1. Introduction
This Privacy Notice explains how Grey Finance LTD ("Grey", "we", "us" or "our") collects, uses, shares and protects your personal information across our websites, applications, products, and related services (collectively, the “Services). we are committed to protecting your privacy and ensuring transparency in our data processing activities. This Privacy Notice forms part of our Terms of Use.
This Privacy notice applies to your use of our Services through any device, including desktop, mobile, or tablet. It does not apply to services not owned or controlled by Grey, including third-party websites or platforms. Such third parties operate under their own privacy policies, and Grey is not responsible for their data handling practices.
2. Who We Are
Grey Finance LTD is registered in England and Wales (company number 13849254) with our registered office at Suite Q, Athene House 86 The Broadway, Mill Hill, London, United Kingdom, NW7 3TD. We act as the data controller for the personal information we collect and process about you.
3. Information We Collect and Process
To gain full access to our website and services, you must register for a Grey account. When you register for an account, we collect Personal Information which you voluntarily provide to us. Personal Information refers to information relating to an identified person or information that can be used to identify you, (e.g. name, email, address, bank details, telephone number). It may also include anonymous information that may be linked to you specifically, (e.g. IP address).
The Personal Information we have about you is directly made available to us when you:
- Sign up for a Grey Account;
- Use any of our services;
- Contact us or our customer support team;
- Fill our online forms;
3.1 Core Data Categories
| Type of Data |
What We Collect |
Why We Need It |
| Identity Data |
Full legal name and any previous names Date and place of birth Gender Nationality and citizenship status National Insurance number or tax identification number Unique identifiers (account numbers, customer reference) |
To verify your identity To comply with anti-money laundering regulations To fulfil our regulatory obligations as an e-money institution |
| Contact Data |
Residential address Email addresses (personal and business) Telephone numbers Correspondence preferences Emergency contact details |
To communicate with you about your account To send mandatory service notifications To verify your residence To prevent fraud |
| Financial Data |
Bank account details (account numbers, sort codes, IBANs) Payment card information Source of funds and wealth information Income details Tax residency status |
To process your transactions To prevent financial crime To assess financial risk To comply with tax regulations |
| Transaction Data |
Payment records (incoming and outgoing) Transaction timestamps and locations Merchant details Transaction purposes and categories Currency conversion details Standing orders and direct debits |
To maintain accurate transaction records To provide transaction history To detect suspicious activities To improve our services |
| Technical Data |
IP addresses and connection data Device identifiers and specifications Operating system information Browser type and version Time zone and language settings Mobile device information |
To ensure secure access To optimise service delivery To prevent unauthorised access To improve user experience |
| Profile Data |
Account preferences Security settings User behaviour patterns Service usage history Customer feedback Survey responses |
To personalise our services To improve user experience To maintain account security To develop new features |
| Usage Data |
Login patterns Feature utilisation Navigation behaviour Session duration App/website interaction patterns Error logs |
To improve service functionality To identify technical issues To enhance user interface To develop new features |
| Marketing and Communications Data |
Marketing preferences Communication opt-ins/opt-outs Preferred contact methods Interest categories Campaign response history |
To manage marketing consents To personalise communications To respect your preferences To improve our marketing efforts |
| Special Categories of Personal Data |
We generally do not actively collect or process special category data. However, we may incidentally process such data when: It appears in identity documents (e.g., photograph in passport) It's relevant for providing specific services You choose to share it with us |
To verify identity documents To provide accessible services To meet specific regulatory requirements |
3.2 Lawful Bases for Processing
We process your data based on the following legal grounds:
- Contractual necessity
- Legal obligations
- Legitimate interests
- Consent
Each of them is discussed in more detail below.
