Privacy Policy

How long do we keep your personal data?

How long we keep your information will depend on the purpose for which we use it. 

We only keep your information for as long as is reasonably necessary for the purposes set out in this Privacy Policy and to fulfil our legal obligations. We have internal rules that set out how long we retain information.

We will keep your personal information while you have an account with us, or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;

• to show that we treated you fairly;

• to keep records required by law.

For example, we are obliged to keep most information relating to the service we provide to you for 6 years after you have stopped using our service.  However, we will keep your Financial Information for as short a period as is reasonable after you have stopped using our service.    Further details on this are available on request using the contact details set out in the “How you can contact us?” section below.

 Who do we share your personal data with?

We may share your personal information with:

• your employer – but please note we only share with your employer the limited amount of personal information (i) that is necessary to show that you have registered for our service and (ii) in certain cases to enable your payroll team to reconcile your salary payments;

• Moneyhub Financial Technology Limited who are our Account Information Service Provider (AISP). With your consent, we provide them with certain personal information in order that we can access Open Banking services and view your bank account transaction history;

• Modulr Finance Limited who are our e-money partner. We provide them with certain personal information including your bank account details to facilitate the making of earned advances and to carry out reconciliation of salary payments on pay day;

• Flagstone Investment Management Limited are our deposit account partner. We provide them with certain personal information in order for them to open and maintain a deposit account and process deposits and withdrawals on your request;

• other third service providers who perform functions on our behalf and who also provide services to us, such as professional advisors, IT consultants carrying out testing and development work on our business technology systems;

• other third parties: when we believe in good faith that an applicable law requires it; at the request of governmental authorities conducting an investigation; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, our business or the public.

• 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 Policy

As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us, your personal information will be disclosed to such entity. These third parties will be required to comply with all our obligations under this privacy notice.

What happens if you do not provide us with the information we request or ask that we stop processing your information?

Where we need to collect personal information to comply with a legal obligation or in connection with the contract we have with you and you fail to provide that personal information 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 services).

Do we track your Mobile App activity? 

In our commitment to providing an optimal user experience and continuously improving our mobile application, we may employ anonymous tracking mechanisms. These tools allow us to gather non-identifiable information about user interactions within the app, such as aggregated usage patterns, feature engagement, and performance metrics. Rest assured that this data is collected in a manner that priorities user privacy, and no personally identifiable information is associated with these tracking activities. The sole purpose of anonymous tracking is to enhance the app's functionality, troubleshoot issues, and tailor future updates to better align with user preferences. Users can always choose to opt out of anonymous tracking within their mobile settings, ensuring transparency and control over their data.

Do we make automated decisions concerning you?

No, we do not carry out automated decision making or automated profiling.

Do we transfer your personal data outside the UK?

 We do not generally transfer personal data out of the UK.  Some of our third party service providers may transfer personal data outside of the UK or the EEA but only where our contract with them allows for it and they do so in a way that complies with the UK’s data protection laws. 

How do we keep your personal data secure?

We have appropriate security measures to prevent personal information from being accidentally lost or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

Level has ISO27001:2017 Information Security certification, certified by the BAB with certificate 235175.  These programmes are designed to independently verify Level are meeting high standards of both information security management and cyber security respectively.

In addition, we:

• implement proactive and defensive security measures on an ongoing basis throughout our software development lifecycle;

• use data encryption, both at rest and in transit;

• have role based restricted access to data;

• carry out background checks on all employees in roles which may put them in contact with your personal information.

 What rights do you have in relation to the personal data we hold on you?

 Under data protection law, you have the following rights:

1. The right to be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Privacy Policy.

2. The right of access: You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy).This is so you’re aware and can check that we’re using your information in accordance with data protection law.

3. The right to rectification: You are entitled to have your information corrected if it’s inaccurate or incomplete.

4. The right to erasure: This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

5. The right to restrict processing: You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

6. The right to data portability: You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.

7. The right to object to processing: You have the right to object to certain types of processing, including processing based on our legitimate interests and processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).

8. The right to lodge a complaint: You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.

9. The right to withdraw consent: If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.

How can you make a request to exercise your rights?

To exercise any of the rights above, or to ask a question, contact us using the details set out at the end of this Privacy Policy.

How will we handle a request to exercise your rights?

We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

• baseless or excessive/repeated requests,

• further copies of the same information.

Alternatively, the law may allow us to refuse to act on the request.

How can you contact us?

If you have questions on the processing of your personal data, would like to exercise any of your rights, or are unhappy with how we’ve handled your information, please contact us at [email protected] or raise a ticket at levelft-help.freshdesk.com/support/home.

 If you’re not satisfied with our response to any complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the UK Information Commissioner who may be contacted at https://ico.org.uk/ or by telephone on 0303123 1113.