Privacy Policy

By installing and using the SSV SmartAccount App, you acknowledge that we process your personal data as described in this Privacy Policy. Where required by applicable law, we will request your consent before processing specific categories of personal data, such as marketing communications. You may withdraw your consent at any time where applicable.

Identity Data - first name, last name, username, date of birth, gender, title
Contact Data - email address and telephone numbers
Financial Data - bank account name, number, and payment information
Transaction Data - details about payments to and from you and services you use
Technical Data - IP address, login data, browser type and version, time zone, plug-ins, operating system, platform, Device ID
Profile Data - username, password, purchases, interests, preferences, feedback
Usage Data - information about how you interact with our products and services
Device Data - device type, unique device identifier (e.g. IMEI), mobile network, operating system, browser type, time zone
Marketing and Communications Data - your preferences for receiving marketing and communication preferences
Content Data - information stored on your device
Biometric Data - facial images, liveness checks, or facial image comparison data used for identity verification and authentication. Identity verification may be processed by providers such as Veriff. Fraud and transaction screening may involve providers such as Sumsub, where required for KYC/KYT, fraud prevention, regulatory compliance, or legal obligations.

Each time you use the App we automatically collect Device, Content, Usage, and Technical Data using software development kits (SDKs), analytics tools, and similar technologies. For information about cookies used on our website, please refer to our Cookie Policy available at Cookie Policy - SSV SmartAccount.

Griffin Bank - our embedded banking infrastructure provider
Service providers such as Google Firebase (for push notifications and crash reporting)
Credit reference agencies (TransUnion, Equifax, Experian)
Identity verification and fraud prevention providers (including Veriff and Sumsub, and other agencies such as CIFAS, Synectics, and Napier where applicable)
Other lenders you use that we are connected with, such as peer-to-peer platforms or mortgage providers

To install the App and register you as a new user - Data: Identity, Contact, Financial, Device. Lawful basis: Your consent.
To deliver banking services and process payments - Data: Identity, Contact, Financial, Transaction, Device. Lawful basis: Your consent; performance of contract; legitimate interests.
To manage your account and notify you of changes - Data: Identity, Contact, Financial, Profile, Marketing & Communications. Lawful basis: Your consent; performance of contract; legitimate interests; legal obligation.
To enable you to complete surveys - Data: Identity, Contact, Device, Profile, Usage, Marketing & Communications. Lawful basis: Your consent; performance of contract; legitimate interests.
To administer and protect our business and the App - Data: Identity, Contact, Device. Lawful basis: Legitimate interests; legal obligation.
To prevent fraud and money laundering - Data: Identity, Contact, Financial, Transaction, Device. Lawful basis: Legitimate interests; legal obligation.
To verify your identity and complete KYC checks for account verification, fraud prevention, anti-money laundering checks, and compliance with legal and regulatory obligations - Data: Identity, Contact, Device, Camera and Photo, Microphone, Biometric. Lawful basis: Legal obligation; legitimate interests.
To carry out automated decision-making on transactions - Data: Identity, Financial, Transaction, Device. Lawful basis: Your consent; performance of contract; legal obligation.
To deliver marketing communications (where consented) - Data: Identity, Contact, Device, Profile, Usage, Marketing & Communications. Lawful basis: Your consent; legitimate interests.
To send push notifications and support App stability (Firebase) - Data: Device, Usage, Technical. Lawful basis: Legitimate interests.

Griffin Bank - our embedded banking infrastructure partner
Affiliated companies and group entities
Partners, suppliers, and sub-contractors
Credit reference agencies: TransUnion, Equifax, Experian
Identity verification and fraud prevention providers: Veriff, Sumsub, CIFAS, Synectics, Napier
The Financial Services Compensation Scheme (FSCS)
Tax authorities, police, and other law enforcement agencies
Regulators - where we are under a duty to disclose to comply with a legal obligation, prevent fraud, or protect rights, property, or safety
Third parties in the event of a sale, merger, or acquisition of part or all of our business
Open Banking providers, Marketplace partners, and organisations integrated via our API - only where you have given permission.

We use automated systems to help make decisions about whether to offer you an account or product, and to detect and prevent fraud or money laundering. These systems draw on data from credit reference agencies, fraud prevention agencies, and biometric tools, and are regularly reviewed for fairness and accuracy.

We may use artificial intelligence (AI) and machine learning to assist with information extraction, identity verification, fraud detection, compliance checks, and operational efficiency. AI is not used as the sole basis for decisions that produce legal or similarly significant effects on individuals.

Where we can, we store and process your data on secure servers in the UK and European Economic Area (EEA). Your data may be processed outside the UK/EEA only if a supplier requires it, or if you make or receive international payments. In all such cases we apply appropriate safeguards, including the International Data Transfer Addendum to the European Commission's standard contractual clauses. To obtain a copy of these safeguards, contact us at info@ssvsmartaccount.co.

All information you provide is stored on secure, encrypted servers. We have put in place appropriate technical and organisational measures to prevent your personal data from being accidentally lost, used, accessed, altered, or disclosed without authorisation. Access to your personal data is limited to those who have a business need to know.

We retain your personal data for a minimum of six years from the date you stop using SSV SmartAccount products or services, as required by law. We may retain it for longer where required to satisfy legal, regulatory, tax, accounting, or reporting obligations, or where there is a complaint or prospect of litigation.

In the App: Profile -> Login & Security -> Close Account -> confirm.
On the web (without the App): Visit https://app.ssvsmartaccount.co/account/delete. Or email info@ssvsmartaccount.co with the subject "Account deletion request" and include your full name, registered email or phone number, and User ID (if known).

You have the following rights under UK data protection law. To exercise any of them, send a message in the App or email info@ssvsmartaccount.co. We will usually respond within one calendar month (up to three months for complex requests). No fee is charged unless your request is clearly unfounded, repetitive, or excessive.

Right to access - receive a copy of the personal data we hold about you
Right to rectification - have inaccurate or incomplete data corrected
Right to erasure - ask us to delete your data (subject to legal obligations). You can do this in the App, via https://app.ssvsmartaccount.co/account/delete, or by emailing info@ssvsmartaccount.co. See Account and data deletion.
Right to restrict processing - ask us to suspend processing in certain circumstances
Right to object - object to processing based on legitimate interests, including direct marketing
Right to data portability - receive your data in a structured, machine-readable format
Right to withdraw consent - at any time, without affecting the lawfulness of prior processing
Right to human review - where automated decision-making has been applied

Email: info@ssvsmartaccount.co
Account / data deletion requests: info@ssvsmartaccount.co or https://app.ssvsmartaccount.co/account/delete
Data Protection Officer: compliance@ssvsmartaccount.co
Telephone: 02036330808
Post: SSV SmartAccount Limited, Level 18, 40 Bank Street, Canary Wharf, London, E14 5NR

We may update this Privacy Policy from time to time. The latest version will always be available within the App and on our website. Any changes will become effective as soon as we post the updated version on our website and App. If we make a significant change, we will notify you by email or in-app message.

SSV SmartAccount App Privacy Policy

Consent to installation of the App

Introduction

Important information about SSV SmartAccount

The personal data we collect

Camera and Photo Access

Microphone Access

Device biometric authentication

How is your personal data collected?

Information you give us

Information we collect automatically

Information from third parties

OTP Autofill

How we use your personal data

Purposes for which we use your personal data

Direct marketing

Opting out

Disclosures of your personal data

Automated decision-making

Artificial intelligence and machine learning

International transfers

Data security

Data retention

Account and data deletion

How to request deletion

What we delete

What we may retain

Your legal rights

Contact details

Complaints

Changes to this privacy policy