Introduction

WE ARE COMMITTED TO PROTECTING AND RESPECTING YOUR PRIVACY.

We will:

1. About us

The Digital Global group is made up of different companies. We will let you know which company you have a relationship with when you first apply for or use one of our products or services.

You can always tell which one of our companies you have a primary relationship with by scrolling to the bottom of the ‘settings’ section in the app you are using.

2. Why do I need to read this policy?

We will collect your personal data when you use:

When we say ‘personal data’, we mean information which can be used to personally identify you (for example, a combination of your name and postal address).

THE FOLLOWING POLICY CONTAINS IMPORTANT INFORMATION.

This policy explains what information we collect, how we use it, and your rights if you want to change how we use your personal data.

If you have concerns about how we use your personal data, you can contact our Data Protection Officer at dpo@thedigi.app.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

Your personal data

3. What personal data do you collect about me?

WE COLLECT DIFFERENT TYPES OF PERSONAL DATA FROM YOU AND OTHERS

The table below explains what personal data we collect and use.

Information you give us

We collect information you provide when you:

• fill in any forms;
• correspond with us;
• register to use the DIGI app;
• open an account or use any of our services;
• take part in online discussions, surveys or promotions;
• speak with a member of our customer support team (either on the phone or through the DIGI app);
• enter a competition; or
• contact us for other reasons.

We will collect the following information:

• Your name, address, and date of birth;
• Your email address, phone number and details of the device you use (for example, your phone, computer or tablet);
• Your DIGI username (this is random and is automatically assigned to you when you first join but you will be able to change it), password and other registration information;
• Details of your bank accounts, including the account number, sort code and IBAN;
• Details of your debit cards and credit cards (or other debit or credit cards you have registered with us), including the card number, expiry date and CVC (the last three digits of the number on the back of the card);
• Identification documents (for example, your passport or driving licence), copies of any documents you have provided for identification purposes, and any other information you provide to prove you are eligible to use our services;
• Ownership documents (to verify certain assets you own);
• Information about your assets (for example, real estate, vehicles, investments);
• Information about financial expenses;
• Information you provide when you apply for credit, including details about your income and financial obligations;
• Information about your future financial goals;
• Insurances information;
• Information about your interactions with services you used or applied to use on DIGI;
• Records of our discussions, if you contact us or we contact you (including records of phone calls);
• Your image in photo or video form (where required as part of our Know-Your-Client (KYC) checks or where you upload a photo to your DIGI account).

If you give us personal data about other people (such as your spouse or family), or you ask us to share their personal data with third parties, you confirm that you have brought this policy to their attention beforehand.

Information from your device

Whenever you use our website or the DIGI app, we collect the following information:

• Technical information, including the internet protocol (IP) address used to connect your computer to the internet, your log-in information, the browser type and version, the time-zone setting, the operating system and platform, the type of device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use.
• Information about your visit, including the links you have clicked on, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling and clicks), and methods used to browse away from the page.
• Information on transactions (for example, payments into and out of your account), including the date, time, amount, currencies, exchange rate, beneficiary details, details of the merchant or ATMs associated with the transaction (including merchants’ and ATMs’ locations), IP address of sender and receiver, sender’s and receiver’s name and registration information, messages sent or received with the payment, details of device used to arrange the payment and the payment method used.
• Information stored on your device, including if you give us access to contact information from your contacts list. The DIGI app will regularly collect this information in order to stay up to date (but only if you have given us permission).

Information about your location

If you have location services in the DIGI app switched on, we track your location using GPS technology.

Information from others

We collect personal data from third parties, such as credit-reference agencies, financial or credit institutions, official registers and databases, as well as fraud-prevention agencies and partners who help us to provide our services.

This includes your credit record, information about late payments, information to help us check your identity, information about your spouse and family (if applicable in the context of an application for credit that you make) and information relating to your transactions.

When you ask us to, we will also collect personal data from accounts you hold with third party banks (and some accounts with third party providers that aren’t banks) so that you can see everything in one place in your DIGI app. You can create a linked account by activating Open Banking in the app.

Information from social media

Occasionally, we will use publicly available information about you from selected social media websites or apps to carry out enhanced due diligence checks. Publicly available information from social media websites or apps may also be provided to us when we conduct general searches on you (for example, to comply with our anti-money laundering or sanctions screening obligations).

