Introduction

Emma Technologies LTD. ("we" or "us"), is a company registered in England and Wales whose registered office is at 49-51 Central Street, London, England, EC1V 8AB and whose registered number is 10578464. We are committed to protecting and respecting your privacy and to providing clear information about the use of your data.

We are the data controller for the purposes of the personal data we collect via our website and for the performance of the services listed under the usages of your personal data, below (together, the “Services”). We are registered with the Information Commissioner's Office (the ICO) with registration number: ZA241546.

Definitions

For the purposes of this policy, the following definitions apply:

• Personal Data: Any information relating to an identified or identifiable individual. This includes, for example, your name, address, email, date of birth, identification numbers, and online identifiers.
• Special Category Data: Certain types of personal information given extra protection under the law. This includes information about your health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, or sexual orientation.

Emma may process special category data when assisting vulnerable customers, and such processing is subject to enhanced safeguards to protect your privacy.

‍Use of our online Services

Collection of personal data

‍When you use our Services we will have access to the personal data that you submit to us and personal data held by Account Servicing Payment Service Providers (i.e. any payment service provider, such as a bank or a credit card issuer that maintains an online payment account on your behalf) (“ASPSPs”) (“Personal Data”) for the duration of the transmission. Such Personal Data may include your date of birth, gender, account information, account balance, transactions, information on loans, insurance data and investments data. The manner in which we access, use, process and store your personal data for the provision of the Services is set out below.

Contacts list

Emma transmits the contacts lists on your phone so you can easily make payments to your contacts using the Emma app. You can, of course, choose not to sync your contacts list with Emma. This means that you won't be able to identify which of your mobile phone contacts are Emma's customers.

‍‍Images

Emma stores the image that you decide to upload when attaching a receipt to a transaction, verifying your identity with us or adding a profile picture to your profile. You can, of course, choose not to upload any of this data.

‍Personal Data

‍Use of your personal data

In order to access and use the main functionality of our Services, we will direct you to use one of our trusted service providers or an ASPSP that implements Open Banking in order to transmit and access information (including personal data) relating to payment accounts (“Account Information”) that you hold with ASPSPs to us.

The information we collect and the process will be used to run the Services.

How we use your data

‍Your personal data is used for the purposes described in this policy, including to:

• Provide and manage your account and our services;
• Meet legal and regulatory requirements (e.g., KYC checks);
• Improve and customise our app and services;
• Monitor for and prevent fraud and financial crime.

Automated Decision Making and Profiling

We use automated systems to make decisions that may significantly affect you, including:

• Identity Verification: Our systems automatically verify your identity using data from Experian and Open Banking. This process analyses your personal information against databases to confirm your identity and assess risk.
• Financial Crime Screening: Experian and ComplyAdvantage systems automatically screen your information against sanctions lists, politically exposed persons (PEP) databases, and adverse media to prevent money laundering and terrorist financing.
• Fraud Detection: Our algorithms analyse transaction patterns, device information, and transaction data to identify potentially fraudulent activity.
• Credit Assessment: Where applicable, automated systems may assess your creditworthiness using your financial data and external credit reference information.
• The Logic Involved: These systems use algorithms that compare your data against known patterns, risk indicators, and regulatory databases. Decisions are based on predetermined risk thresholds and compliance requirements.
• These automated decisions can result in account restrictions, transaction blocks, service denial, or additional verification requirements.
• Your Rights: If any automated decision significantly affects you, you have the right to request human intervention, express your viewpoint, and contest the decision by contacting [email protected].

Data Retention Schedule

We will only retain your personal data for as long as necessary to fulfil the purposes outlined in this policy or as required by law. The specific retention period depends on the type of data and our legal and regulatory obligations. In general, this may include keeping your data for up to seven years after our business relationship with you has ended.

Consent

We’ll be able to access your Account Information (including any Personal data), if you give us explicit consent.

‍How do I withdraw my consent?‍

If after you provide your consent, you change your mind, you may withdraw your consent by contacting us at our address or at the email address set out in the contact information above.

Legal Bases for Processing

Emma Technologies LTD processes your personal data only where it has a lawful basis to do so, as required under the UK GDPR and Data Protection Act 2018. The main legal bases Emma relies on are:

• Contract: To provide you with our services and fulfil our obligations to you.
• Legal Obligation: To comply with laws and regulatory requirements, such as anti-money laundering (AML) and Know Your Customer (KYC) regulations.
• Legitimate Interests: To operate and improve our services, provided these interests do not override your rights and interests.
• Consent: Where required, we will seek your explicit consent (for example, for certain marketing activities). You may withdraw your consent at any time.

Deletion of Personal Data

We will not keep your Personal Data for longer than necessary. We will delete your Personal Data as soon as it is no longer needed to provide the Services to you or upon termination of the Terms of Service. To request your data to be deleted, please contact live chat in the app, use the delete function in your profile settings page, or send us an email at [email protected]. Your data will be deleted within 30 days of your request.

Just to let you know, as a regulated financial services provider, we must keep certain customer personal data even when you ask us to delete it. If you've closed your Emma account, we may not be able to delete your entire file because these regulatory responsibilities take priority. We'll generally keep your personal data for seven years after our business relationship ends, or such period as may be required by applicable local laws.

