1. Privacy Notice
  2. Version 2.0, Effective 18 May 2018
  3. PLEASE READ THIS PRIVACY POLICY VERY CAREFULLY

SETTING THE SCENE

At Starling, service is our no.1 priority. This includes respecting your privacy and protecting your information. This has always been the case and so we have updated this notice to build on what we are already doing and to make sure it works with the new data protection law, GDPR.

Part of the updates include trying to make this notice even easier to understand. To help us do this, we use some straightforward words throughout the notice that are detailed at the bottom of it – so if you need to check what one of these words means, scroll down to the bottom.

The notice describes how we collect and use your information and it covers all the ways you can interact with us….and there are lots of ways! For example: you visit any of our websites, you use the App, you have an account with us, you get in touch with us, you apply for a job or you use a service that integrates with us.

Please note that you don’t have to transfer your information to us; however, if you don’t, it will severely limit your ability to use our services – in particular, you will not be able to have a bank account with us.

The notice has the following sections, so it’s best to look there first:

  1. – What information do we collect;
  2. – How do we use your information and what is the lawful basis;
  3. – Who do we share your information with;
  4. – Some specific information about credit reference and fraud prevention agencies;
  5. – Where do we process and store your information or transfer it;
  6. – Your rights;
  7. – Other information that we need to give you or we think you’ll find useful;
  8. – Meanings of some of the terms we use.

Each section has two parts:

  1. In short – this sets out a brief, easy to read summary of that section; and
  2. If you want more detail – this is a more comprehensive explanation of that section.

Our websites and the App may, from time to time, contain links to and from the websites or other links or apps of our partner networks and our affiliates. If you follow one of these links, please note that these links and destinations have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any of your information via these links or destinations.

1. WHAT INFORMATION DO WE COLLECT?

In short, we collect and use information about you that is picked up when you interact with us such as through our websites, when you use the App, if you have an account with us, if you get in touch with us, if you apply for a job or if you use a service that integrates with us. We also collect and use information about you that is provided by third parties.

If you want more detail, here is the information that we may collect about you:

2. HOW DO WE USE YOUR INFORMATION AND WHAT IS THE LAWFUL BASIS?

In short, we use your information in order to carry out our operation as a bank and provide banking and financial services, to make sure we don’t breach any contracts, to keep Starling and you secure, to give people information about services and to comply with the law.

If you want more detail, we use your information in the following ways:

We process your information for the purposes set out above on the following grounds: given our legitimate interest in providing banking and financial services, operating and improving Starling and being as efficient as we can about complying with legal duties, obligations and regulations that apply to us and keeping our records up to date.

We process your information for the purposes set out above on the following grounds: where it is necessary for the adequate performance of contracts with you and to take steps requested by you prior to you entering into contracts with us.

We process your information for the purposes set out above on the following grounds: your consent to do so where you choose to share your information with Marketplace partners and any other third parties and where it is necessary for the adequate performance of contracts with you and to take steps requested by you prior to you entering into contracts with us where Marketplace partners share it with us and being as efficient as we can about complying with legal duties, obligations and regulations that apply to us and keeping our records up to date.

We process your information for the purposes set out above on the following grounds: given our legitimate interest in undertaking activities to offer you products or services that may be of interest to you or that you have expressed an interest in hearing about, given our legitimate interest in providing banking and financial services, operating and improving Starling and being as efficient as we can about complying with legal duties, obligations and regulations that apply to us and keeping our records up to date.

We process your information for the purposes set out above on the following grounds: given our legitimate interest in operating and improving Starling and providing banking and financial services.

3. WHO DO WE SHARE YOUR INFORMATION WITH?

In short, sometimes we share your information with our affiliates, with those we do business with, with credit reference and fraud prevention agencies, with law enforcement bodies and regulators or if the information is aggregated (and so cannot identify you specifically).

If you want more detail, we may share your information in certain circumstances, including:

4. CREDIT REFERENCE AGENCIES, CREDIT SCORING AND FRAUD PREVENTION AGENCIES

In short, we use credit reference and fraud prevention agencies for a number of matters including when you apply for an account with us and in relation to lending. Some of the ways we use them is through automated decision making but you can contact us if this happens and you want us to look at an application again.

If you want more detail:

5. WHERE DO WE PROCESS AND STORE YOUR INFORMATION OR TRANSFER IT?

In short, we generally process your information through servers in the EEA and normally store it for six years. Sometimes the information goes outside the EEA but we try and keep this to a minimum and we put safeguards in place as far as possible.

If you want more detail:

6. YOUR RIGHTS

In short, you have certain rights under the law and under this notice to request access to your information, to manage it and to request us to delete or transfer information about you or restrict the way it is used. You also have a right to complain.

If you want more detail:

7. OTHER IMPORTANT MATTERS

In short, please check frequently for updates to this notice and, if you need to contact us, details are below.

If you want more detail:

8. WHAT THE WORDS MEAN