Customer Privacy Notice

Who are we?

We are Agile Investment Development Ltd (‘we’, ‘our’, ‘us’) and operate under the name Thirdly.

We’re registered with the United Kingdom (UK) data protection authority (the Information Commissioners Office or ICO) under number ZC007822.

This notice explains how and why we use your personal information when you apply for an account, use our website or services managed by Thirdly.

Getting in touch

Email us through the app, or website link in ‘Contact Us’.

Your rights

You have a right to:

• access the personal data we hold about you, or to get a copy of it
• ask for a copy of your personal data or ask us to send it to someone else
• ask us correct inaccurate data
• ask us to delete your data, though for legal reasons we might not always be able to do it
• object to us using your data for direct marketing and where your data is processed on the basis of 'legitimate interests', or for research and statistical reasons
• withdraw any consent you've given us at any time but this does not make prior processing based on consent invalid
• restrict processing of your data
• complain to the Information Commissioner's Office. We ask that you first contact us to give us an opportunity to address any concerns.

To do any of these things, please get in touch using the details above.

How to make a complaint

If you have a complaint about how we use your personal information, please contact us and we'll do our best to fix the problem.

If you're still not happy, you can refer your complaint to the Information Commissioner Office (ICO), the UK regulator for data protection issues. For more details, visit their website.

Changes to this notice

We'll update the privacy notice on this page and if they're significant changes, we'll let you know by email or in the app.

Thirdly Customers, or application for a Thirdly account

Thirdly will collect data about you when you apply to be a Thirdly customer, and if you are successful.

Non - Thirdly Customers

Thirdly may collect data about you even if you are not a Thirdly customer. This might be if you use our website, pay or get paid by a Thirdly customer.

The information we hold about you, and how we use it

When you sign up for a Thirdly account or use our services

• personal details like your name, date and place of birth
• contact details like your home address (and previous addresses), email and phone number
• information about your identity, such as a copy of your ID document, a short video of yourself
• information about your right to live in the UK and your tax residency
• details you give us when you sign up for a specific service, like your National Insurance number if you open an Individual Savings Account (ISA)
• information you give us through in-app emails and in-app forms;
• answers you give to surveys about Thirdly and our services
• details about payments to and from your account, and your investments
• details about how you use our app

We may sometimes ask for additional information about transactions through our app to protect you and to help detect and prevent fraud and other suspicious activities.

When you use our website or social media

• your social media handle
• your interactions with our website or social media channel
• direct messages you send to our social media pages

When you get in touch

If you contact us outside of the app email contact, we collect the following information so we can help:

• the email address you use and the contents of your email and any attachments
• public details from your social media profile (like Facebook, Instagram or Twitter) if you reach out to us via these platforms, and the contents of your messages or posts to us
• details about why you are contacting us
• details of any support needs or communication preferences you disclose to us
• details of the device that you are contacting us from.

We may collect some data from your device

We collect this information to:

• provide our services to you
• keep your data safe
• improve features for you
• show you relevant advertising through our third-party advertising services on non-Thirdly sites
• perform data analysis to measure and improve our advertising channels

This includes your:

• mobile network and operating system, so we can analyse how our app works and fix any problems
• IP address and device ID (we may link your mobile number with your device)
• mobile advertising ID, so we can share it with companies that help us with advertising online (you can reset this ID or limit tracking in your phone 'Settings')
• location, if enabled, so we can help protect your account; and phone contacts (we don't store your phone contact list)
• actions taken in our app.

Who we share your data with

Companies that give services to us

Here we mean companies that help us provide services and need to process details about you for this reason, such as:

• cloud computing power, storage and software providers
• our business intelligence and analytics platform providers
• companies that help us with functional analytics (to help us solve technical problems with the website, for example)
• software companies that we use for emailing you, or for processing and storing email communications with you
• companies that help us with customer support if you reached out to Thirdly
• our insurance providers and other third companies that give us benefits
• companies that help us with fraud prevention
• third-party advertising services to show you relevant ads on non-Thirdly sites and measure ad performance.

Fraud prevention and Law enforcement agencies

We may share information about you with:

• authorities that spot and stop financial crime, money laundering, terrorism and tax evasion if the law says we have to, or if it’s necessary for other reasons
• the police, courts or dispute resolution bodies if we have to
• local health authorities, such as Adult Social Services, to safeguard your wellbeing
• other banks to help trace money if you’re a victim of fraud or other crimes, or if there’s a dispute about a payment
• any other third parties where necessary to meet our legal obligations

We also may share your details with our regulators if required.

Anyone you give us permission to share it with

We may share your data:

• we may share your posts on social media platforms
• with journalists.

How long we keep your information

We’ll keep your information for 6 years in case we need to respond to a legal claim. In some circumstances, like cases of anti-money laundering or fraud, we may keep data longer if we need to (that’s in our legitimate interest) and/or the law says we have to.

To work out how long we keep different categories of data, we consider why we hold it, how sensitive it is, how long the law says we need to keep it for, and what the risks are.