Legal Privacy Policy

Privacy Policy

Last updated: 1 June 2024

What Personal Data do we Store & Use?

When you browse our website
When you browse our website we only collect your IP address for security purposes. You can find more information in the Cookies Policy outlined below.

When you contact us
When you contact us through email or our social media accounts, we store your personal information to provide you with prompt feedback regarding your queries.

When you use our services
We are making our services available to those individuals who sign up for our web-based Dashboard. At Strabo, we are connecting accounts across the globe, starting off with a limited number of countries. You can enroll to use Strabo's services by filling in your email in the signup form on our website. We may collect your first and last name, email address, current country of residence and countries where you have financial accounts. We need this information to make our services available to you, and prioritise the availability of our services to all our users based on their location.

Usage data is collected while using the platform. This may include information such as your device's internet protocol (IP) address, browser type, browser region, the pages of the service you use, the features you interact with, the time, date and length of your visit and other simple diagnostic data.

The Strabo Dashboard does not require, and hence store, login credentials like usernames and passwords. These are managed through trusted third-party authentication from either Google or AWS, as of the date of this policy. To provide our services on the Strabo Dashboard, we use Open Banking implemented by Plaid, , Yodlee & Vezgo, who are trusted third-party Account Information Service Providers (AISP) under the Revised Payment Service Directive.

In the UK, Strabo Financial Ltd provides you with regulated account information services as an agent of Plaid Financial Ltd., an authorised payment institution regulated by the Financial Conduct Authority under the Payment Services Regulations 2017 (Firm Registration Number: 804718) for the provision of payment services, including account information services. You can read more about Strabo's regulatory status directly on the FCA register.

https://ec.europa.eu/info/law/payment-services-psd-2-directive-eu-2015-2366_en

Consent & Use of Personal Data

At Strabo, we may use personal data for the following purposes:

  • To provide and maintain the service

  • To manage your account and registration of the user to the service

  • To contact you by email or push notification regarding updates or informative communications related to functionality, products or contracted services, including security updates, when necessary or reasonable for their implementation

  • To provide you with news, special offers and information about the service

  • To manage your requests to us

  • To send you rewards


We may share some of this information in the following circumstances:

  • With service providers: for connecting your online financial accounts, fetching asset values, processing payments, monitoring usage and in-platform analytics, reporting bugs, customer support, email marketing and promotional campaigns. In cases where any data is shared with third parties, it is anonymised both at point of use and when reviewing.



Storage and Retention of your Data

Strabo will retain your Personal Data for only as long as is required for the purposes set out in this policy. We will only use this data for the extent necessary to comply with our legal obligations, resolve disputes and enforce our legal agreements and policies.Usage data will be retained for internal analysis purposes. This is generally stored for a shorter period of time, except when used to strengthen the security or improve the functionality of our service, or when legally required.

At Strabo, we strive to keep adequate measures in place, be that physical, technical or operational to protect your data from unauthorised access, use and disclosure. We have deployed our technology using secure cloud computing services from Amazon Web Services & Google. We have strict guidelines for Strabo personnel with access to your data complying with GDPR best practices.

Our internal Data Access Policy ensures that any user information collected is made accessible only to one senior member of the technical team in accordance with the policy. Ad-hoc requests are made and reviewed on a case-by-case basis, and access is only granted in circumstances where the data is siloed for the purposes of bug-fixing.

Personal Data Retention

This data is retained on the system on the basis that if a user fails to log in to the platform for a period of 180 days, a series of 3 emails will be sent to the user. These will contain a link to allow the user to access the platform, and an option to opt out. The user is not required to log into their Strabo account.

Clicking on the link and visiting the page will reset an inactive timer. In the event that all 3 of these emails are unanswered, the user will no longer receive communication until 12 months after which period they will receive one final reminder. 30 days after this, all data will be deleted from the Strabo system in its entirety, including backups.

Who Do We Share Your Data With?

Your information, including personal data, is processed at the company's operating offices or in other places where the processing parties are located. This means that information may be transferred to, and maintained on computers outside of our own, but only where strictly necessary. In these instances, the company will take all reasonable steps to ensure that your data is treated securely and in accordance with this policy. No transfer of your personal data will take place to any organisation unless there are adequate controls in place, including but not limited to data security.

Data will not be transferred outside the European Economic Area (EEA).To help us provide our services, we share encrypted data in as small a quantity as possible with third-parties so you get the best experience from Strabo. This may include our Open Banking Partner, Cloud computing companies, software companies for email marketing, marketing automation, customer service and business analytics. We will always ensure all the right checks and balances are in place before your data is shared with any third party.

Your Rights

At Strabo, you always come first. You can, at any time, ask us to provide any data we have stored about you via email at hello@strabo.app. You can reach out to us to correct any inaccurate data we hold about you. You also always have the right to withdraw consent you have given us. Please let us know if you have any complaints regarding Strabo & your personal data, and we will make our best efforts to rectify it. Should you not feel satisfied, you have the right to file an official complaint with the ICO.
http://www.ico.org.uk./

Your specific rights include (but are not limited to):

  • The right to restrict the processing of your personal data

  • The right to complete erasure of your personal data

  • The right to object to processing of this data

  • The right to object to direct marketing

  • The right to object to data portability (as applicable)


To exercise any of these rights, please get in touch with our team at hello@strabo.app

Cookies Policy

We use Cookies and similar tracking technologies on our website and platform to collect data about how you interact with us and enhance your experience. Tracking technology includes tags and simple scripts to collect information to improve and analyse our service. You can find out all information about Cookies on the following website:

www.allaboutcookies.org

We rely on Google Analytics for the provision and use of cookies, and all the information regarding these cookies can be found here:

https://developers.google.com/analytics/devguides/collection/ga4

You can block the use of cookies by adjusting the settings on your browser or by instructing your browser to refuse all cookies on loading of the website.

We rely on Mixpanel for the provision of in-platform analytics, including feature engagement, page and session duration, and email engagement. You can read more about their policy here:

https://docs.mixpanel.com/docs/privacy/protecting-user-data

We rely on Livesession for the provision of live user behaviour data in order to improve the Platform. Where possible, all user data is obscured and anonymised. You can read more about their policy here:

https://livesession.io/privacy-policy/#:~:text=We%20always%20provide%20at%20least,personal%20data%20to%20its%20affiliates.



Changes to this Policy

We may make changes to this policy from time to time to align with any changes to the service or legal requirements, and all such changes will be posted here. The date of this policy states the time of the last amendment to the policy.

Users are given a link to this policy on Signup, and should be aware that changes are made periodically. If any terms included herewith are deemed unsatisfactory to the user, signup should not be completed. Please direct any questions on the above policy, or the Platform more broadly, to hello@strabo.app