Privacy Policy

1234567891011 Cheddar Privacy Policy
Welcome to Cheddar Payments Limited's ("Cheddar", "we", "us" or "our") privacy policy.
Cheddar respects your privacy and is committed to protecting your personal data. This privacy policy
will inform you as to how we look after your personal data when you visit our website (regardless of
where you visit it from) or use our App and tells you about your privacy rights and how the law
protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set
out below. Please also use the Glossary to understand the meaning of some of the terms used in this
privacy policy.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
1 Important information and who we are  
Purpose of this privacy policy
This privacy policy aims to give you information on how Cheddar collects and processes your
personal data through your use of our platform, social payment service and cashback rewards
scheme, including any data you may provide when you access our mobile application (the “App”) or
website, register with us, purchase a product or service (either via our App or website), contact us,
send us your feedback, enter one of our competitions, or complete our customer surveys.
Our App and website are not intended for children and we do not knowingly collect data relating to
children under the age of 13.
It is important that you read this privacy policy together with any other privacy policy or fair processing
policy 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 policy
supplements other notices and privacy policies and is not intended to override them.
ControllerCheddar is made up of different legal entities, details of which can be found here: [LINK]. . These
include:
- Cheddar Payments BV, with registered offices at Singel 542, 1017 AZ, Amsterdam, The
NetherlandsNL; and
- Cheddar Payments Limited, with registered offices at 71-75 Shelton Street, London, WC2H 9JQ,
UK.
This privacy policy is issued on behalf of the Cheddar Group so when we mention "Cheddar", "we",
"us" or "our" in this privacy policy, we are referring to the relevant company in the Cheddar Group
responsible for processing your data. Cheddar is the controller and responsible for the website and
App.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in
relation to this privacy policy. If you have any questions about this privacy policy, including any
requests to exercise your legal rights, please contact the DPO using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in
the following ways:
DPO: Peter Elms, MLROHead of Compliance and MLRO
Full name of legal entity: Cheddar Payments Limited
Email address: data_protection@cheddar.me
Postal address: Cheddar, Soho Works, 2 Television Centre, 101 Wood Lane, London, W12 7FR
Telephone number: +44203 389 8703
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 deal with your concerns before you approach the ICO so please contact us in the first
instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on [DATE] 1st   29th
JulySeptember 2022. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us by editing your personal
details in the Cheddar Aapp.
Third-party links
This 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 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 policy of every website you visit.2 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 as follows:
●Identity Data includes first name, maiden name, last name, username or similar identifier,
marital status, title, date of birth and gender.
●Contact Data includes billing address, delivery address, email address and telephone
numbers.
●Financial Data includes bank account and payment card details.
●Transaction Data includes details about payments to and from you and other details of
products and services you have purchased from us.
●Technical Data includes mobile device ID, 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
App and this website.
●Profile Data includes your username and password, purchases or orders made by you, your
interests, preferences, cheddartag, feedback and survey responses.
●Usage Data includes information about how you use our App and/or website, products and
services, including survey responses.
●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 could be derived from your personal data but is not considered personal
data in law as this data will 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 or App
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 privacy 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.
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 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.
3 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, Profile, Marketing and
Communications, and Financial Data by filling in forms or by corresponding with us via our
website, App, by post, phone, email or otherwise. This includes personal data you provide
when you:
●apply for our products or services;
●create an account on our App;
●subscribe to our service or publications;
●request marketing to be sent to you;
●enter a competition, promotion or survey; or
●give us feedback or contact us.
●Automated technologies or interactions. As you interact with our App or website, we will
automatically collect Technical, Usage and Transaction Data about you and your equipment,
and your browsing and spending actions and patterns. We collect this personal data by using
cookies, server logs, open banking technologies and other similar technologies. We may also
receive Technical Data about you if you visit other websites employing our cookies. Please
see our cookie policy [LINK] for further details.
●Third parties or publicly available sources. We will receive personal data about you from
various third parties and public sources as set out below:
●Technical Data from the following parties: (a)analytics providers such as Google
based in the UK and/or outside the EEAUK;
           (b)        advertising networks [such as [NAME] based [inside OR outside] the UK];
and

           (c)        search information providers [such as [NAME] based [inside OR outside] the
UK].
●Contact, Financial, Technical and Transaction Data from providers of technical,
payment and delivery services including partner banks [such as [NAME] based
[inside OR outside] the UK]such as Barclays, HSBC and Lloyds bank, based inside
the UK.
●Identity and Contact Data from data brokers or aggregators such as anti-money
laundering check providers based [in the UK side OR and/or outside]  the UKthe
EEA.
●Identity and Contact Data from publicly available sources such as Companies House
and the Electoral Register based inside the UK.
●Identity, Contact and Financial Data from other users of our platform who send or
receive payments to or from you.
4 How we use your personal 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 obligation.
Click here [LINK TO GLOSSARY, LAWFUL BASIS] 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 although we
will get your consent before sending third party direct marketing communications to you via email or
text message. You have the right to withdraw consent to marketing at any time by contacting us, or
updating your marketing preferences in Aapp.
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.