Information from publicly available sources

We might collect information and contact details from publicly available sources, such as media stories, online registers or directories, and websites for enhanced due diligence checks, security searches, and KYC purposes for DIGI Busines-to-Business partners.

DIGI BUSINESS PARTNERS

If you apply to become a DIGI Partner, we will need to confirm your identity as part of our KYC process. We will ask you to provide documents, and will also collect information from third parties, such as commercial registers, for this purpose. We might also periodically check for any changes in public registers for our regulated partners about their ongoing licenses.

4. What is your legal basis for using my personal data?

We must have a legal basis (a valid legal reason) for using your personal data. Our legal basis will be one of the following.ddghjgfdsasdafgb

Keeping to our contracts and agreements with you

We need certain personal data to provide our services and cannot provide them without this personal data.

Legal obligations

In some cases, we have a legal responsibility to collect and store your personal data (for example, under anti-money laundering laws we must hold certain information about our customers).

Legitimate interests

We sometimes collect and use your personal data, or share it with other organisations, because we have a legitimate reason to use it and this is reasonable when balanced against your right to privacy.

Consent

Where you’ve agreed to us collecting your personal data, for example when you have ticked a box to indicate you are happy for us to use your personal data in a certain way.

We have explained more about how we use your personal data in theHow do you use my personal data? section below.

Substantial public interest

Where we process your sensitive personal data (sometimes known as special category personal data) to adhere to government regulations or guidance, such as our obligation to support you if you are or become a vulnerable customer.

5. How do you use my personal data?

We use your personal data so we can provide the best service, tell you about products and services you may be interested in, and meet our legal obligations.

PROVIDING OUR SERVICES

Whenever you apply for a product or service, we will use your personal data to check your identity (as part of our KYC process) and decide whether or not to approve your application.

If you are already a DIGI customer, we use your personal data to meet our obligations relating to any services you inquire from us (for example, when you schedule an appointment with a financial consultant through DIGI, we send them your complete current financial situation for analysis and best advice).

Where you apply through DIGI for any product or service of our partners or the partners of our partners, we use your personal data to provide the most current information for your situation, so you can receive the quickest and most accurate results with the least effort.

We use your personal data to give you details of our products and services and to help us develop new products and services.

We use your personal data to contact you by phone and provide you with information about our products or services, as well as customer support services. We may monitor or record any communications between you and us, including phone calls, to maintain appropriate records, check your instructions, analyze, assess and improve our services, and for training and quality control purposes.

HERE’S AN EXAMPLE OF HOW WE USE YOUR PERSONAL DATA TO PROVIDE OUR SERVICES

If you schedule a financial consultation through us, and then decide to apply for a credit product, we, our consultation partner or our conluntant’s lending partner (the provider of the credit product) will carry out a credit check to better understand your financial circumstances and repayment history.

Our legal basis is one or more of the following:

• keeping to contracts and agreements between you and us;
• legitimate interests (we need to be efficient about how we meet our obligations and we want to provide you with good products and services); or
• legal obligations.

PROTECTING AGAINST FRAUD

We use your personal data to check your identity to protect against fraud, keep to financial-crime laws and to confirm that you are eligible to use our services. We also use it to help us better understand your financial circumstances and manage fraud risks related to your DIGI account.

Our legal basis is one or more of the following:

• keeping to contracts and agreements between you and us;
• legitimate interests (to develop and improve how we deal with financial crime and meet our legal responsibilities); or
• legal obligations.

MARKETING AND PROVIDING NEW PRODUCTS AND SERVICES THAT MIGHT INTEREST YOU

We use your personal data to do the following:

• provide you with information about other products and services we or our partners offer that are similar to those you have already used (or asked about, where allowed by law).
• provide you with information about our or our partner’s products or services which we think you might be interested in. To help us do this, we may use information about you to help us better understand your interests. You can opt out of this by using the privacy settings in the DIGI app or by emailing our Data Protection Officer at dpo@thedigi.app.
• if you agree, provide you with information about our partners’ promotions or offers which we think you might be interested in.
• if you agree, allow our partners and other organizations to provide you with information about their products or services.
• measure or understand the effectiveness of our marketing and advertising, and provide relevant advertising to you.
• ask your opinion about our products or services.
• process applications for products and services available through us, and make decisions about whether to approve applications.

