Talia Privacy Policy

Last updated 18 May March 2022 

1. Introduction

This Privacy Policy (“Policy”) describes how Hera Money Ltd (trading as Talia) (‘Talia’’, ‘we’, ‘us’ or ‘our’) of Second Floor, 3 Liverpool Gardens, Worthing, West Sussex, England, BN11 1TF use any personal data and special category data related to our Website and Service. 

Talia also operates an Application which gives you the tools and information to build your pension goals and the context to know what parts apply to your life. 

This Policy should be read in conjunction with our Terms and Conditions.

This Policy applies to all users of our Application and visitors to our Website, including any other individuals who are in contact or interact with us.

2. Purpose

This Policy aims to give you information on how we collect and process your personal data through your use of this Website or our Application, including any data you may provide through this Website or Application when you sign up to our newsletter or enquire about our services.

This Website is not intended for children and we do not knowingly collect data relating to children.

You must read this Policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy shall supplement the other notices and is not intended to override them.

3. Changes to this Policy

This Policy is updated regularly, historic versions can be obtained by contacting us using the contact details below. 

Please keep us informed if your personal data changes during your relationship with us as it is important that the personal data we hold about you is accurate and current.

4. Controller

We determine the purposes and means of the processing of personal data, including the security measures concerning the operation and use of the Application and Website and are therefore a data controller. 

5. Third party data processors

A processor means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of a data controller.

There are a number of third party organisations that we have integrated into our Application who act as processors on behalf of Talia:

Heap Analytics Data analytics on usage data

Privacy Policy
Smartlook Data analytics on usage data

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Amazon Web Services (AWS) Web hosting and back end infrastructure

Privacy Policy
OneSignal Management of in-app messages and notifications

Privacy Policy
Postmark Transactional email delivery

Privacy Policy
GrowSurf Referral campaigns and offers

Privacy Policy
Intercom Customer Support

Privacy Policy

Our Website or Application may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

6. Security

We will use strict procedures and security features to safeguard against the risks that are presented by personal data processing, such as accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

All our employees and any third parties we engage to process data are obliged to respect the confidentiality and security of such data and as required under applicable data protection or other legislation.

7. Your rights in relation to your personal information

The following section explains your rights.

The various rights are not absolute, and each is subject to certain exceptions or qualifications.

Please note that we may be unable to delete or remove your data for compliance or regulatory reasons, we will let you know if this applies to your data.

1. Right to be informed

You have the right to be provided with clear, transparent, and easily understandable information about how we use your information and your rights. Therefore, we are providing you with the information in this Policy.

2. Right of access

You have the right to obtain a copy of your information (if we’re processing it), and certain other information (similar to that provided in this Policy) about how it is used. This is so you’re aware and can check that we are using your information in accordance with data protection law. We can refuse to provide information where doing so may reveal personal data about another person or would otherwise negatively impact another person’s rights.

3. Right to rectification

You can ask us to take reasonable measures to correct your information if it’s inaccurate or incomplete. E.g., if we have the wrong date of birth for you.

4. Right to erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it or its use is unlawful. This is not a general right to erasure; there are exceptions, e.g., where we need to use the information, in defence of a legal claim.

5. Right to restrict processing

You have rights to ‘block’ or suppress further use of your information when we are assessing a request for rectification or as an alternative to erasure. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

6. Right to data portability

You have rights to obtain and reuse certain personal data for your own purposes across different organisations. E.g., if you decide to move services, this enables you to move, copy or transfer your information easily between different service providers (or directly to yourself) safely and securely, without affecting its usability. This only applies to your information that you have provided that is being processed with your consent (if relevant) or to perform a contract that you are a party to, which is being processed by automated means. We do not expect this right to be relevant in the context of the services that we provide.

7. Right to withdraw consent or object

You have the right to withdraw consent or object to certain types of processing, on grounds relating to your situation, at any time insofar as that processing takes place for the purposes of legitimate interests pursued by us or by a third party. We will be allowed to continue to process the information if we can demonstrate “compelling legitimate grounds for the processing which override your interests, rights and freedoms” or we need this for the establishment, exercise, or defence of legal claims.If you wish to exercise any of the rights set out above please contact us. 

