Privacy policy

Hooha is the marketplace app for face-to-face payments, replacing cash.

Keeping your data secure is important to us. We’re going to talk you through how we process your personal data, how we might share it to provide you with Hooha services, how we protect your personal data and what your rights are.

From time to time we may need to update this policy. If the change is material, we will let you know in this app.
If you have any queries about this Privacy Policy or other aspects of data protection please e-mail [email protected]

Looking after your data

“Personal data” is any personal information which relates to a living individual who can be identified from that data. You agree that the personal data which you supply to us will be true, complete and accurate in all respects, and you agree to notify us immediately of any changes to that Data.

“Sensitive Data” is information which relates to an individual’s racial or ethnic origin, sexuality, health status, political beliefs, union membership or criminal background. We will not ask you for any sensitive data. Occasionally we may come in to possession of sensitive data which is acquired from searches of open source information and databases.

We will deal with your personal data in compliance with the applicable Data Protection regulations. Please note this applies only to Hooha Innovations Ltd and subsidiary companies, not to other companies or organisations’ websites to which may link. Hooha Innovations is not responsible for the content or the privacy practices of other companies.

How we use your personal data

We will collect and process personal data for the purposes of providing Instant Escrow payment services to you and the other purposes mentioned below. Personal data may also be processed by other organisations on our behalf for the purpose of providing Hooha services to you. The use of information will remain under the control of Hooha Innovations Ltd at all times. We work hard to ensure that we only partner with organisations that apply the same high standards to data protection as we do. It may be necessary for your Personal Information to be processed outside the European Union.

Once you are a registered customer, we will hold personal information relating to the transactions you enter into with us. We may disclose personal information to a party to the transaction, but only to assist your transaction and subject to your approval.
We use your personal data to monitor the transactions of our customers for a number of reasons including crime prevention and market research as well as to understand how we can improve our products and services and to ensure that we properly segregate our client’s funds from our own money.

When you call us we may monitor or record your calls to confirm your instructions or for training and regulatory purposes. To view or correct your personal data, you can write to us at Data Protection Officer, Hooha Innovations Ltd, Portland House, Bressenden Place, London SW1E 5BH.
A fee may be payable, in certain circumstances, for viewing personal information and we will respond within one month.

Sharing personal data

For us to provide you with any of our services it may be necessary for us to disclose your personal data to third parties with which we work. We will always do so in in good faith and for the following purposes, for example:

• To service providers for the purpose of opening, operating and servicing your account.
• To enable you to be advised about changes or amendments to our service or for marketing purposes.
• To conform with a legal requirement or a request from authorities with which we will fully cooperate.
• To protect and defend our rights or property.
• To enforce our Terms and Conditions, or to act to protect the interests of our registered customers or others.
• In the event of the sale or acquisition of Hooha Innovations Ltd by another entity.

We explicitly do not allow the third parties we work with to use or share your data for any purposes other than what has already been agreed and stated above.

Storing, securing and retaining personal data

We take the security of your personal data very seriously. We operate a strict information security policy that is updated periodically to maintain best practice. In addition to this the following approaches are also applied:

• We work to protect against accidental loss or unauthorised access to your personal data.
• Regular external penetration tests are undertaken to ensure that our external defences remain robust and up to date.
• Only authorized staff that need access to personal data to perform their roles are able to do so.
• Data is only transferred to business partners using secure mechanisms.
• Staff are trained to apply the highest standards of data security.

Your rights

We will respect all the rights that you have under applicable data protection regulations. Where appropriate to do so, we will correct, amend or delete your personal data.

Specifically, we will honour your following rights:

• The right to access to your personal data.
• This is subject to other relevant legal requirements and the provision of suitable identification. We reserve the right to charge a fee in certain circumstances
• The right to correction or deletion.
• You have a right to correct or amend your personal data if it is incorrect. Please contact us to update your personal data. You also have a right to deletion, subject to other applicable legal requirements.
• The right to be informed about the processing of your personal data.
• This sets out how we will process your data. It will be updated from time to time or at times of regulatory change.

How to contact us

If you require further detail or have any questions about this policy, please contact us using the details below:

E-mail
[email protected]

Post
Data Protection Officer
Hooha Innovations Ltd
Portland House
Bressenden Place
London
SW1E 5BH