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 at privacy@thirdlyapp.com, 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 to 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 liegitimate interests', or for research or statistical reasons
- withdraw any consent you;ve given us at any time but this does not make your 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
- 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
- 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 tyour account, and your investments
- details about how you use our app
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 , 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 those platforms, and the contents of your messages or posts to us
- details of why you are contacting us
- details of any support needs or communication preferences you disclose to us
- details of the device 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
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.
