PensionBee Privacy and Cookie Policy

1. Introduction

This is our privacy policy. It tells you how we collect and process data received from you through our services (including via our website and mobile app) and obtained from third parties. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it in line with the Data Protection Act 2018 and the UK General Data Protection Regulation (“UK GDPR”). If you have any comments on this privacy policy, please email them to contact@pensionbee.com.

2. Who We Are

PensionBee is the data controller for personal information we collect, unless otherwise specified. Here are our contact details:

• Our website address is www.pensionbee.com
• Our company name is PensionBee Limited
• Our registered address is 209 Blackfriars Road, London, SE1 8NL
• Our nominated representative is Jonathan Lister Parsons, Chief Technology Officer, and he can be contacted at contact@pensionbee.com

3. What we may collect

We may collect and process the following data about you:

• information you provide directly to us through our digital services, on any telephone conversations, over email, through the post or through our affiliated social media pages;
• identity information and documentation you provide to us online and offline;
• from third parties who we contact directly or indirectly using information you have provided to us;
• details of transactions you carry out through our services;
• details of your usage of our website and mobile app, the resources you use, how you interact with us and information about your device (e.g. your IP address, browser, operating system, etc.) or cookie settings;
• if you engage with a separate app or website that uses a PensionBee API (or whose API we use);
• when you provide information on behalf of somebody else pursuant to a power of attorney, the personal data which you provide about that person (including mental health information) may be processed as set out in this policy. In addition, information about your position as attorney will be held in accordance with this policy;
• a record of any correspondence between us including but not limited to email, live chat, post and recorded telephone conversations.

Under UK GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following bases applies:

• you have given consent to the processing of your personal data for one or more specific purposes;
• processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
• processing is necessary for compliance with a legal obligation to which we are subject;
• processing is necessary to protect the vital interests of you or of another natural person;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
• processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our direct debit processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

In most instances, we will process your data on the basis it is necessary for the performance of a contract to which you are party or in order to take steps at the request of you prior to entering into a contract.

4. Cookies

A ‘cookie’ is a piece of data from a website that is stored within a web browser that the website can retrieve at a later time. Cookies are used to tell the server that users have returned to a particular website.

All cookies used by and on our website are used in accordance with current UK law.

Our services use cookies or similar technology to collect information about your access to the services. Cookies are pieces of information that include a unique reference code that a website transfers to your device to store and sometimes track information about you. Where our mobile app also stores information on your device to achieve similar goals as cookies, this section will apply.

A few of the cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the website and will last for longer.

Cookies on our website are set by us (“first-party cookies”) and also by third-party tools and marketing providers we work with (“third-party cookies”). Most web browsers automatically accept first-party cookies and either block third-party cookies by default or make it straightforward to block these. You can control the setting of both first-party and third-party cookies by adjusting the settings on your browser. Please note however, that by blocking or deleting cookies you may not be able to take full advantage of the website or view your account.

Where we maintain a presence on a third-party social media platform, these platforms will also set cookies on your devices. Please refer to the privacy and cookie policies of any such service for guidance on their use of cookies and how to control the setting of these. When using our mobile app, the terms governing the storage of information on your mobile device to achieve similar goals as cookies will be governing by the terms set out on the relevant app store at the time of downloading our mobile app.

Our cookies will be used for:

Essential session management

• Creating a specific login session for a user of the services, in order that the user remains logged in and that the resource requests made by their device are delivered in an effective, secure and consistent manner;
• Recognising when a user of the services has visited before allowing us to identify the number of unique users we receive and make sure we have enough capacity for the number of users that we get.

Performance and measurement

• Recognising if a visitor to the website is registered with us in any way;
• We may also log information from your device including the existence of cookies, your IP address and information about your web browser in order to allow us to diagnose problems, administer and track your usage of our services;
• Collecting statistical information about how our users use our services so that we can improve the services and learn which parts are most popular to users.

Monitoring advertising performance

• Customising elements of the promotional layout and/or content of the pages of the services;
• Tracking the effectiveness of advertising campaigns and identifying characteristics of visitors so we can tailor our advertising to reach audiences most interested in it.

We will seek your consent for non-essential cookies on our website.

4.1 Website cookies

We review the cookies in use twice a year

If you decide you no longer consent to how we use cookies on this website, you can change your preferences for non-essential cookies through our cookie policy settings at any time.

4.2 Mobile App

Our mobile app uses similar technologies as cookies to store information on your device to achieve similar goals as cookies on our website.

5. How we use what we collect

We use information about you to:

• provide, monitor, administer, maintain, develop, expand and improve our services, including, for example, enhancing our customer service and administering your account;
• perform internal operations, including, for example, to prevent fraud and abuse of our services;
• confirm your identity by using third-party databases (e.g. the Electoral Roll and utility provider databases), although we will never perform a credit check on you without your explicit permission;
• locate the existing pensions you request us to find, by liaising, amongst others, with your past and current employers, your financial adviser, relevant government agencies and your current and past pension providers;
• undertake all activities and communications necessary, in such manner and with such third parties as we determine to be appropriate, for the purposes of achieving the consolidation of your existing pensions into your chosen pension (when you proceed to use our consolidation services);
• send you communications we think will be of interest to you in relation to similar products and services you procure from us;
• send you newsletters;
• send push notifications to your mobile device(s);
• respond to regulatory, government or legal requests that are either legally binding upon us or which we consider legitimate.