3.2.1 Contractual Necessity
We process data where it is required for the purposes of entering into or fulfilling a contract between us. This includes situations required to:
- To provide our services
- To execute your payment instructions
- To maintain your account
- To deliver our core financial services
3.2.2 Legal Obligations
We process data where it is required to fulfil our legal obligations. These legal obligations include but are not limited to:
- Anti-money laundering checks
- Counter-terrorist financing verification
- Counter-proliferation financing compliance
- Regulatory reporting requirements
- Tax compliance obligations
- Financial crime prevention
3.2.3 Legitimate Interests
We process data for our legitimate interests where necessary and proportionate:
| Legitimate Interest |
Purpose |
Data Involved |
Justification |
| 1. Fraud Prevention and Detection |
Identify, prevent, and mitigate fraudulent activities. |
Transaction histories, account details, behavioural data |
Protects Grey and you from financial loss and security breaches. |
| 2. Direct Marketing of Own Products and Services |
Inform you about new products, services, promotions, or updates. |
Contact information, transaction history, preferences |
Facilitates business growth and your engagement, with opt-out options available. |
| 3. Improving Products and Services |
Analyse your data to enhance offerings and develop new features. |
Usage patterns, feedback, demographic information |
Enhances your satisfaction and maintains competitive advantage. |
| 4. Customer Support and Service Management |
Handle your inquiries, resolve issues, and provide effective support. |
Contact information, account details, communication history |
Essential for maintaining high-quality customer service and operational efficiency. |
| 5. Operational Efficiency and Business Management |
Manage day-to-day operations, including account management and billing. |
Financial records, account information, employee data |
Necessary for the smooth functioning and sustainability of the business. |
| 6. Risk Management and Assessment |
Evaluate and manage risks such as credit, operational, and compliance risks. |
Financial data, credit histories, transaction records |
Helps in making informed decisions and maintaining financial stability. |
| 7. Security of Systems and Data |
Protect IT systems from cyber threats, unauthorised access, and breaches. |
Access logs, security protocols, user credentials |
Ensures the integrity and confidentiality of sensitive information. |
| 8. Communication of Important Information |
Send essential updates, changes in terms, and policy updates to customers. |
Contact information, account details |
Keeps customers informed and ensures compliance with regulatory requirements. |
| 9. Data Analytics and Reporting |
Conduct internal analyses, performance monitoring, and generate reports. |
Aggregated transaction data, user behaviour metrics |
Supports business intelligence and informed strategic decision-making. |
| 10. Compliance with Legal and Regulatory Obligations |
Ensure adherence to legal and regulatory requirements. |
Varies depending on the obligation (e.g., AML, Consumer Duty, Vulnerable Customer Treatment, Complaints Management, etc.) |
Maintains compliance with laws and regulations, which may overlap with legitimate interests. |
3.2.4 Consent
Lastly, we rely on your consent and where appropriate, we obtain your explicit consent for:
- Marketing communications
- Special category data processing
- Cookies and tracking technologies
- Third-party data sharing
Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
Data Protection Principles
4.1 Security Measures
We take your data’s security seriously and have put in place strong measures to keep it safe. These include:
- Encrypting your data: This applies both when it’s being sent over networks (in transit) and when it’s stored (at rest).
- Restricting access: Only authorised individuals with proper credentials can access your data.
- Regular checks: We routinely assess and update our security systems to stay ahead of potential risks.
- Training our team: All staff undergo regular training to ensure they understand and comply with data protection practices.
- Preparedness for incidents: If there’s ever a security issue, we have clear procedures in place to handle it quickly and minimise any impact.
5. Data Retention
We keep your personal data for as long as necessary to meet regulatory and legal requirements, fulfil business needs, and improve our services. Specifically:
| Retention Period |
Types of Data |
| 5 years from the end of your business relationship with us or your last transaction - whichever is later |
Identity Data Contact Data Financial Data Transaction Data Technical Data Profile Data Usage Data |
| Until there is valid consent |
Marketing and Communications Data |
6. Categories of Recipients of Personal Data
6.1 Overview of Data Sharing
We share your personal data with various recipients to provide our services, meet regulatory obligations, and maintain security. All data sharing is conducted in accordance with applicable data protection laws and subject to appropriate safeguards.
6.2 Categories of Recipients
| Type |
Purpose |
Data Shared |
| Service Providers and Business Partners |
Transaction processing Payment execution Account funding Financial settlements |
Identity Data Contact Data Financial Data Transaction Data Technical Data |
| Technology and Infrastructure Providers |
Service delivery System maintenance Security operations Technical support |
Financial Data Transaction Data Technical Data Usage Data Profile Data |
| Identity and Verification Partners |
Identity verification Document authentication Address validation |
Identity Data Special Categories of Personal Data |
| Regulatory and Compliance Partners |
Fraud detection Regulatory compliance Risk assessment Statutory reporting |
Identity Data Contact Data Financial Data Transaction Data Technical Data |
| Professional Services Providers |
Legal compliance Audit requirements Professional advice Service optimization |
Identity Data Contact Data Financial Data Transaction Data Profile Data |
| Regulatory and Law Enforcement Bodies |
Regulatory supervision Compliance monitoring Statutory reporting Investigation assistance |
Identity Data Contact Data Financial Data Transaction Data Technical Data Profile Data Usage Data |
7. International Transfers
If your data needs to be transferred outside the UK or the European Economic Area (EEA), we ensure it’s handled with the same level of protection as required under UK laws. This includes:
- Implementing safeguards and using standard contractual clauses approved for international data transfers.
