Privacy Policy

1 December 2021 to 26 July 2022

We created Snoop so everyone could have the chance to harness the data held by their Bank and use it for their own advantage. We knew it could help so many people in the UK and eventually, the world.

But we know this means we have a big responsibility to do the right thing with the data we hold ourselves.

That’s why we never sell any of your personal information. And that’s why our number one focus is always how we store, analyse and protect your personal data.

So how do we actually use your data? Well, we use the data you share with us to spot super-smart suggestions we believe will help you spend, save and live smarter.

Sometimes when you move to a new provider off the back of one of Snoop’s suggestions, they may pay us for the introduction. We always make sure you know when this happens. Crucially, this never influences Snoop’s view of what’s right for you – and has zero impact on the kinds of things Snoop suggests to you. Snoops algorithms on what to suggest aren’t programmed to take account of any payments we might receive.

We also pool data from all the different sources we have - after making it totally anonymous - and use it to identify big trends in areas like consumer spending. We then use this to help other businesses make better decisions. None of your personally identifiable information is ever used for this. In fact, your personal data is never used in a way that means you, any other individual or their data can be identified.

We believe our approach to privacy is nice and straightforward. We’ll always be 100% clear with you on how we use your data to help you save time and money - and we’ll always be completely upfront with you about how we make money as a business ourselves.

If that all sounds fair enough to you, let’s get Snooping together.  And if you’d like more info, our detailed Privacy Policy is below.

Best wishes, Team Snoop.

Who we are 

We are Usnoop Limited (company number 11797870) ("Snoop", "we", "us" or "our"), and Snoop is a robot friend for your money that will do four key things for you:  

1. Snoop organises your finances so you can see all your different online accounts, for example bank accounts, savings accounts and credit cards in our Apps, meaning you can see your money in one place. We do this by using regulated Open Banking technology to communicate with your third-party bank account providers in a secure way. 
   
2. Snoop allows you to see all your regular bills in one list and get reminders of promotions and offers at the right time so you can shop around for a new deal through the Apps. 
   
3. Snoop automatically checks how much you are being charged for things by the banks and big businesses you deal with. If Snoop thinks you're being taken advantage of, you're overpaying for something, or it thinks there's something you should know that will benefit you, Snoop will tell you by email, push notification or in the Snoop app.  
   
4. Snoop looks for smart ideas it thinks could save you money, or help you more generally. Snoop will create a personalised list of these ideas just for you and communicate it to you. If Snoop finds any ideas that it thinks are particularly important, Snoop will let you know. 

We are constantly developing and improving the Snoop Mobile App, Snoop Web App (together the ‘Apps’) and Snoop website, so we will also tell you about new features of Snoop we’ve launched that you might not be aware of, existing features of Snoop we can see you've not used and new or existing third-party services which can be accessed through the Apps or website. 

We may also develop the Mobile and Web Apps at different paces, so you may find some features are available in one but not the other. We will let you know which features are available in each channel. 

We recognise everyone will want something different from Snoop – so that’s why Snoop has been built to learn from each user, so we can provide you with a customised experience that will be the most help for you. 

How does Snoop do that? 

Through the secure processing of your personal data. Without access to your personal data, and the right to process it as required and set out in this Privacy Policy, Snoop cannot perform the main functions for you that it has been designed for. Your privacy and security are our number one priority, and your data is always protected by bank-level security. This Privacy Policy sets out how and on what basis we collect information about you, and the ways in which you and your data are protected when you use the Apps and our website.  

To find out exactly what that means, read on to learn about our data protection principles and how we use your data. Before we get to that, please understand that Snoop is a data controller of the personal data that you provide to us or that we collect. ‘Data controller’ refers to a company that collects or stores personal data and has the decision-making power to decide what to do with that personal data. Personal data under this privacy policy is any data relating to a person who is identified or who can be identified from the data itself (so it would include things like a name, an identification number, or an online identifier) – see section 2 for more information. 

Please read this Privacy Policy carefully to understand how we handle your personal data. By engaging with us in the ways set out in this Privacy Policy, you confirm that you have read and understood the whole of this Privacy Policy, as it applies to you.  

You have the right to object: You have various rights in respect of our use of your personal data as set out in the 'Your Key Rights' section below. The fundamental right to be aware of is that you may ask us to consider any valid objections which you have to our use of your personal data where we process your personal data on the basis of our, or a third party's, legitimate interest.   

You can exercise this right by emailing us at hello@snoop.app.

