be deleted.

Similarly, if nudge ceases to have a contract for services we will arrange for the deletion of all the data that we store on the expiry or termination of the contract.

The requirements of Data Protection Laws

We regard the lawful and correct treatment of personal information by Nudge Global Limited as very important to our successful operation, and to maintaining confidence between us and our users. We ensure that our organisation treats personal information lawfully and correctly. To this end, we fully endorse and adhere to the ‘Principles of Data Protection’, as set out in the Legislation.

In particular, without your consent or first amending this Privacy Policy to reflect and change in our usage of personal information:

  • We will not use your personal information for any purpose that is incompatible with this Privacy Policy

  • We will only collect sufficient personal information from you to operate our online Financial Education system and not any more

  • We will endeavour to keep your personal information up to date and we will immediately amend the data where we are advised that the data is inaccurate

  • We will not retain your personal information longer than necessary unless required to do so by law

  • We will operate appropriate technical and organisational processes to protect your personal information against unauthorised or unlawful access or processing and against accidental loss or destruction. The detailed measures we take are described elsewhere in this Privacy Policy

  • We will not transfer your personal information to a country outside the UK or European Economic Area unless adequate and sufficient safeguards are in place to protect your personal information to the standards that apply within the UK/EEA

Additional privacy measures

We have put in place internal training and management processes to enable us to perform in accordance with this Privacy Policy. In particular, we have a person with specific responsibility for data protection in our organisation.

Our designated Data Protection Officer is the Operations Director, Keir Tutt. This person is responsible for ensuring that:

  • Everyone managing and handling personal information understands that they are responsible for following good data protection practice

  • Everyone managing and handling personal information is appropriately trained to do so

  • Everyone managing and handling personal information is appropriately supervised

  • Anybody wanting to make enquiries about handling personal information knows what to do

  • Anybody handling queries about personal information knows what to do

  • Queries about handling personal information are promptly and courteously dealt with

  • Methods of handling personal information are clearly described

  • A regular review and audit is made of the way personal information is managed and new technology and security measures considered

  • Methods of handling personal information are regularly assessed and evaluated

  • Performance with handling personal information is regularly assessed and evaluated

  1. Security arrangements for your personal information

We believe that security of your personal information is core to you using and trusting our online system.

When handling personal information, security must be paramount and we have rigidly pursued a maximum security policy. We utilise TLS 1.2 Encryption, implemented with digital certificates from Digicert, the recognised leader in this field. This protects web Internet and all information transferred to and from our online system from unauthorised access and snooping. This ensures that personal information can be uploaded to the platform with the confidence that personal information is secure.

The personal information stored on our system is also further protected from unauthorised access by ‘firewall’ systems and monitoring tools. These prevent access by anyone other than legitimate users. With our powerful monitoring and logging tools, we can trap any events which may be associated with attempted security breaches.

Our online system is hosted by Rackspace. This company was selected by us because they have an outstanding reputation for both security and a robust protocol, which further protects our Site.

With whom is your personal information shared?

Nudge Global Limited does not share your personal information with any other party unless required to do so by law, court order or other Governmental authority or if it believes that such action is necessary to protect and defend the rights, property or personal safety of Nudge Global Limited, our online Financial Education system of its visitors.

IP Addresses and Cookies

We may collect information about your computer including where available, your IP address, operating system and browser type for system administration and as part of our audit trail process. In addition, we obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies are pieces of information that a website transfers to your hard drive to store and sometimes track information about you. Most web browsers automatically accept cookies, but if you prefer, you can change your browser to prevent that.

However, you may not be able to take full advantage of the platform if you do so. Cookies are specific to the server that created them and cannot be accessed by other servers, which means that they cannot be used to track your movements around the web. Although, they do identify a user’s computer, cookies do not personally identify users and passwords and credit card information are not stored in cookies.

We may use cookies to hold the brand last accessed for the login page where this is not specifically referenced.

You are not obliged to accept cookies – go to www.cookiecentral.com for instructions on how to disable cookies.

Access to information

Data Protection law gives you various rights including the right to access information held about you.

The list below of the rights you have give a brief explanation.

You can ask for a summary of the personal information that we hold about you upon your written request. To make a request, you should send an email to support@nudge-global.com and provide your name and email address. You also have the right to request details of the information that we are storing relating to you, we will provide you within a reasonable timescale (and no later than one month) a list of all the information.

You can also request at any time that the personal information we hold about you is updated or corrected if you believe it is incorrect.

You also have a right to object to your data being used for the provision of Financial Education, this can take two forms:

  1. The right to have your data removed completely from the application (also known as the right of erasure); This does mean that you will no longer be able to take part in the service and you won’t receive Financial Education in the future.

  2. The right to unsubscribe; in this instance we will ensure that you do not receive any communication from us in the future, however, your details will continue to be stored on our application.

To exercise these rights please send an email to support@nudge-global.com providing your name and email addres and the nature of your request. For the avoidance of doubt

  • A request for removal will result in the data being completely deleted, subject to the confirmation from nudge. However, this must be explicit and clear that all data is to be removed.

  • Any other request will result in the unsubscription from the notification service and data will not be deleted.

Your acceptance of these terms

By using our online Financial Education system, you agree to the collection and use of your personal information by Nudge Global and to this Nudge Global Limited Privacy Policy.

If we change our Privacy Policy in any way, we will post these changes on this page. We recommend that you visit this Privacy Policy as often as you can to check for any changes.

Please e-mail any questions, concerns or comments you have about these policies to keir.tutt@nudge-global.com or write to us at Nudge Global Limited , Thomas House, 84 Eccleston Square, London SW1V 1PX.

March 2020