Privacy Policy
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
Contents
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- GLOSSARY
IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how Work Wallet Limited collects and processes your personal data through your use of our website and application, including any data you submit when you sign up as a user of our application.
Our website and application are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing 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 privacy notice supplements the other notices and is not intended to override them.
In this privacy notice references to Work Wallet, we, us or our are to Work Wallet Limited.
Controller and Processor Contexts
In certain circumstances, we will be a “controller” of personal data (for example, during all pre-contractual or non-contractual commercial discussions or when dealing with our own employees’ personal data)
In certain circumstances, we will be a “processor” of personal data (for example, when we are providing our services to customers/clients and are processing personal data for our customers/clients). We will be a processor of personal data when providing services to customers under our licensing agreement.
If you wish to find out who the controller is for your personal data, please contact our Data Protection Officer using the contact details mentioned below.
Further details on controllers and processors can be found on the website of the Information Commissioner’s Office (ICO).
You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance where we are acting as the controller. Where we are acting only as the possessor then you will need to contact the controller.
Contact details
Our full details are:
Full name of legal entity: Work Wallet Limited. We are registered in England and Wales under number 10315489 and we have our registered office at Friar Gate Studios, Ford Street, Derby, England, DE1 1EE. Our VAT number is GB 248590867.
We have appointed a Data Protection Officer (DPO) as the person who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
- Email address: [email protected]
- Postal address: Friar Gate Studios, Ford Street, Derby, England, DE1 1EE
- Telephone number: 01332 505252
Changes to the privacy notice and your duty to inform us of changes
This version was last updated in January 2024 and historic versions can be obtained from our website or by contacting us.
It is important that the personal data we hold about you is accurate and current. We may ask you to confirm updates to your personal data from time to time but please keep us informed if your personal data changes during your relationship with us in the meantime. Please inform the DPO of any changes in your data at the following email address: [email protected]
Third-party links
Our website 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 and organisations connected with us have a social media presence for the purpose of engaging with you.
If you enable such connections or choose to communicate your personal data to us via third-party websites or social media, please remember that we do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or interact with us on social media, we encourage you to read the privacy notice of every website or forum that you visit or use.
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 personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, username or similar identifier, date of birth and photo identification.
- Contact Data includes email address, postal address and telephone numbers (including emergency contact numbers and next of kin information).
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments from you and other details of services you have purchased from us, including which tier of our mobile application you are subscribed to.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website and our mobile application.
- Profile Data includes your username and password, your preferences and feedback.
- Professional Data includes data relating to your qualifications, training and completion of any site inductions, results of any tests you have taken on our mobile application, details of your location (if you enable this function within the mobile application), details of times at which you have clocked in/out of a job, and any other similar personal data you may submit via our mobile application.
- Health Data includes details of any injuries, health conditions and requirements or other similar information which you may submit via our mobile application.
- Usage Data includes information about how you use our website and mobile application.
- Communications Data includes your communication preferences.
We refer to the above categories of data in the data subject category tables.
We may from time to time collect Special Categories of Personal Data about you (this may include 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). Much of this information is provided by way of Health Data and identified as such in our information tables. All such information is collected in accordance with this privacy notice. We have in place appropriate policy documents and/or other safeguards which we are required by law to maintain when processing such data.
If you fail to provide personal data
Where we need to collect 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 services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Professional, Health and Financial Data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
- contact us via a form or live chat on our website;
- register as a user of our mobile application and web platform;
- upload information to our mobile application and web platform;
- give us some feedback.
- Automated technologies or interactions. As you interact with our website, we or our third party processors may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from analytics providers such as Google based outside the EU;
- Contact, Financial and Transaction Data from providers of technical and payment services such as Go Cardless based inside the EU.
HOW WE USE YOUR DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data.
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, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. The table is split into three different sections for each category of data subject: individual users, business users and members of the public. You should consult the relevant section of the table to determine how we process your personal data. Note that you may fall into more than one category (for example, you may be an individual user of our mobile application but may also view our website as a member of the public).