What this Privacy Policy contains 

1. A summary of our data protection principles
2. What personal data do we use and how do we use it?
3. Our legal basis for using your personal data
4. Your key rights
5. Where do we store your personal data?
6. Protecting your personal data 
7. Who we share your personal data with 
8. How long do we keep your data? 
9. Using computers to make decisions about you 
10. Communicating the benefits of Snoop 
11. Links to other websites 
12. Children 
13. Our contact details 
14. Complaints to the Information Commissioner's Office (ICO) 
15. Changes to our Privacy Policy 
16. Personalised Advertising and Cookies

1. A summary of our Data Protection principles:   

Privacy and security are at the very heart of Snoop:   

• We strongly protect and secure the personal data we hold about you.   
• We will only use your personal data to allow us to deliver you our services.   
• Where we track your use of our Apps and website, we do this to continuously improve and personalise your experience.   
• Where we reuse your personal data, we do so to avoid asking you for the same data twice, and do so for the same purpose, or a purpose that is compatible with the original purpose. For example, if you provide Snoop with your postcode, we may reuse this to enable you to get an energy quote more quickly and easily.  
• We may use suppliers to help us deliver our service, but we restrict their use of data to what you allow us to do and bind them to data protection laws and to strict confidentiality. For more information, see the 'Who we share your personal data with' section below.   

Where you choose to use services provided by our partners on Snoop (for example, if you want to switch a service like gas and electricity where we’ve identified you may be overpaying), they may receive relevant data about you, but this will only be done in accordance with our Terms and when it is clear to you what has been shared and for what purpose. When data is shared with a partner, they become the data controller for the data they receive and their usage of the data from that point is then governed under their applicable terms and privacy policy.  

You are always in control:   

• You decide whether to connect banks and account providers to our Apps or not. If you choose not to do that, there are other ways we can help you. 
• You can disconnect a bank or account provider at any time to stop data exchange with them, by contacting your bank or account provider directly. Or if you no longer want your personal account information to be displayed in the Apps, nor stored by Snoop, you may remove these accounts from within the Apps or by emailing us at hello@snoop.app.
• You have the right to be forgotten: You can close your Snoop account by emailing us at hello@snoop.app or through the Apps if that feature is available. We will then anonymise and archive all data we have about you 6 months later (we keep this data for 6 months to fulfil legal and regulatory requirements and make sure we can investigate customer service queries or complaints after closure), unless you ask us to delete it immediately following closure (and this doesn't conflict with our legal and regulatory requirements) which you can do by sending us an email at privacy@snoop.app.
• If any data has been provided by Snoop or you to a partner service which you have accessed through the Apps or website, that data may still be processed by that partner. You should request deletion of that data and your right to be forgotten directly with them if you want this to happen.   

With an understanding of these principles, it’s important that you recognise that the use of your personal data to personalise your app experience and to deliver you targeted insights that aim to help you is an integral part of the Snoop service that we offer to you as outlined in our Terms, and cannot be switched off. If you would prefer we did not use your personal data in this way then you should not use the Snoop service. 

2. What Personal Data do we use and how do we use it? 

What do we mean when we say ‘personal data’?   

Personal data is any data relating to a person who is identified or who can be identified from the data itself (so it would include things like a name, an identification number, or an online identifier).   

You may give us personal data by interacting with the Apps,  by visiting our website, or by corresponding with us.   

We (or third parties on our behalf) may collect and use any of the following categories of personal data about you:    

• Registration Information/Contact Details – mobile number, email, and legal first and last name.  
• Account Information – information about connected accounts (for example provider name, product type, account numbers, sort codes) as well as the account held with Snoop (for example, account status, security data, preferences).  
• Transactional Information* – information about transactions and balances from connected accounts as well as any manually entered by you.  
• Additional Personal Information – location, address, device details, interaction tracking data and data customised by you (e.g. tags, updated categories), supplementary information we may ask you from time to time (for example, whether you are a student) or that you choose to provide to us (for example, Your Bills notes). 
• Partner Services Information – information provided by a partner relating to a service or product you have applied for or purchased via the Apps or website, such as the date you submitted an application for a switch, the status of your application, your chosen provider and the amount you will pay. 
• Technical Information – your IP address and general processing or monitoring data for performance and technical purposes.  
• Support Information – messages or emails you send us as well as any comments you may choose to make in the SnoopSpace Forum.  
• Unique Customer Identifier – a reference number which relates to you as an individual.  
• Mandatory Information – data we’re obliged to keep for the purposes of Financial Conduct Authority (FCA) reporting or audit (e.g. complaints).  