No fee required – with some exceptions

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

8. Who do we share the information with?

Where appropriate for the purposes of providing the Services and providing other products and services on the Application we may share your information with:

- Any other person who is authorised to act on your behalf.
- Our professional advisers including lawyers, bankers, auditors and insurers based in the European Economic Area (EEA) who provide consultancy, banking, legal, insurance and accounting services.
- The entities identified as processors under the section on processors above.
Regulators, government departments, law enforcement authorities, tax authorities and insurance companies.
- Any relevant ombudsman, dispute resolution body or the courts.
- Persons in connection with any fundraising, sale, merger, acquisition, disposal, reorganisation, or similar change in the Talia business.
- Third parties who provide products and services available through the Application.
- Pension industry bodies, to enable research-related initiatives to provide pension data analysis, including developing better evidence of people’s savings habits.

The entities listed above may also share personal data with their own business suppliers, for example in relation to the operation of IT systems or where they outsource part of their services. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

9. How your personal data is collected?

We collect and process the information about you directly that you provide by filling in forms on our Website when you register with us or request information, report problems or require additional services. Alternatively, through correspondence with us and our service providers (including within your account area, email, letter, text, phone or otherwise) or taking part in user experience and market research surveys and questionnaires. This includes personal data you provide when you apply for our Services, create an account with us, subscribe to our Services or publications, request marketing materials, enter a competition, promotion or survey, or, give us any feedback or contact us. 

As you interact with our Website and Application, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

10. The data we collect about you 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

We may collect, use, store and transfer different kinds of data which we have grouped together as follows:  

- Identity Data
includes first name, maiden name, last name, username or similar identifier, marital status, title, date or birth and gender; 
- Contact Data includes email addresses, residential or delivery address, telephone numbers; 
- Technical Data includes internet protocol (IP) address, your login data and browser type
- Profile Data
includes your username and password, your interests, preferences, feedback and survey responses; 
- Usage Data includes information about how you use our Website, Application and Services; 
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences; 

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. 

For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy. 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

11. If you fail to provide personal data

Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

12. How we use your personal data

We will only use your personal data when the law allows us to. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. Most commonly, we will use your personal data in the following circumstances:

Performance of Contract: this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Legitimate Interest: this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. 

We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. 

We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Compliance with a legal or regulatory obligation: this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. 

You have the right to withdraw consent to marketing at any time by contacting us.

13. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so. 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need further information. 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new user (a) Identity
(b) Contact
Performance of a contract with you
To manage our relationship with you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests
To administer and protect our business and the Website and/or Application (a) Identity
(b) Contact
(c) Technical
(d) Usage
(a) Necessary for legitimate interests
(b) Necessary to comply with a legal obligation
To deliver relevant website and application content and communications to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests
To use data analytics to improve our Website and Application (a) Technical
(b) Usage
Necessary for our legitimate interests
To make suggestions and recommendations of alternative services (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests

Talia uses a number of services to improve the quality of service provided to you. All of these services use anonymised information (as we always seek to put your privacy and information security concerns above data analysis).

14. Where we store your personal data/international transfers

The data that we collect from you may be transferred outside the UK or the EEA where our service providers host data outside the UK or the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by using established industry leaders. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

15. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party (which has not been expressly identified in this Policy) for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at legal@jointalia.com  at any time.Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or other transactions. 

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy. 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 

If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

16. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including of the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. In some circumstances you can ask us to delete your data, please refer to the “Your Rights” section above for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

17. Contact details

If you have any questions about this Policy or our privacy practices, please contact our data privacy manager in the following ways: 

Our contact details

Hera Money Ltd (trading as Talia) 

Post: Second Floor, 3 Liverpool Gardens, Worthing, West Sussex, England, BN11 1TF
Email via: legal@jointalia.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk).

We would, however, appreciate the chance to resolve your concerns before you approach the ICO so please contact us in the first instance. 

ICO contact details Post: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK
Phone: 0303 123 1113
Email via: https://ico.org.uk/global/contact-us/email/