- Using proper mechanisms to ensure that all transfers comply with data protection regulations.
- We make sure your data privacy rights are upheld, no matter where your information is processed.
We are committed to treating your data with the utmost care, ensuring compliance with all relevant laws and maintaining the highest standards of security.
8. Your Privacy Rights
8.1 Core Rights
As a data subject, you are entitled to specific rights under data protection laws to give you control over your personal information. These include:
- Access your data: Request a copy of the personal data we hold about you.
- Correct inaccuracies: Ask us to fix any errors or incomplete information in your records.
- Erase your data: Request deletion of your data, provided there’s no overriding legal or regulatory reason for us to keep it.
- Restrict processing: Limit how we use your data, for instance, while you’re disputing its accuracy or lawfulness.
- Data portability: Obtain a copy of your data in a portable format to transfer it to another service.
- Object to processing: Refuse the use of your data for certain purposes, such as direct marketing or automated decision-making.
8.2 Additional rights
In addition to the core rights, you may:
- Withdraw consent: If we rely on your consent to process your data, you can revoke it at any time.
- Complain to authorities: File a complaint with your local data protection authority if you believe your rights have been violated.
- Challenge automated decisions: Contest decisions made solely by automated systems that significantly affect you, and request human intervention.
- Request processing limitations: Temporarily or permanently limit certain types of data processing.
8.3 Exercising your rights
We’ve made it easy for you to exercise your privacy rights:
- Reach out directly for guidance or to submit a request.
- Submit a rights request via the designated section in our app.
- Send an email to dpo@grey.co with your request details.
8.4 Response times
We aim to address your requests promptly and efficiently:
- Within 1 business day of receiving your request, we’ll provide initial acknowledgement.
- We will provide you with a full response usually within 1 month.
- If your request requires extensive investigation, we may extend the deadline by 2 months to provide a full response, but we’ll keep you informed every step of the way.
We value your privacy and are committed to respecting your rights. Please don’t hesitate to reach out if you have any questions or concerns about how your data is handled.
9. Cookies and Tracking
We use cookies and similar technologies to enhance your experience with our services. These tools help secure our systems, remember your preferences for a more personalised experience, and analyse how our services are used so we can improve their performance.
Cookies enable our servers to recognise information such as IP addresses, the date and time of visits, and general web traffic patterns. This helps us monitor usage, improve functionality, and prevent fraudulent activities.
Our cookies do not store personal or sensitive information. Instead, they contain a unique random reference that allows us to recognise your browser and provide relevant content when you return to the site.
If your browser or browser add-on allows it, you may choose to disable cookies on our website. However, doing so may affect certain features and your overall experience. By continuing to use our website without disabling cookies, you consent to their use.
10. Updates to This Notice
10.1 Changes and Notifiactions
This privacy notice may be updated from time to time to ensure it remains accurate and reflective of:
- New features, functionalities, or service updates
- Changes in laws, regulations, or guidance from authorities
- Enhancing your understanding and clarity
- Changes in how we collect, use, or handle your data
We are committed to keeping you informed about any significant changes to this notice but you should still visit this page from time to time. If you keep using our Services, you consent to all amendments of this Privacy Policy.
11. Contact Information
11.1 General Enquiries
For day-to-day questions and account support, we're here to help:
- Through our app's chat feature (fastest response)
- By email at support@grey.co
Our support team can assist with account questions, transaction issues, and general matters. Most queries can be resolved quickly through these channels.
11.2 Data Protection Queries
For questions or concerns about your data privacy or this notice, you can contact our Data Protection Officer (DPO) at dpo@grey.co.
11.3 Complaints
If you are dissatisfied with how we handle your personal data, we encourage you to reach out so we can address your concerns.
- Contact our DPO: We will work to resolve your issue promptly and transparently.
- Escalate to the ICO: If you feel your complaint remains unresolved, you can contact the UK’s Information Commissioner’s Office (ICO). More details on how that can be done can be found here: https://ico.org.uk/global/contact-us/contact-us-public/