*As part of your Transactional Information, when we process your banking transactions we may process 'special categories of personal data'. For example, if you have a payment for a membership to a particular political party, this could reveal your political beliefs. Other banking transactions you have made could contain data about your racial or ethnic origin, political opinions, philosophical beliefs or trade union membership, as well as health data or data concerning your sex life or sexual orientation. We will only hold this data where you have made such data available to us as part of our provision of services to you and will do so in strict accordance with the law and we will never use it for any other purpose (for example profiling or tailoring of our service).  

We use the above personal data for the purposes set out in the below table. You can read more about our lawful basis for processing your personal data in section 5. 

3. Our legal basis for using your personal data 

We consider the legal bases for using your personal data as set out in this Privacy Policy are as follows:   

(A) Contractual performance: If you download our Apps and want us to deliver you our services as outlined in our Terms, we can only perform these services if we can process your personal data for this purpose. Therefore, most of our processing of your personal data is necessary to perform the contract we have in place with you, as outlined in the 'What personal data do we use and how do we use it?' section above. 

Please be aware that if you do not want us to process your personal data for most of the purposes set out above, then we cannot deliver our services to you through the Snoop app. Without the use of your data there is no benefit to the Snoop app and so if you don’t wish your personal data to be processed in this way, then you shouldn’t use the Snoop app.  

(B) Legal obligations: We will also process your personal data where we are under a legal obligation to do so to. For example, to:   

• Prevent and detect fraud, money laundering, other crime, and security issues.  
• Comply with laws and regulations, as well as any sector-specific mandatory guidelines and regulations.   

(C) Legitimate interest:  We also process your personal data on the basis of our legitimate interest, or the legitimate interests of others. Our legitimate interests are to:   

• understand our user demographic, preferences and behaviours so we can improve the relevance of Snoop to individual customers;  
• track the use of the Apps and website and identify areas where we can improve performance or functionality (business and technical);  
• keep going as a business and continue to provide a free service, which means we may provide aggregated market research services, from which all personal data is removed, to other businesses in return for revenue;  
• to help us grow and develop our business and help our customers with the account opening process;  
• operate our website and Apps generally;  
• carry out market research and business development;  
• to help potential customers complete their onboarding journey;
• provide services to our customers;  
• invest in and roll out new services to benefit our existing customers and to attract new customers; and 
• for business purposes.  

(D) Consent: If we rely on your consent for us to use your personal data in a particular way, but you later change your mind, you may withdraw your consent by contacting us at privacy@snoop.app and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide our app and associated services to you. 

4. Your key rights 

You have the following rights in relation to your personal data: 

Right to object: You have a right to ask us to consider any valid objections which you have to our use of your personal data where we process your personal data on the basis of our or a third party's legitimate interest.     

Right of access: All data that you have provided to us is accessible through the Apps. You can request a copy of all personal data you have provided by sending us an email from the email address you use for your Snoop account. We can only give you the data we hold ourselves. Any data that a partner holds about you is with that partner. You should request access to that data directly with them. We will help you where we can.   

Right to data portability: You have a right to ask us to provide your personal data to a third-party provider of services.  

Right to rectification: You can control your data through the Apps. Where you cannot change this data through the Apps, you have the right to ask us to rectify inaccurate or incomplete personal data which we have about you.   

Right to erasure: You have the right to ask us to erase your personal data. You can close your Snoop account by emailing us at hello@snoop.app, or by using the appropriate feature in the Apps, when available. We will then anonymise and archive all data we have about you 6 months later (we keep this data for 6 months in case of any subsequent queries and for legal and regulatory requirements, unless you ask us to delete it following closure (and this doesn't conflict with our legal and regulatory requirements), which you can do by sending us an email at privacy@snoop.app. Be aware that the partners you have used may still have data about you. You will need to contact them directly in order for them to delete this data.  

Right to restrict use of your personal data: You have a right to ask us to restrict the way that we process your personal data in certain specific circumstances. We will also pass your request onto other recipients of your personal data unless that is impossible or involves disproportionate effort.  

If you wish to exercise any of the rights set out above, please email us at privacy@snoop.app. We aim to respond to all 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.  

You will not have to pay a fee to access your personal information (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.  

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

Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.  

5. Where do we store your personal data? 

Your personal data is processed and stored on secure computer systems located in the UK, European Economic Area and the US.  