Remember, you can ask us to stop sending you marketing information by adjusting your marketing choices (the How do you use my information for marketing? section below explains how to do this).

Our legal basis is one or more of the following:

• legitimate interests (to develop our products and services, define types of customers for new products or services, and to be efficient about how we meet our legal and contractual duties); or
• consent (for you to receive marketing from other organizations).

TO KEEP OUR SERVICES UP AND RUNNING

We use your personal data to manage our website and the DIGI app, (including troubleshooting, data analysis, testing, research, statistical and survey purposes), and to make sure that content from our website is presented in the most effective way for you and your device.

We also use your personal data to allow you to take part in interactive features of our services, to tell you about changes to our services, and to help keep our website and the DIGI app safe and secure.

HERE’S AN EXAMPLE OF HOW WE USE YOUR PERSONAL DATA TO RUN OUR SERVICES

If any changes we make to our services affect you, we’ll normally contact you using the email address you gave us when you signed up, or through the DIGI app, to tell you about the changes.

Our legal basis is one or more of the following:

• keeping to contracts and agreements between you and us;
• legitimate interests (to be efficient about how we meet our obligations and keep to regulations that apply to us); or
• consent (where required by law).

HELPING WITH SOCIAL INTERACTIONS

We use your personal data to help social interactions through our services or to add extra functions in order to provide a better experience.

HERE’S AN EXAMPLE OF HOW WE USE YOUR PERSONAL DATA FOR SOCIAL INTERACTIONS

We might let you know if any DIGI customers have accepted your invitation request.

If you give us permission, we’ll use the contacts list on your phone, so you can easily make referrals to your contacts using the DIGI app.

Our legal basis is one or more of the following:

• legitimate interests (to develop our products and services and to be efficient in meeting our obligations); or
• consent (to access information held on your phone (for example, contacts in your contacts list), to track you when you have location services switched on).

PROVIDING LOCATION-BASED SERVICES

We use your personal data to provide relevant advertising to you (for example, information on nearby merchants), to protect against fraud, and to let you know when any of your contacts who are DIGI customers are in the same area as you (if they have location services switched on).

HERE’S AN EXAMPLE OF HOW WE USE YOUR LOCATION INFORMATION

If you want to book an appointment with a partner, DIGI can give you information on nearby locations.

Our legal basis is one or more of the following:

• keeping to contracts and agreements between you and us;
• legitimate interests (to develop and market our obligations and keep to regulations that apply to us); or
• consent (to track you when you have location services switched on).

PREPARING ANONYMIZED STATISTICAL DATASET

We may prepare anonymized statistical datasets about our customers’ spending patterns for forecasting purposes or to help governments in policy-making. These datasets may be shared internally or externally with others, including non-DIGI companies. We produce these reports using information about you and other customers. The information used and shared in this way is never personal data and you will never be identifiable from it. Anonymized statistical data cannot be linked back to you as an individual.

Our legal basis is:

• legitimate interests (to conduct research and analysis, including to produce statistical research and reports); or
• legal obligations.

MEETING OUR LEGAL OBLIGATIONS, ENFORCING OUR RIGHTS AND OTHER LEGAL USES

We may need to share personal data about you:

• with other organizations (for example, fraud-prevention agencies);
• if this is necessary to meet our legal obligations or in connection with legal claims; or
• to help detect or prevent crime.

You can find out more in the Do you share my personal data with anyone else? section below.

Our legal basis is one or more of the following:

• legitimate interests (to keep to laws and regulations that apply to us);
• substantial public interest (if we process your sensitive personal data to keep to legal requirements that apply to us); or
• legal obligations.

6. Do you make automated decisions about me?

Depending on the DIGI products or services you use, we may make automated decisions about you.

This means that we may use technology that can evaluate your personal circumstances and other factors to predict risks or outcomes. We do this for the efficient running of our services and to ensure decisions are fair, consistent and based on the right information.

Where we make an automated decision about you you have the right to ask that it is manually reviewed by a person. You can find out more about this in the What are my rights? section below.