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 details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing under UK GDPR, with all references to articles being to the UK GDPR. | Third-party processing and international transfer information |
| INDIVIDUAL USERS – this section of the privacy policy applies to users of our application. Our application is both our web portal and mobile app. | |||
| To register you as a new user of the application | 1. Identity
2. Contact 3. Profile |
Performance of a contract with you – Art. 6(1)(b). | Microsoft Azure Cloud Services are engaged as a third party to store data and host our application |
| To enable you to use the functions of our application including:
1. Uploading and storing your information on our application for businesses (with whom you are engaged to provide services to) to access; 2. Taking tests or quizzes; 3. Enabling you to clock in/out of a job you are engaged to undertake. |
1. Identity
2. Contact 3. Profile 4. Professional 5. Health 6. Technical |
Performance of a contract with you – Art. 6(1)(b). | Microsoft Azure Cloud Services are engaged as a third party to store data and host our application |
| To enable businesses (with whom you are engaged to provide services to) to use our application including:
1. To access the information you have uploaded to our mobile application; 2. To monitor your location for the purposes of clocking you in/out or lone worker safety; 3. To share your personal information with other businesses (such as sub or primary contractors) who are also registered with our application and who may require your personal information; 4. To contact your emergency contact in the case of an emergency |
1. Identity
2. Contact 3. Profile 4. Professional 5. Health 6. Technical |
Performance of a contract with you – Art. 6(1)(b). | Microsoft Azure Cloud Services are engaged as a third party to store data and host our application
Businesses (with whom you are engaged to provide services to or may in the future be engaged to) provide services to may share their access to your personal information between themselves as they deem appropriate and you should check their privacy policy for further information as to the terms of their data processing practices. |
| To manage our relationship with you which will include notifying you about changes to our terms or privacy policy | 1. Identity
2. Contact 3. Profile 4. Communications |
1. Performance of a contract with you – Art. 6(1)(b).
2. Necessary to comply with a legal obligation – Art.6(1)(c). 3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) – Art.6(1)(f). |
Microsoft Azure Cloud Services are engaged as a third party to store data and host our application |
| To administer and protect our business and our application(including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | 1. Identity
2. Contact 3. Technical |
1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) – Art.6(1)(f).
2. Necessary to comply with a legal obligation – Art.6(1)(c). |
Microsoft Azure Cloud Services are engaged as a third party to store data and host our application |
| To measure or understand how you use our application, including the use of data analytics | 1. Identity
2. Contact 3. Profile 4. Usage 5. Technical |
Necessary for our legitimate interests (to study how users use our website and mobile application, to develop them, to grow our business, and to inform our marketing strategy) – Art.6(1)(f). | Microsoft Azure Cloud Services are engaged as a third party to store data and host our application and website.
We use Google Analytics and other similar analytics services (who may be based inside or outside the EU) within our website and mobile application to track page views, source information, generic session information and error logs |
| BUSINESS USERS – this section of the privacy policy applies to our business customers and partners (who may be companies, individuals, sole traders and small partnerships) or their representatives who use our application pursuant to a licence agreement. | |||
| To process and deliver your request to engage our application services including:1. Manage payments, fees and charges
2. Collect and recover money owed to us |
1. Identity
2. Contact 3. Financial 4. Transaction 5. Communications |
1. Performance of a contract with you – Art. 6(1)(b).
2. Necessary for our legitimate interests (to recover debts due to us) – Art.6(1)(f). |
Microsoft Azure Cloud Services are engaged as a third party to store data and host our application
We may use a third-party direct debit payment provider called GoCardless for the purposes of processing your direct debit payments or a third party card payment provided called Stripe for the purposes of processing card payments |
| To enable you to use the functions of our application including accessing and sharing end user information | 1. Identity
2. Contact 3. Profile 4. Professional 5. Technical |
Performance of a contract with you – Art. 6(1)(b). | Microsoft Azure Cloud Services are engaged as a third party to store data and host our application |
| To manage our relationship with you which will include notifying you about changes to our terms or privacy policy | 1. Identity
2. Contact 3. Profile 4. Communications |
1. Performance of a contract with you – Art. 6(1)(b).
2. Necessary to comply with a legal obligation – Art.6(1)(c). 3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) – Art.6(1)(f). |
Microsoft Azure Cloud Services are engaged as a third party to store data and host our application |
| To administer and protect our business and our application(including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | 1. Identity
2. Contact 3. Technical |
1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) ).– Art.6(1)(f).
2. Necessary to comply with a legal obligation – Art.6(1)(c |
Microsoft Azure Cloud Services are engaged as a third party to store data and host our application |
| To deliver relevant content to you and measure or understand how you use our application, including the use of data analytics | 1. Identity
2. Contact 3. Profile 4. Usage 5. Communications 6. Technical |
Necessary for our legitimate interests (to study how users use our mobile application, to develop them, to grow our business, and to inform our marketing strategy) – Art.6(1)(f). | Microsoft Azure Cloud Services are engaged as a third party to store data and host our application.