Disclosure

We share your personal data with the following categories of third parties:

Essential Service Providers:

• Banking Partners: Secure data transmission for account connectivity and payment processing
• Cloud Infrastructure Providers: Amazon Web Services (AWS) for secure data storage and processing
• Identity Verification Services: Experian for KYC checks and identity confirmation
• Compliance Screening: ComplyAdvantage for PEP and sanctions screening

Regulatory and Legal:

• Financial Conduct Authority (FCA): As required for regulatory compliance and reporting
• HM Revenue & Customs (HMRC): For tax reporting obligations where applicable
• Law Enforcement: When legally required by court order or statutory obligation

Business Operations:

• Customer Support Platforms: For managing customer inquiries and technical support
• Analytics Providers: Anonymised data for service improvement and fraud prevention
• Marketing Partners: Only with your explicit consent for promotional communications

All third-party providers are contractually bound to protect your data and use it only for specified purposes. We conduct due diligence on all partners to ensure appropriate data protection standards.

Credit Broking Services

Emma Technologies Ltd acts as an Introducer Appointed Representative and is not a lender. We introduce customers to Monevo Limited, who is a licensed credit broker. As part of this service, if you apply for a loan via Emma, your information will be shared with Monevo in order to obtain loan quotes. By submitting your details, you confirm that the information you provide is accurate and you agree to Monevo's Terms & Conditions and Privacy Policy. You understand that your data may be shared with TransUnion (formerly Callcredit) and other credit bureaus for the purpose of matching you with a lender.

‍Keeping Your Personal Information Secure

‍ We take the security of your personal information very seriously and have appropriate physical, technical and administrative procedures in place to help protect your personal information from unauthorised access, use or disclosure as required by law in England.

Once we have received your User Information, we will use strict procedures and security features to try to prevent unauthorised access including: encrypting any Personal Information which we transfer to our banking partner; and having in place an agreement with our banking partner which requires it to have in place appropriate measures to safeguard the security of the Personal Information we send to them.

Your Rights

Subject Access Requests

You have the right to ask us to provide any personal data we have collected about You, to You. Should You wish to do so, please email us at [email protected] to make a subject access request detailing:

• your name,
• your address,
• the period of data you’d like access to.
• Making a complaint to a supervisory authority

Should you be dissatisfied with the service we provide, You have the right to file a formal complaint to the Information Commissioner's Office at www.ico.org.uk.

Under data protection law, you have the following rights with respect to your personal data:

• Right to be Informed – To know how we collect and use your data.
• Right of Access – To request a copy of the personal data we hold about you.
• Right to Rectification – To correct inaccurate or incomplete data.
• Right to Erasure – To request deletion of your data in certain circumstances.
• Right to Restrict Processing – To restrict how your data is used.
• Right to Data Portability – To receive your data in a portable format or have it transferred to another provider.
• Right to Object – To object to our use of your data, including for marketing or profiling.
• Right Related to Automated Decision Making and Profiling – To challenge and request human review of significant decisions made solely by automated means.

To exercise any of your rights, if you have concerns about how we handle your personal data, or if you wish to make a complaint please contact us at [email protected] . We may ask for proof of your identity before processing your request.

We will respond to your request as soon as possible and at the latest within one month of receipt. In complex cases, we may extend this period by up to two additional months; if we do, we will notify you and provide reasons.

In most cases, you will not have to pay a fee. However, if your request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse to comply—if so, we will explain why.

If we refuse your request, you will receive an explanation and information on how to complain to the Information Commissioner’s Office (ICO).

Changes To This Policy

‍If we change this policy, we will post the revised policy here with an updated effective date. If we make significant changes to the policy, we may also notify you by other means such as sending an email or posting a notice on our home page.

‍Cookies Policy

At Emma Technologies, we are committed to safeguarding your privacy and ensuring a transparent approach to how we use cookies and similar technologies on our website (https://emma-app.com/).

This Cookie Policy outlines what information is collected by cookies, how we use that information, and how you can manage your cookie preferences. For further details on how we handle your personal data, please refer to our Privacy Notice.

‍A cookie is a small data file that we store on your browser or the hard drive of your computer if you agree. Cookies are widely used to make websites work or work more efficiently, as well as to provide information to the owners of the site.

‍Emma Technologies Ltd (Emma) uses cookies to better understand how visitors interact with our website. These cookies help us tailor our website to your needs, provide you with a seamless experience while using our services and communicate with you across the web in a personalised manner.

Types of Cookies We Use:

1. Strictly Necessary Cookies: These cookies are essential for the operation of our website. For example, they enable you to log into secure areas of our website or access specific features like live chat. Without these cookies, certain services cannot function.
2. Analytical/Performance Cookies: These cookies help us analyse how visitors use our website. For example, they enable us to count the number of visitors, understand how visitors navigate our site and identify areas for improvement

We use Google Analytics to help us measure how you interact with our website and its contents. You can find more information about the individual cookies we use, the purposes for which we use them and their default expiration times by following this link.

You can block cookies by activating the settings on your browser that allow you to refuse the storage of all or some cookies. However, please note that disabling all cookies (including essential cookies) may impact the functionality of our website and restrict your access to certain features.

If you have any questions or require assistance with managing cookies, please contact us at:

[email protected] or on our live chat.

We may update this Cookie Policy from time to time to reflect changes in technology, legislation, or our practices. We encourage you to review this page periodically for the latest updates.

By continuing to use our website, you consent to the use of cookies as described in this policy unless you have opted out via your browser settings.