1. The basics about what you need to know

   About us

   We are Atmen Ltd. Our registered office is Level 3 207 Regent Street, London, England, W1B 3HH. Our company number is 12736447.

   We are registered with the Information Commissioner's Office (ICO), the data-protection regulator in the UK, to use personal information.

   We are committed to protecting and respecting your privacy.

   We will:

   • always keep your information safe and private;
   • never sell your information; and
   • allow you to manage and review your marketing choices at any time.
      
2. Why do I need to read this notice?
   
   We will collect your personal information when you use:
    
   • our website at www.myatmen.com;
   • the My Atmen app; or
   • any of the services you can get access to through the My Atmen app or website (our services).
   
   Under data-protection law, we are what is known as the 'data controller' of your personal information.
   
   This policy contains important information
   
   This document explains what information we collect, how we use it, and your rights if you want to change how we use your personal information.
   
   If you have concerns about how we use your personal information, you can contact our data protection officer myatmen@myatmen.com
    
3. What information do you collect about me?
   
   We collect different types of information from you and others
   
   The table below explains what personal information we collect and use.
    

   Type of information	Details
   Information you give us	We collect information you provide when you:
   	✓ fill in any forms;
   	✓ correspond with us;
   	✓ register to use the My Atmen 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 My Atmen 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 username, password and other registration information.
   	✓ Details of your bank account, including the account number, sort code and IBAN.
   	✓ Details of your debit cards and credit cards, 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 number), copies of any documents you have provided for identification purposes, a personal description (if you provide one), and any other information you provide to
   Type of information	Details
   	prove you are eligible to use our services.
   	✓ Records of our discussions, if you contact us or we contact you.
   	✓ Your photo (only if you upload one).
   Information from your device	Whenever you use our website or the My Atmen 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 and so on.
   	✓ 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, 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 address book, log-in information, photos, videos or other digital content, check-ins (sometimes, we call this content information). The My Atmen app will regularly collect this information in order to stay up to
   Type of information	Details
   	date.
   Information about your location	If you have location services in the My Atmen app switched on, we track your location using GPS technology and your IP address.
   Information from others	We collect information from third parties, such as credit- reference agencies, fraud-prevention agencies and partners who help us to provide our services.
   	This includes your credit record, information to help us check your identity, and information relating to your transactions.
   Information from social media	If you allow us to, we will collect information such as friends lists from Facebook or similar information from other online accounts. If you've asked us to, we'll use your Facebook profile to confirm your identity as part of our know-your-client (KYC) process (the process of how we check who you are).

   
   BUSINESS CUSTOMERS
   
   If you are a business user, 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 may also collect any of the above information relating to your use of the Atmen Dashboard, the My Atmen app and our website.
    
4. What is your legal basis for using my information?
   
   We must have a legal basis (a valid legal reason) for using your personal information. Our legal basis will be one of the following.
    
   • Keeping to our contracts and agreements with you
     
     We need certain personal information to provide our services and cannot provide them without this information.
      
   • Legal obligations
     
     In some cases, we have a legal responsibility to collect and store your personal information (for example, under money-laundering laws we must hold certain information about our customers).
      
   • Legitimate interests
     
     We sometimes collect and use your personal information, or share it with other organisations, because we or they have a legitimate reason to have it and this is reasonable when balanced against your right to privacy.
      
   • Consent
     
     Where you've agreed to us collecting your information, for example by using the My Atmen app or when you have ticked a box to indicate you are happy for us to use your personal information in a certain way.
     
     We have explained more about how we use your personal information in the How do you use my information? section below.
      
5. How do you use my information?
   
   We collect your information 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 information to check your identity (as part of our KYC process) and decide whether or not to approve your application.
     
     If you are already a Atmen customer, we use your personal information to meet our obligations relating to any transactions you make (for example, making payments into and out of your Atmen account, withdrawing cash or making payments with your Atmen Card). If you ask us to exchange the currency of the e-money you hold in your Atmen account, we'll use your personal information to help us do that.
     