The following suppliers may store or access your personal data outside of the UK: 

• Amazon Web Services – Snoop hosting Platform (EEA - Ireland) 
• Openwrks – Open Banking data aggregator (EEA - Ireland) 
• Tink – Open Banking data aggregator (EEA - Ireland) 
• Braze – Customer Communications (EEA - Ireland) 
• Zendesk – Customer Support helpdesk (EEA or US) 
• Amplitude - Customer behaviour tracking analytics (US) 
• Segment - Customer behaviour tracking data (US) 

If we provide any personal data about you to any of the above non-UK suppliers, we will take appropriate measures to ensure that the recipient protects your personal data adequately in accordance with this Privacy Policy.  These measures may include the following: 

• ensuring that there is an adequacy decision by the UK Government in the case of transfers out of the UK, which means that the recipient country is deemed to provide adequate protection for such personal data;
• where we have in place standard model contractual arrangements with the recipient which have been approved by the UK Government. These model contractual clauses include certain safeguards to protect the personal data. 

Partners and services you decide to use through the Snoop service could decide to store your data in other countries or parts of the world. We recommend you read carefully their privacy policies. When you use a partner service, the partner or our Apps will give you easy access to these privacy policies. 

6. Protecting your personal data 

We are committed to ensuring that your personal data is secure.   

In order to prevent unauthorised access to, or disclosure of, your personal data, we have put in place suitable physical, electronic and operational procedures to safeguard and secure It. For example, we protect your personal data by deploying secure sockets layer (a security protocol) and high standard encryption algorithms. We also ensure that we meet security standards imposed by law that are applicable to the operation of Snoop.  

Help us help you: to help us protect your personal data, you should comply with our security policies and procedures that we may notify you about in our Terms from time to time.   

7. Who we share your personal data with 

Partners 

We may use your personal data to enable you to use or purchase the products or services of our partners.   

 You are in control:   

• We only share your personal data where you have requested to use a partner service. 
• Only after receiving such a request will we disclose or provide your personal data to those third parties so that they can provide their services to you and give you a smooth user experience.   
• We won't disclose more than is needed for the products and services of that partner. 

Please remember that the use of your data by our partners will be governed by their terms and conditions and their privacy policy – we do not control this.  

If you want a partner to delete your data, then you should contact them directly.  We will try to help you as much as we can. 

Providers, Regulators and Law Enforcement    

Other than what is described above, we will only share your personal data in a very limited way. This will happen either where (1) it is in our legitimate interests to do so to run , grow and develop our business, (2) if we are under a duty to disclose it to comply with any legal obligation, or (3) in order to enforce of apply our Terms. 

We may share your personal data with the following: 

• Our service providers (including their sub-contractors). This may happen where they help us to run our service or the technology systems that are needed to operate our website, app and services. These are:  

• Regulators in connection with their duties
• Fraud prevention agencies and law enforcement agencies, where we’re required to help them do their job 

We will always ensure that any third parties with whom we share your personal data are subject to privacy and security obligations consistent with this privacy policy and applicable laws.  

We may also disclose and use anonymised, aggregated reporting and statistics about users of our Apps and website for the purpose of reporting to third parties for industry analysis (and we might be paid for this), and for our marketing and promotion purposes (see the section on 'Communicating the benefits of Snoop' for more information). None of these anonymised, aggregated reports or statistics will enable our users to be personally identified. 

Save as expressly detailed above, we will never share, sell or rent any of your personal data to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal data in a particular way, but later change your mind, you should contact us and we will stop doing so. 

8. How long do we keep your data? 

After you have closed your account we will then anonymise and archive all data we have about you 6 months later (we keep this data for 6 months to fulfil legal and regulatory requirements and make sure we can investigate customer service queries or complaints after closure), unless you ask us to delete it immediately following closure (and this doesn't conflict with our legal and regulatory requirements) which you can do by sending us an email at privacy@snoop.app.

9. Using computers to make decisions about you 

Snoop is designed to process your personal data to make suggestions designed to save you money, or help you manage your life more effectively. We store information about you on our systems in order to make decisions on what products and services to suggest to you.   

We do not currently use automatic processing or profiling to make automated decisions about you that could significantly impact you (like refusing you financial products or credit profiling). If this ever changes in future, we will let you know.  

10. Communicating the benefits of Snoop 

We want to share the benefits that Snoop can bring to all UK consumers, so the data we collect might be used anonymously in communications such as:   

• Blog posts and infographics,   
• Emails, 
• Social media posts, and 
• Marketing campaigns. 

Any data we use in support of the above is always anonymised and aggregated and can never be tracked to you personally. 

11. Links to other websites 

Our Apps contain hyperlinks to and from the websites or apps of our partners and other third parties. Any hyperlinks we provide are there to help you access the services of our partners and are for your reference and convenience, or may be used to understand the action you’ve taken to allow us to improve the service we offer or fulfil offers. When we provide hyperlinks to other websites, we are sometimes paid by the partner or third party. If we are paid when you use the hyperlink on our Apps to purchase a third party product or service, this is clearly disclosed.  