For example, we may make automated decisions about you that relate to:

• Approving credit applications: by credit and affordability checks to see whether we can accept your credit application; or setting credit limits.
• Opening accounts: by anti-money laundering and sanctions checks; and identity and address checks.
• Detecting fraud: by monitoring your account to detect fraud and financial crime.

Our legal basis is one or more of the following:

• keeping to contracts and agreements between you and us; or
• legal obligations.

7. Do you carry out credit checks about me?

We and our lending partners will use credit-reference agencies (or other providers of credit information in relevant countries) to carry out credit checks on you if you apply (or tell us you want to apply) for a credit product through DIGI.

We will also share your personal data with credit-reference agencies (or other providers of credit information) to:

• confirm details you have provided when you apply for products or services;
• make an assessment about whether to accept your credit application; or
• determine an appropriate credit limit for you.

When you enter into a credit agreement with us or our partners, we may continue sharing information with credit reference agencies or other providers of credit information (for example, information about your repayments and whether you repay in full or on time).

The personal data we share with and receive from credit reference agencies (or other providers of credit information) when you apply for, or use, a DIGI or DIGI partners’ credit product will vary depending on the country you live in. We will provide full details when you apply for a DIGI or DIGI partner’s credit product.

8. How do you use my information for marketing?

If you sign up to our services, and where allowed by law, we will assume you want us to contact you by post, email and SMS text message with information about DIGI products, services, offers and promotions. We may use the personal data we have collected about you in order to tailor our offers to you.

You can adjust your preferences, or tell us you don’t want to hear from us, at any time. Just use the privacy settings in the DIGI app or click on the unsubscribe links on any marketing message we send you.

We won’t pass your details on to any organizations outside the Digital Global group of companies for their marketing purposes without your permission. You can find out more in the section Do you share my personal data with anyone else?

Your Rights

9. What are my rights?

You have the right to be told about how we use your personal data.

We provide this privacy policy to explain how we use your personal data.

If you ask, we will provide a copy of the personal data we hold about you. We can’t give you any personal data about other people, personal data which is linked to an ongoing criminal or fraud investigation, or personal data which is linked to settlement negotiations with you. We also won’t provide you with any communication we’ve had with our legal advisors.

You can ask us to correct your personal data if you think it’s wrong.

You can have incomplete or inaccurate personal data corrected. Before we update your file, we may need to check the accuracy of the new personal data you have provided.

You can ask us to delete your personal data if:

• there’s no good reason for us to continue using it;
• you gave us consent (permission) to use your personal data and you have now withdrawn that consent;
• you have objected to us using your personal data;
• we have used your personal data unlawfully; or
• the law requires us to delete your personal data.

Just to let you know, we may not be able to agree to your request. As a services provider, we must keep certain customer personal data even where you ask us to delete it (we’ve explained this in more detail below). If you’ve closed your DIGI account, we may not be able to delete your entire file because these regulatory responsibilities take priority. We will always let you know if we can’t delete your information.

You can object to us processing your personal data for marketing purposes.

You can object to us processing other personal data (if we are using it for legitimate interests).

If our legal basis for using your personal data is ‘legitimate interests’ and you disagree with us using it, you can object.

However, if there is an overriding reason why we need to use your personal data, we will not accept your request.

If you object to us using personal data which we need in order to provide our services, we may need to close your account as we won’t be able to provide the services.

You can ask us to restrict how we use your personal data. You can ask us to suspend using your personal data if:

• you want us to investigate whether it is accurate;
• our use of your personal data is unlawful but you do not want us to delete it;
• we no longer need the information, but you want us to continue holding it for you in connection with a legal claim; or
• you have objected to us using your personal data (see above), but we need to check whether we have an overriding reason to use it.

You can ask us to transfer personal data to you or another company.

If we can, and are allowed to do so under regulatory requirements, we will provide your personal data in a structured, commonly used, machine-readable format.

You can withdraw your permission.

If you have given us any consent we need to use your personal data, you can withdraw your consent at any time by changing your privacy settings in the DIGI app or sending an email to dpo@thedigi.app.

(Note, it will have been lawful for us to use the personal data up to the point you withdraw your permission).

You can ask us to carry out a human review of an automated decision we make about you.

Your ability to exercise these rights will depend on a number of factors. Sometimes, we will not be able to agree to your request (for example, if we have a legitimate reason for not doing so or the right does not apply to the particular information we hold about you).