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
including basis of legitimate
interest
To register you as a new
customer
(a) Identity
(b) Contact
(c) Profile Data
Performance of a contract with you
To provide our platform and
service to you, including
managing payments, fees and
charges
(a) Identity
(b) Contact
(c) Financial
(d) Profile
(a) Performance of a contract with
you
(b) Necessary for our legitimate
interests
(c) Compliance with a legal obligation
To process and deliver any
payment request to or from
your bank account
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications
(f) Profile
(a) Performance of a contract with
you
(b) Necessary for our legitimate
interests
To manage our relationship
with you which will include:
(a) Notifying you about
changes to our terms or
privacy policy
(a) Identity
(b) Contact
(c) Profile
(a) Performance of a contract with
you
(b) Necessary to comply with a legal
obligation(b) Asking you to leave a
review or take a survey
(d) Marketing and
Communications
(c) Necessary for our legitimate
interests (to keep our records
updated and to study how customers
use our products/services)
To enable you to partake in a
prize draw, competition or
complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(a) Performance of a contract with
you
(b) Necessary for our legitimate
interests (to study how customers
use our products/services, to develop
them and grow our business)
To administer and protect our
business and App and/or
website (including
troubleshooting, data analysis,
testing, system maintenance,
support, reporting and hosting
of data)
(a) Identity
(b) Contact
(c) Technical
(a) 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)
(b) Necessary to comply with a legal
obligation
To deliver relevant website
and/or App content and
advertisements to you and
measure or understand the
effectiveness of the
advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Technical
(g) Transaction
Necessary for our legitimate interests
(to study how customers use our
products/services, to develop them,
to grow our business and to inform
our marketing strategy)
To use data analytics to
improve our website, App,
products/services, marketing,
customer relationships and
experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests
(to define types of customers for our
products and services, to keep our
App and/or website updated and
relevant, to develop our business and
to inform our marketing strategy)
To make suggestions and
recommendations to you
about goods or services that
may be of interest to you
(a) Identity
(b) Contact
Necessary for our legitimate interests
(to develop our products/services and
grow our business)(c) Technical
(d) Usage
(e) Profile
(f) Marketing and
Communications
(g) Transaction
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising. We have the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage, Transaction 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 (we call this marketing).
You will receive marketing communications from us if you have requested information from us or
purchased goods or services from us and 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 for
marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us
at support@cheddar.me or updating your marketing preferences in the App or by using the
'unsubscribe' link in our emails.
Where you opt out of receiving these marketing messages, this will not apply to personal data
provided to us as a result of a product/service purchase, product/service experience 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 [LINK TO YOUR 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.
5 Disclosures of your personal data  
We may share your personal data with the parties set out below for the purposes set out in the table
Purposes for which we will use your personal data above.
●Internal Third Parties such as other companies in the Cheddar Group [acting as joint
controllers or processors]  and who are based in the Netherlands and provide IT and system
administration services and undertake leadership reporting.
●External Third Parties including:
●Service providers acting as processors based [SPECIFIC COUNTRIES] in the UK
and/or EU who provide identity verification and anti-money laundering check services.
This includes for example, W2 Global Data Solutions Limited, based in the UK.
●Professional advisers acting as processors or joint controllers including lawyers,
bankers, auditors and insurers based in the UK and the Netherlands who provide
consultancy, banking, legal, insurance and accounting services.
●HM Revenue & Customs, regulators and other authorities acting as processors or
joint controllers based in the United Kingdom who require reporting of processing
activities in certain circumstances.
●Third Party providers acting as processors who assist Cheddar in running our
business, including our CRM provider, marketing agencies and App and website
hosting providers.
●We may also need to share some personal information with other parties, such as
potential buyers of some or all of our business or during a restructuring. Usually,
information will be anonymised but this may not always be possible. The recipient of
the information will be bound by confidentiality obligations.
●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 policy.
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.
6 International transfers  
We share your personal data within the Cheddar Group. This will involve transferring your data
outside the UK.
Many of our External Third Parties are also based outside the UK so their processing of your personal
data will involve a transfer of data outside the UK.Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is
afforded to it by ensuring at least one of the following safeguards is implemented:
●We will only transfer your personal data to countries that have been deemed to provide an
adequate level of protection for personal data. For further please contact us; or
●Where we use certain service providers, we may use specific contracts approved for use in
the UK which give personal data the same protection it has in the UK. For further details,
please contact us.
Please contact us if you want further information on the specific mechanism used by us when
transferring your personal data out of the UK.
7 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.
8 Data retention  
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we
collected it for, including for 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 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, regulatory, tax, accounting or other
requirements.
9 Your legal rights  
Under certain circumstances, you have rights under data protection laws in relation to your personal
data. Please click on the links below to find out more about these rights:
●Request access to your personal data.
●Request correction of your personal data.
●Request erasure of your personal data.
●Object to processing of your personal data.
●Request restriction of processing your personal data.
●Request transfer of your personal data.
●Right to withdraw 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 could 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 could 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.
10 Glossary  
LAWFUL BASIS
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.
Comply with a legal obligation means processing your personal data where it is necessary for
compliance with a legal obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right to:
1. 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.
2. 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.3. 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.
4. 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.
5. 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:
●If you want us to establish the data's accuracy.
●Where our use of the data is unlawful but you do not want us to erase it.
●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.
●You have objected to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
6. 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.
7. 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.