You are able to recommend PensionBee to a friend by sharing your unique link with that friend. If you have been referred to PensionBee by a friend and are signing up or have signed up to our service using that friend’s referral link, we will share your name and information regarding your pension transfer for the purposes of you and/or your friend claiming the relevant reward(s).

Please ensure when sharing information about PensionBee, including recommendations, in public (for example, on social networks or other forums), you do not submit any personal data that you do not want to be seen, collected or used by others. We may use public recommendations you make about us on one public forum in other public forums.

We identify customers to our advertisers, including Facebook, Google and Microsoft. We share personal data including names, emails and addresses in order to tailor our advertising to reach the most relevant audience. Your data will not be used by these advertisers in other ways. We rely on the basis of our “legitimate interest” to do this. If you wish to object to our using your data in this way, you should let us know via contact@pensionbee.com and we will not use your data as part of our targeting activities. We will not sell your personal information to third parties without your explicit consent.

In most cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the services we can provide you if you don’t provide your personal data in these cases.

6. Where we store your data and how long we keep it for

We may transfer your collected data to storage outside the UK. It may be processed outside the UK to provide our services to you. Where we transfer your data outside the UK we have appropriate protections with our suppliers in place.

By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.

All information, including payment information and passwords, transmitted between your device and our servers is encrypted during transit. If we give you a password, you must keep it confidential. Please don’t share it. Although we try to provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our efforts.

We only keep your personal data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it. We will conduct an annual review to ascertain whether we need to keep your personal data.

Please be aware that our primary regulator, the Financial Conduct Authority, requires us to keep data related to safeguarded benefits pension transfers indefinitely and we may need to keep some of your personal data indefinitely in order to meet our regulatory obligations. Your personal data will be deleted if we no longer need it. If you have not yet requested a pension transfer but have provided some personal information to us we will delete your personal information on your request.

Please note that after any termination of your PensionBee account (whether by you or us) we may retain information about you as required by law and our regulators, or for legitimate business purposes to the extent permitted by law. For instance, if we believe you have committed fraud or violated our Terms, we may seek to resolve the issue before deleting your information.

7. Disclosing your information

We are allowed to disclose your information in the following cases:

• if we want to sell our business, or our company, we can disclose it to the potential buyer;
• we can disclose it to other businesses in our group;
• we can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights;
• we can exchange information with others to protect against fraud or credit risks.

We may contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data.

Our main suppliers who we may share your data with include Facebook, Google, Microsoft, Origo Services, Plaid, Salesforce and Trustpilot. Please contact us if you have further questions regarding our suppliers and data sharing arrangements.

Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under UK GDPR and the law.

8. Your rights

You can ask us not to use your data for marketing. You can do this by ticking the relevant boxes in the email preference centre, or by contacting us at any time at contact@pensionbee.com. You may also opt out of receiving promotional messages from us by following the instructions in those messages. If you opt out, we may still send you non-promotional communications, such as those about your PensionBee account, your statements, the PensionBee services you have requested, or our ongoing business relations. Please note that where you opt out from communications sent directly from the systems of one of our suppliers, you are not necessarily unsubscribing from our communications.

In addition, under the UK GDPR, you have the right to:

• request access to, deletion of or correction to, your personal data held by us at no cost to you;
• request that your personal data be transferred to another person (data portability) although we are only required to transfer personal data you have provided to us as opposed to all data we hold on you;
• be informed of what data processing is taking place;
• restrict processing;
• object to processing of your personal data; and
• complain to a supervisory authority.

PensionBee will comply with your requests regarding access, correction, and/or deletion of the personal data we store, in each case to the extent permitted by and always in compliance with applicable law. You may also correct your PensionBee account information (including any of your Personal Data held by us) at any time by logging into www.pensionbee.com.

To enforce any of the foregoing rights or if you have any other questions about our website, mobile app or this privacy policy, please contact us at contact@pensionbee.com. If you remain dissatisfied, you can make a complaint about the way we process your personal information to the Information Commissioner’s Office (the ICO) as the UK supervisory authority - please follow this link: https://ico.org.uk/make-a-complaint/.

9. Waitlists

Where we are collecting your information to assess demand for a specific new feature, via a waitlist, we will use the data you provide only for analysis of demand, to update you about the specific feature’s development, and market it to you. We may store and process your data on the third parties listed in section 7, Disclosing your information. We will not share details gathered on waitlists with any third parties for any marketing purposes. We will erase or anonymise data gathered through waitlists once we have completed our assessment of demand and marketing of new features. We expect to store this data for no longer than 12 months. Should you wish to take your name off the waitlist, please email us at contact@pensionbee.com. Your full UK GDPR rights (outlined in section 8, Your rights) still apply. For data gathered from waitlists, where any other section of this privacy policy is in conflict with this section, this section shall take precedence.

10. Links to other websites

Please note that our Terms and our policies will not apply to other websites that you get to via a link from our website. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

11. Changes

If we change our privacy policy, we will post the changes on this page. If we decide to, we may also email you.

Last edited: 04-10-2023