     We also use your personal information to give you details of our products and services and to help us develop new products and services.
     
     We also use your personal information to contact you by phone and provide you with customer support services. We may record these calls, but only for internal training and quality-control purposes.
     
     The types of information we use are:
      
     • information you have given us; and
     • information from third parties (as explained in the What information do you collect about me? section above).
    

   HERE'S AN EXAMPLE OF HOW WE USE YOUR PERSONAL INFORMATION TO PROVIDE OUR SERVICES
   
   If you apply for a credit product, we or our 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 would be 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)
   • Legal obligations
   • Protecting against fraud
    

   We use your personal information 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 Atmen account.
   
   The types of information we use are:

   • information you have provided;
   • information from your device;
   • location information; and
   • information from third parties.
   
   HERE'S AN EXAMPLE OF HOW WE USE YOUR PERSONAL INFORMATION TO PROTECT AGAINST FRAUD
   
   If you have switched on location services in the My Atmen app and your mobile phone tells us that you're in the UK, but your Atmen Card is being used in Spain, we may not process that transaction.
   
   Our legal basis would be 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)
   • Legal obligations
   • Marketing and providing new products and services that might interest you
    

   We use your personal information to do the follow

   • Provide you with information about other goods and services we offer that are similar to those you have already used or asked about.
   • Provide you with information about our goods or services, and our partner's promotions or offers, 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 help service through the My Atmen app or by emailing our Data Protection Officer at the address given above.
   • If you agree, allow our partners and other organisations to provide you with information about their goods or services.
   • Measure or understand the effectiveness of our advertising, and provide relevant advertising to you.
   • 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 Do you use my information for marketing? section below explains how to do this).

   The types of information we use are:

   • information you have provided;
   • information from your device;
   • location information; and
   • information from third parties.
    

   HERE'S AN EXAMPLE OF HOW WE USE YOUR PERSONAL INFORMATION FOR MARKETING
   
   If you are a Atmen customer, we may contact you about optional extras or promotional offers. We may use information we gather about you through your use of our services to tailor these offers to you.
   
   Our legal basis would be one or both 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)
   • Consent (for you to receive marketing from other organisations)
   • To keep our services up and running
    

   We use your personal information to manage our website and the My Atmen 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. For more information, please see our Cookies Policy.
   
   We also use your personal information 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 My Atmen app safe and secure.
   
   The types of information we use are:

   • information you have provided; and
   • information from your device.
    

   HERE'S AN EXAMPLE OF HOW WE USE YOUR PERSONAL INFORMATION 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 My Atmen app, to tell you about the changes.
   
   The legal basis would be one or both 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)
   • Helping with social interactions
    

   We use your personal information to help social interactions through our services or to add extra functions in order to provide a better experience.
   
   The types of information we use are:

   • information you have provided;
   • information from your device; and
   • location information.
    

   HERE'S AN EXAMPLE OF HOW WE USE YOUR PERSONAL INFORMATION FOR SOCIAL INTERACTIONS
   
   We'll let you know if any of your contacts who are Atmen customers have used our products, upgrades or features or are in the same area as you (if they have location services switched on).
   
   If you have the relevant settings in the My Atmen app switched on, we'll use the contact list on your phone, or your photo gallery, so you can easily make payments to your contacts and send photos using the My Atmen app.
   
   The legal basis would be one or both of the following.

   • Legitimate interests (to develop our products and services and to be efficient in meeting our obligations)
   • Consent (to track you when you have location services switched on)
   • Providing location-based services
   
   We use your information 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 Atmen customers are in the same area as you (if they have location services switched on).
   
   The types of information we use are:
    
   • information you have provided; and
   • location information.
    

   HERE'S AN EXAMPLE OF HOW WE USE YOUR LOCATION INFORMATION
   
   If you go abroad, the My Atmen app may automatically tell you the exchange rate in that country.
   