We use Google Analytics and other similar analytics services (who may be based inside or outside the EU) within our application to track page views, source information, generic session information and error logs. |
| PUBLIC – this section of the privacy policy applies to members of the public. | |||
| To enable us to respond to your query submitted through our website contact form | 1. Identity
2. Contact |
Necessary for our legitimate interests (to respond to your query and deal with it appropriately) – Art.6(1)(f). | WPEngine (based within the EU) is engaged as a third party to store data and host our website.
Hubspot (based within the EU) is engaged as a third party to store prospective and current customer data. |
| To store your details where you have been involved in an accident involving a company using our application | 1. Identity
2. Contact 3. Health |
Necessary for our legitimate interests (to enable us to store data uploaded by users of our mobile application (a service which our users pay us for), where such users are required to retain such data by law) – Art.6(1)(f). | Microsoft Azure Cloud Services are engaged as a third party to store data and host our application |
| To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | 1. Identity
2. Contact 3. Technical |
1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) – Art.6(1)(f).
2. Necessary to comply with a legal obligation – Art.6(1)(c). |
WPEngine (based within the EU) are engaged as a third party to store data and host our website. |
| To deliver relevant content to youand measure or understand howyou use our website, including the use of data analytics | 1. Identity
2. Contact 3. Profile 4. Usage 5. Communications 6. Technical |
Necessary for our legitimate interests (to study how users use our website, to develop them, to grow our business and to inform our marketing strategy) – Art.6(1)(f). | WPEngine (based within the EU)are engaged as a third party tostore data and host our website.
We use Google Analytics and other similar analytics services (who may be based inside or outside the EU) within our website and application to track page views, source information, generic session information and error logs |
Marketing
We have various sections on our website which enables you to request details of our services. Where you do so, we will respond with marketing information as appropriate in the context of your enquiry. We will not send you any unsolicited marketing communications.
Cookies
We use cookies (small text files placed on your electronic device) to monitor user activity. Our cookies are used for a number of reasons, including ensuring the website works effectively and to monitor user behavior. 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 our cookies, some parts of our website may become inaccessible or not function properly. Please see view our Cookie Settings for further information about the cookies we use.
Please visit the ICO website for more information on cookies generally.
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.
DISCLOSURES OF YOUR PERSONAL DATA
Our business users (with whom you are engaged to provide services to) may share your personal data with other business users (who you may not necessarily have a direct relationship with) via our application as they deem appropriate. If you do not want your personal data to be shared in this way, please do not input it into the application. You should check the privacy policy of any businesses with whom you engage with for further information as to the terms of their data processing practices.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Specific third parties listed in the table above.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available on request by contacting us.
By law, we have to keep basic information about our business users (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
We will retain information about our individual users as directed by our business users. Our business users may need to retain Health Data in relation to individual users for a certain time period in order to comply with their legal obligations. They may retain such data using our mobile application or they may export it from our mobile application and store it elsewhere. We recommend that our individual users check the privacy policy of any business users with whom they engage for further information in relation to retention periods.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may 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.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Request access to your personal data.
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. - Request correction of your personal data.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. - Request erasure of your personal data.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. - Object to processing of your personal data.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. - Request restriction of processing your personal data
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. - Request transfer of your personal data.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. - Right to withdraw consent
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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 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 will respond to all legitimate requests within one month. It will take us longer than a month if your request is particularly complex or you have made a number of requests or it takes time for you to confirm your identity where identity should be confirmed. In this case, we will notify you and keep you updated.
INTERNATIONAL TRANSFERS
International Transfers within Work Wallet
To facilitate our global operations, we may transfer information internationally where we have operations for the purposes described in this policy. For customers within the UK/EU, all data is held within this geographic region. For customers outside the UK/EU, data may be transferred to our support teams from the main territory where your data resides. We have taken appropriate safeguards to require that your Personal Data will remain protected wherever it is transferred. This Privacy Policy will apply even if we transfer Personal Data to other countries.
We currently support 3 main data zones (UK/EU, USA, Australia) for our customers where customer data resides when we are acting as a data processor. These are chosen by our customers on their account setup, in line with their requirements as the data controller.
GLOSSARY
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and 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.
Performance of Contract 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.