10. How do I exercise my rights?

To exercise any of your rights set out in the previous section, you can contact us by sending an email at dpo@thedigi.app.

For security reasons, we can’t deal with your request if we are not sure of your identity, so we may ask you for proof of your ID.

DIGI will usually not charge you a fee when you exercise your rights. However, we are allowed by law to charge a reasonable fee or refuse to act on your request if it is manifestly unfounded or excessive.

If you are unhappy with how we have handled your personal data you can complain to your local data protection authority. In the EU, there are national and regional data protection authorities.

11. Do you share my personal data with anyone else?

DIGITAL GLOBAL GROUP COMPANIES

We share your personal data within the Digital Global group of companies in order to provide you with the best service.

OTHER DIGI CUSTOMERS

We will ask you to let us sync your mobile phone contacts. This will help you to identify which of your mobile phone contacts are not DIGI customers already, so you can invite them to join.

Once referrals join on your referral, you will only be able to see the information about them you put. Both you and your referral must have synced your mobile phone contacts lists with DIGI to be viewable to each other in the DIGI app with the data you have added yourselves.

We might use technological safeguards to ensure a referral is somebody you already know and who knows you (for example, you have each other saved in each other’s mobile phone contacts lists), before we award any referral points.

We only show your basic contact details in the DIGI app to your trusted contacts who are also DIGI customers (for example, your name (as saved in your friend’s contacts list), mobile phone number, DIGI username, your DIGI profile photo (if you have one)).

You can, of course, choose not to sync your contacts list with DIGI. This means that you will not be able to identify which of your mobile phone contacts are not DIGI customers, apart from what you have written for them in the pending referral request.

SUPPLIERS

Suppliers that we share your personal data with:

• Suppliers who provide us with IT, payment and delivery services: to help us provide our services to you.
• Our banking and financial-services partners and payments networks: to help us provide our services to you. This includes banking and lending partners, banking intermediaries and financial consultant intermediaries.
• Analytics providers and search information providers: to help us improve our website or app.
• Customer-service providers, survey providers and developers: to help us to provide our services to you.
• Communications services providers: to help us send you emails, push notifications and text messages.
• Debt collection agencies: to manage and recover debts that you owe or may become owing.

PARTNERS WHO HELP TO PROVIDE OUR SERVICES

We may share your personal data with our partners in order to provide you with certain services you have asked us for (for example, when you want to book an appointment with a financial consultant).

HERE’S AN EXAMPLE OF WHEN WE MIGHT SHARE YOUR PERSONAL DATA WITH OUR PARTNERS

If you have asked for insurance services, we will share your relevant personal data directly or to our partner, who will connect with the provider of insurance services. The service provider will require your personal data to provide you with insurance.

We will only share your personal data in this way if you have asked for the relevant service or it is provided as part of one of our plans.

From time to time we may work with other partners to offer you co-branded services or promotional offers, and we will share some of your personal data with those partners. We will always make sure you understand how we and our partners process your personal data for these purposes.

Our partners will have their own privacy policies explaining how they use your personal data. It’s important that you read those privacy policies as well.

CREDIT-REFERENCE AGENCIES

As set out in the Do you carry out credit checks about me? section, if you apply for a credit product through us, we’ share your personal data with our partners or credit-reference agencies to check whether you are likely to make repayments when due.

OTHER FINANCIAL INSTITUTIONS

We may share your personal data with other financial institutions if requested.

HERE’S AN EXAMPLE OF WHEN WE MIGHT SHARE YOUR PERSONAL DATA WITH OTHER FINANCIAL INSTITUTIONS

If you have applied for a mortgage after a consultation booked through our partner, we might share the relevant information needed from your account to assist the partner in getting more accurate rates for your situation.

We may also share your personal data with other financial institutions where you do not ask us to.

FOR LEGAL REASONS

We also share your personal data with fraud-prevention agencies to check your identity, protect against fraud, keep to anti-money laundering laws and confirm that you are eligible to use our products and services.dghjgfdsasdafgb

HERE’S AN EXAMPLE OF WHEN WE MIGHT SHARE YOUR PERSONAL DATA FOR LEGAL REASONS

If you give us false or inaccurate personal data and we identify fraud, we will let fraud-prevention agencies know. Law-enforcement agencies may check and use this personal data.