   The legal basis would be 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)
   • Consent (to track you when you have location services switched on)
   • Meeting our legal obligations, enforcing our rights and other legal uses
    

   We may need to share information about you:

   • with other organisations (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 information with anyone else? section below.
   
   The types of information we may share include:

   • information you have provided;
   • information from your device;
   • location information;
   • information from third parties; and
   • social-media information.
    

   Our legal basis would be one or more of the following.

   • Legitimate interests (to keep to laws and regulations that apply to us)
   • Legal obligations
   • Consent (for you to receive marketing from other organisations)
6. Do you carry out credit checks or make any automated decisions about me?
   
   Our lending partners use credit-reference agencies to carry out credit checks on you if you apply for one of their credit products. We will need to carry out credit checks if you apply for any of our credit products, but we will let you know before we do this.
   
   We may also check your credit history to help us develop and offer credit products that are tailored to you. Credit-reference agencies will not store any of your information that we send them when we use their services for this purpose.
   
   These checks of your credit history (credit insights) mean that when you apply for credit products, or we suggest credit products to you through the My Atmen app, we can better understand your financial circumstances and repayment history, and can tailor our credit products to your needs. These credit insights do not leave any ‘footprint’ (trace) whatsoever on your credit record held by the credit-reference agency. If you do not want us to carry out credit insights, please contact us through the My Atmen app or by emailing dpo@Atmen.com.
   
   Some of the searches we make when you apply for a credit product leave a 'soft footprint' on your credit history. This means that the search will be registered on your credit file but will not be visible to others if they search your credit history. A soft footprint will not affect your credit rating. If you apply for credit, we will provide more information about this in the application form.
   
   Some of our third-party providers, such as fraud-prevention agencies, may also use credit- reference agencies to help us check your identity and prevent fraud. These searches also only leave a soft footprint credit history.
   
   We do not accept joint account holders, but credit-reference agencies may sometimes link your credit record with that of anyone else who is financially connected to you.
   
   Due to the international nature of our services, we use credit-reference agencies and fraud- prevention agencies in the UK and overseas.
   
   Sometimes you may have a right to see your personal records held by credit-reference and fraud-prevention agencies. If you would like details of the credit-reference and fraud- prevention agencies we use, please contact us through the My Atmen app or by sending an email myatmen@myatmen.com You can withdraw your permission for credit checks by contacting us through the My Atmen app. The credit-reference agencies have created a joint document to explain how they use and share your information
    
7. How do you use my information for marketing?
   
   If you sign up to our services, we will assume you want us to contact you by post, email and phone (including text message) with offers and promotions. We may use the information 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' section within the 'Profile' section of the My Atmen app or click on the unsubscribe links on any marketing message we send you.
   
   We won't pass your details on to any organisations outside the Atmen group of companies for their marketing purposes without your permission. You can find out more in the Do you share my information with anyone else? section.
   