This Privacy Policy only applies to the personal data that we collect or which we receive from third party sources, and we aren’t responsible for personal data about you that is collected and stored by third parties. Third-party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal data to these websites. We do not accept any responsibility or liability for the content of third-party websites or third-party terms and conditions or policies.  

12. Children 

You must be aged 18 or over to use our Snoop service. Our website and Apps are not directed at children under the age of 18 and we do not knowingly collect any personal data from visitors in this age group.   

If you are under the age of 18 and we learn that we have inadvertently obtained personal data from you from our website, Apps, or from any other source, then we will delete that information as soon as possible.  

Please contact us at privacy@snoop.app if you are aware that we may have inadvertently collected personal data from a child under the age of 18.  

13. Our Contact Details 

Snoop is a registered trade mark of Usnoop Limited. Our registered office is Usnoop Ltd, 10 Norwich Street, London, United Kingdom, EC4A 1BD.  

If you have any questions about our privacy policy or our collection, use or storage of your personal data, please send an email to privacy@snoop.app  

14. Complaints to the Information Commissioners Office (ICO) 

You have the right to complain to the ICO if you believe we might have broken data protection rules.   

The ICO can be contacted at: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 0303 123 1113 (local rate) or 01625 545 745. Our ICO reference ID is ZA564008.   

15. Changes to our Privacy Policy 

We may update our Privacy Policy from time to time. Any changes we make to our Privacy Policy in the future will be posted on this page and, where  a material update is made, provided to you by email or in another appropriate manner.  

16. Personalised Advertising and Cookies 

We also use personalised online advertising to tell you about our Apps and our products and services. This means that you may see advertising for our Apps, products and services when you are on other third-party websites, including social media platforms.     

We use the Facebook Pixel on our website and Apps, which is triggered when you engage with one of our ads on Facebook. When you click on a Facebook ad and are redirected to our website or Apps, the Facebook Pixel tracks your behaviour on our website or Apps and if you take an action, the Facebook Pixel will report it to us. This allows us to measure the effectiveness of our Facebook ads for statistical and market research purposes and helps us target our ads.   

Using the Facebook Pixel, the ads you see are personalised whilst you are using Facebook, through Facebook's Custom Audiences tool. When you browse our website and Apps, information about your browsing session, along with a hashed version of your Facebook ID and the URL viewed, is sent to Facebook. When you then use Facebook, you will be shown personalised ads based on your experience whilst using our website or app.  

You can find out more about how Facebook processes your personal data in its Data Policy here:  

https://www.facebook.com/policy.php

You can opt-out of the collection of your personal data by Facebook Pixel, or to the use of your personal data for the purpose of displaying Facebook ads using Custom Audiences using this link.  

We may use and support one or more Google tools, including Google Analytics (including Universal Analytics), Google AdWords (including Smart Pixel), Google Developer Console, Google Display Advertising and Google Customer Match which may include one or more of the following features:  

• remarketing;
• Google Display Network Impression Reporting;  
• the DoubleClick Campaign Manager integration; and   
• Google Analytics Demographics and Interest Reporting.  

We use these tools to better understand you and our other customers, to deliver personalised online advertising to you and others like you on Google properties (such as YouTube and Google Maps), and to measure the effectiveness of our Google ads for statistical and market research purposes so that we can better target our ads. Some of these tools also use cookies, so please see our Cookie Policy below for further details.   

You can opt-out of Google advertising by visiting the Google Ads Settings page.

Cookie Policy 

What cookies are used by Snoop?  

Snoop uses third-party cookies (meaning the cookies are provided by third parties and are not proprietary to Snoop) to track when you visit our Apps or website and what you look at. By understanding which areas of our Apps or website are the most popular and where visitors spend their time, we can improve the performance for everyone.   

We also use third-party cookies to allow us to:  

• Find out whether our advertising encourages people to download or access our Apps or visit our website.  
• Show you advertising and content relating to Snoop. For example, if you visit the Apps and look at a page giving information about being part of our beta launch but don’t sign up, we could use cookies to show you advertising in the future to remind you about Snoop, as it may be something you’re interested in.   

The table below shows the third-party cookies Snoop uses and why we use them:  

Tracking (third-party cookies) 

Advertising (third-party cookies) 

In relation to our website and Web App, we will ask you whether you consent to our use of cookies when you first use our website or Web App. You can choose which specific cookies you consent to. These preferences will then be remembered for one year however, you can turn off or manage your cookie preferences at any time here. You can also delete cookies if you would like to by using your browser or mobile phone settings.

If you turn off or delete cookies you may still see advertising for Snoop, but these adverts will be general and not tailored to you based on your visits to the Apps or website.