If fraud is detected, you could be refused certain services, finance or employment. You can contact us through email at dpo@thedigi.app to ask us for details of the fraud-prevention agencies we may share your personal data with.

We may also need to share your personal data with other third party organisations:

• if we have to do so under any law or regulation;
• if we sell our business;
• in connection with criminal or fraud investigations;
• to enforce our rights (and those of customers or others); or
• in connection with legal claims.

SOCIAL MEDIA AND ADVERTISING COMPANIES

HERE’S AN EXAMPLE OF WHEN WE MIGHT SHARE YOUR PERSONAL DATA FOR ADVERTISING PURPOSES

We may share your personal data (your name, email address and app events) with our advertising partners in the ways described below, but the personal data is hashed before we send it, and the social-media platform we share it with is only allowed to use that hashed personal data in the ways described below.

When we use social media for marketing purposes, your personal data may be shared with the social-media platforms so that they can check if you also hold an account with them. If you do, we may ask the advertising partner or social-media provider to:

• use your personal data to send our adverts to you, because we think that you might be interested in a new DIGI product or service;
• not send you our adverts, because the marketing relates to a service that you already use; or
• send our adverts to people who have a similar profile to you (for example, if one of our services is particularly useful to people with similar interests to the ones on your social-media profile, we may ask our advertising partner or social-media partner to send our adverts for that service to those people).

An example of how we may use social media for marketing purposes is through Facebook’s ‘Custom Audience’ tool, the terms of which are available here..

Our legal basis is:

• legitimate interests.

You can contact us at any time by emailing dpo@thedigi.app, if you do not want us to share your personal data for advertising purposes or use the privacy settings in the DIGI app to opt out from having your personal data shared in this way.

Remember you can also manage your marketing preferences directly with any social media provider that you have an account with.

WHERE YOU ASK US TO SHARE YOUR PERSONAL DATA

Where you direct us to share your personal data with a third party, we may do so. For example, you may authorize third parties to act on your behalf (such as a consultant, lawyer, accountant or family member or guardian under a power of attorney).

DIGI and Your Personal Data

12. Will my information go outside of Europe?

As we provide an international service, we may need to transfer your personal data outside the European Economic Area (EEA) in order for us to provide our services.

For example, if you want to add a bank account you own outside the EEA, we might need to communicate with our partners to link it properly. We might also send your personal data outside of the EEA to keep to global legal and regulatory requirements, and to provide ongoing support services.

We may share your personal data with credit-reference agencies and fraud-prevention agencies that are based outside of the EEA.

We will take all reasonable steps to make sure that your personal data is handled securely and in line with this privacy policy and data protection laws.

If you would like more information, please contact us by sending an email to dpo@thedigi.app.

13. How do you protect my personal data?

We recognise the importance of protecting and managing your personal data. Any personal data we process will be treated with the utmost care and security. This section sets out some of the security measures we have in place.

We use a variety of physical and technical measures to keep your personal data safe and prevent unauthorised access to, or use or disclosure of it. Electronic data and databases are stored on secure computer systems with control over access to information using both physical and electronic means. Our staff receives data protection and information security education. We have security and data protection guidelines which staff are required to follow when they handle your personal data.

While we take all reasonable steps to ensure that your personal data will be kept secure from unauthorised access, we cannot guarantee it will be secure during transmission by you to our app, a website or other services. We use HTTPS (HTTP Secure) for all our app, web and payment-processing services.

If you use a password for the DIGI app or our website, you will need to keep this password confidential. Please do not share it with anyone.

When you use our services, which includes our social network accounts and the DIGI forum, do not share any personal data that you don’t want to be seen, collected or used by other customers, as this personal data will become publicly available.

14. How long will you keep my personal data for?

We will generally keep your personal data for six years after our business relationship with you ends or such period as may be required by applicable local laws.

We are required to keep your personal data for this long by anti-money laundering laws. We may keep your personal data for longer because of a potential or ongoing court claim or another legal reason.

15. How will you keep me updated on how you use my personal data?

If we change the way we use your personal data, we will update this policy and, if appropriate, let you know by email, through the DIGI app or through our website.

16. Do you use cookies on your websites?

We use cookies to analyse how you use our website.