   Your rights
    
8. What are my rights?
    

   Your right	What it means
   You have the right to be told about how we use your personal information.	We provide this privacy notice to explain how we use your personal information.
   You can ask to see the personal information we hold about you (this is called making a ‘data subject access request’, or DSAR for short).	If you make a DSAR, we will provide a copy of the personal information we hold about you. We can’t give you any information about other people, information which is linked to an ongoing criminal or fraud investigation, or information which is linked to settlement negotiations with you. We also
   Your right	What it means
   You can also ask for information about what information we process and why.	won't provide you with any communication we've had with our legal advisers.
   You can ask us to correct your personal information if you think it's wrong.	You can have incomplete or inaccurate information corrected. Before we update your file, we may need to check the accuracy of the new information you have provided.
   You can ask us to delete your personal information.	You can ask us to delete your personal information if:
   	✓ there's no good reason for us to continue using it;
   	✓ you gave us consent (permission) to use the information and you have now withdrawn that consent;
   	✓ you have objected to us using the information;
   	✓ we have used the information unlawfully; or
   	✓ the law requires us to delete the information.
   	Just to let you know, we may not be able to agree to your request. As a firm authorised by the Financial Conduct Authority, we must keep certain customer information for at least six years (we've explained this in more detail below). If you've closed your Atmen 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 information for marketing purposes.	You can tell us to stop using your personal information for marketing.
   You can object to us processing other information (if we are using it for legitimate interests).	If our legal basis for using your personal information 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 right	What it means
   	the information (for example, legal reasons), we will not accept your request.
   	If you object to us using information 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.
   	For example, if you object to us sending your personal information to our partners such as concierge providers (as part of our Premium and Metal plans), we may no longer be able to provide you with those concierge services.
   You can ask us to restrict how we use your personal information	You can ask us to suspend using your personal information if:
   	✓ you want us to investigate whether it is accurate;
   	✓ our use of the information 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 information (see above), but we need to check whether we have an overriding reason to use it.
   You can ask us to transfer personal information to you.	If we can, and are allowed to do so under regulatory requirements, we will provide your personal information 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 information, you can withdraw your consent at any time by changing your settings in the My Atmen app or sending an email to myatmen@myatmen.com
   	(Note, it will have been lawful for us to use the personal information up to the point you withdrew your permission).

9. How do I exercise my rights?
   
   To exercise any of your rights set out in the previous section, you can contact us through the My Atmen app or send us an email at myatmen@myatmen.com 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.
   
   If you are unhappy with how we have handled your personal information you can complain to the ICO through their website.
    
10. Do you share my information anyone else?
    
    Atmen Suppliers
    
    The table below explains which suppliers we normally share your personal information with.
     

    Type of supplier	Why we share your information
    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, including Visa and Mastercard	To help us provide our services to you this includes banking and lending partners, banking intermediaries and international payment-service providers
    Card manufacturing, personalisation and delivery companies	To create and deliver your personalised Atmen Card
    Advertisers	To promote our services. (We provide anonymous information only for example, ‘500 men under 30 clicked on their advert’.)
    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
    Credit-reference and fraud- prevention agencies	To help us develop and offer credit products to you, and to check your identity and your eligibility for credit products.

    
    Partners who help to provide our services
    
    We may share your personal information with our partners in order to provide you with certain services you have asked us for.
    
    If you are a business customer, we may share your personal information with our partners (through the Atmen for Business API) when you switch this function on through Atmen Connect.
    
    HERE'S AN EXAMPLE OF WHEN WE MIGHT SHARE YOUR INFORMATION WITH OUR PARTNERS
    
    If you have asked for concierge services, we will share relevant information with the provider of the concierge service.
    
    We will only share your personal information in this way if you have asked for the relevant service. You can withdraw your permission at any time by contacting us through the My Atmen app. However, this may affect your ability to continue to use those services.
    
    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 information with those partners. We will always get your consent before sharing your information for these purposes. You can withdraw your consent at any time by contacting us through the My Atmen app.
    
    Our partners will have their own privacy notice explaining how they use your personal information. It's important that you read those privacy notices as well.
    
    Credit-reference agencies
    
    If you apply for a credit product, we'll share your personal information with credit-reference agencies to check whether you are likely to make repayments when due.
    
    For legal reasons
    
    We also share your personal information 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.
    
    HERE'S AN EXAMPLE OF WHEN WE MIGHT SHARE YOUR PERSONAL INFORMATION FOR LEGAL REASONS
    
    If you give us false or inaccurate information and we identify fraud, we will let fraud- prevention agencies know. Law-enforcement agencies may check and use this information.
    
    If fraud is detected, you could be refused certain services, finance or employment. You can contact us through the My Atmen app to ask for more details of how your information will be used by us and these fraud-prevention agencies.
    
    Some fraud-prevention agencies have created a document to explain how they use and share your information you can see this here.
    
    We may also need to share your personal information 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.
     

    HERE'S AN EXAMPLE OF WHEN WE MIGHT SHARE YOUR PERSONAL INFORMATION FOR ADVERTISING PURPOSES
    
    We may share your information (your name, email address and app events) with our advertising partners in the ways described below, but the information is hashed before we send it, and the social-media platform we share it with is only allowed to use that hashed information in the ways described below.
    
    When we use social media for marketing purposes, your information 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 information to send our adverts to you, because we think that you might be interested in a new Atmen 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.
    
    The legal basis would be the following.

    • Legitimate interests
       
    You can contact us as at any time, either through the My Atmen app or by emailing myatmen@myatmen.com , if you do not want us to share your personal information for marketing purposes. Remember you can also manage your marketing preferences directly with any social-media provider that you have an account with. Atmen and your personal information
     
11. Will my information go outside Europe?
    
    As we provide an international service, we may need to transfer your personal information outside the European Economic Area (EEA) in order for us to provide our services.
    
    For example, if you ask to make an international payment, we will send funds to banks overseas. We might also send your information overseas to keep to global legal and regulatory requirements, and to provide ongoing support services.
    
    We may share your personal information with credit-reference agencies and fraud- prevention agencies outside the UK. (You can read more about this in the Do you carry out credit checks or any make any automated decisions about me? section above).
    
    We will take all reasonable steps to make sure that your personal information is handled securely and in line with this privacy notice and data-protection laws.
    
    If you would like more information, please contact us through the My Atmen app or by sending an email to myatmen@myatmen.com .
     
12. How do you protect my personal information?
    
    We store your information on our secure servers.
    
    Any payment transactions carried out by us or our payment-processing providers will be encrypted using Secured Sockets Layer technology or a secure virtual private network.
    
    If you use a password for the My Atmen app or our website, you will need to keep this password confidential. Please do not share it with anyone. Unfortunately, providing information online is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee that all information you provide through the My Atmen app or our website will be secure. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
    
    When you use our services, which include social networking, chat room or forum features, do not share any personal information that you don't want to be seen, collected or used by other users, as this information will become publicly available.
     
13. How long will you keep my personal information for?
    
    Under anti-money-laundering laws we need to hold information about you and your transactions for five years.
    
    You have the right to redeem (ask us to return) your e-money for up to six years after your Atmen account is closed. We will therefore hold your information for this long.
    
    Generally, we will not hold your personal information for more than six years after our business relationship with you has ended, unless we need to hold it for longer because of a potential or ongoing claim or another legal reason.
     
14. How will you keep me updated on how you use my information?
    
    If we change the way we use your personal information, we will update this notice and, if appropriate, let you know by text message, by email, through the My Atmen app or through our website.
     
15. Cookies
    
    We use cookies to analyse how you use our website. Please read the Cookies Policy for more information about cookies

How we use cookies (the technical bit)

Some cookies are needed to run the website. For example, when you log in, cookies help torecognise you and keep you logged in as you browse the website. We call these strictlynecessary cookies.

We also use the following types of cookies:

• Necessary cookies

We need to use these cookies to make our website work, for example, so you can get promotions awarded to your account.

• Analytics and advertising cookies

These allow us to recognise and count the number of visitors to our website, and see howvisitors browse our website, so we can improve it where necessary.

These also allow us to see what pages and links you have visited so we can provide morerelevant ads. We may share this information with other organisations, such as Google,Facebook and LinkedIn, for the same purpose.

These cookies are all session cookies, which means that they will stop tracking your activityon the website when you close your website browser.

How do I change my preferences?

You can manage your preferences in relation to cookies, or change your browser settings torefuse the use of all or some cookies. However, if you block all cookies (including necessarycookies), you may not be able to use all or some parts of our website.

Please note, other organisations, such as advertising networks, may also use cookies totrack you across different websites. We have no control over these cookies.