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  • Privacy Policy June 2025 

Privacy Policy June 2025 
Effective Date: June 18, 2025

1. Our Privacy Policy 

1.1 We are committed to protecting and respecting your privacy and personal data and will only collect and use personal data in ways that are described here and ways that are consistent with our obligations and your rights under applicable law relating to the protection of personal data. 

1.2 This Privacy Policy aims to give you information about how we collect and process your personal data when you visit our websites (including subdomains of our websites) and apps through which we make our services available. This Privacy Policy tells you how we collect and process data received from you from: 

1.3 This Privacy Policy would apply regardless of where you visit our Platform from and would apply to any data that you may provide through our Platform, when you register to use our services, or when you otherwise interact with us. 

1.4 Please read this Privacy Policy carefully and ensure that you understand it. By using our Platform and/or services, you agree to be bound by this Privacy Policy and consent to the collection, use, processing, and disclosure of your personal data as described in this Privacy Policy.  

1.5 It is important you read this Privacy Policy together with any other privacy policy we may provide from time to time when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.  

1.6 References to “you” or “your” are to you as an individual using our Platform or otherwise contacting us (whether on behalf of yourself, or another individ1ual or organisation). 

2. Information About Us 

2.1 This Platform is operated by Atoa Payments Limited, a company registered in England and Wales with company number 13910811 and registered office at 30 Churchill Place, Canary Wharf, London E14 5EU (“Atoa”, “we”, “us” or “our”). We are regulated by the Financial Conduct Authority (FCA) with firm reference number 1007647. We are the controller and are responsible for our Platform.  

2.2 We are responsible for your personal data, except where we process your personal data because you use our services as a result of your relationship with a client who we supply our services to (for example, if you use our services as a result of your being our client’s employee or client).  

2.3 Where we process your personal data because you use our services as a result of your relationship with a client who we supply our services to, we are not the data controller as we would be processing personal data on behalf of our client as a data processor. 

2.4 Where we are processing your personal data on behalf of our client, the privacy policy that you should be referring to would be our client’s privacy policy. Our client’s privacy policy should inform you as to how your personal data will be processed. 

2.5 We are bound by applicable data protection laws in respect of the handling and collection of your personal data. We are registered as data controllers in England and Wales, and our Information Commissioner’s Office (“ICO”) registration number is ZB502951. 

2.6 If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us at legal@paywithatoa.co.uk.  

3. Consent to install the Atoa Pay app and/or Atoa Business app 

3.1 Before installation of the Atoa Pay App and/or Atoa Business App, please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in this Privacy Policy. 

YES I consent to the installation of the Atoa Pay App and/or Atoa Business App for the purposes of making payments. 

NO I do not consent to the installation of the Atoa Pay App and/or Atoa Business App. 

3.2 How do you withdraw consent 

Once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting us (hello@paywithatoa.co.uk) but that will not affect the lawfulness of any processing carried out before you withdraw your consent. 

3.3 Consent to processing Location Data 

YES I consent to processing of my Location Data (including details of my current location disclosed by GPS technology so that location-enabled services are activated to aid in the protection of users against unauthorised access by other parties. 

NO I do not consent to processing of my Location Data and location-enabled services are disabled in my settings. 

4.What personal data we collect about you 

4.1 Personal data or personal information means any information about you that enables you to be identified personally.  

4.2 Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data and other online identifiers that can be linked with such information in order to identify you. It does not include data where the identity has been removed (anonymous data). 

4.3 Depending on the use you make of our Platform, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: 

  • Identity Data includes your name, username or similar identifier, title, gender, date of birth, and photographic and/or facial identification data. 
  • Contact Data includes residential address, billing address, registered business address, email address, and telephone numbers. 
  • Financial Data includes bank account details.  
  • Transaction Data includes details about payments to and from you, details of your direct debt payments to Atoa and other details of services you have purchased from us (including Atoa Pay App and/or Atoa Business App in-app purchases). 
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Platform. 
  • Device Data includes the type of mobile device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of your 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, time zone setting. 
  • Content Data includes information stored on your device, including friends’ lists, login information, photos, videos or other digital content. 
  • Profile Data includes your username and password, Atoa Pay App and/or Atoa Business App in-app purchase history, data about your interests, preferences, feedback, and survey responses.  
  • Usage Data includes details of your use of any of our apps or your visits to any of our sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access. 
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.  
  • Location Data includes your current location disclosed by GPS technology. 
  • Phone Contacts – if you grant us permission to access your contact list (when you enter the “Refer” and “Invite” pages), we may access this information to help send invites and track rewards. 
  • Special Category Data includes information about your race or ethnicity, health, hobbies, religious or political beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data. 

4.4 We do not ask you for any Special Category Data about yourself, nor do we ask you for any information about criminal convictions and offences. However, if you choose to provide us with such types of personal data when you interact with us, you are giving us your explicit consent to process such data about you to the extent permitted by the UK data protection regime (as applicable). 

4.5 We may also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law and will not directly or indirectly reveal your identity. For example, we may aggregate your usage information to calculate the percentage of users accessing a specific feature of our Platform. However, if we combine Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.  

4.6 The name, phone number, and or e-mail of people you refer to Atoa is uploaded to our database for issuing referral credits. We will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. 

4.7 Your photo is used for the purpose of displaying as a user avatar. This can be the image you have selected from your gallery or the image taken by you from your camera. This photo will not be shared outside the app. You can also opt-out from uploading a photo. 

5. If you fail to provide personal data  

Where we need to collect personal data by law, or under the terms of a contract we have with you, or pursuant to a service that we have been asked to supply to you, and you fail to provide that data when requested, we may not be able to perform the applicable contract or service. In this case, we may have to cancel any arrangement you have with us, but we will notify you if this is the case.  

6. How we collect your personal data 

6.1 We use different methods to collect data from and about you, including through:  

  • Direct interactions. You may give us your personal data by entering information on our Platform, filling in forms or questionnaires, subscribing to our communications, by corresponding with us by phone or email, via our ‘contact us’ page or by otherwise directly interacting with us.  
  • Automated technologies or interactions and information collected about you and your device. As you interact with our Platform, we will automatically collect personal data including Device Data, Content Data and Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. You can read more about our handling of cookies by visiting our Cookie Policy. 
  • Third parties. We may receive personal data about you from various third parties, such as the partners we work with from time to time in relation to the running and operating of our Platform and the provision of our services. 
  • Publicly available sources. We may receive personal data about you from public sources including but not limited to analytics providers, search information providers, publicly available social media accounts, Companies House, and the Electoral Register based in the UK.  
  • Location Data. We also use GPS technology to determine your current location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your phone settings. 
  • Unique application numbers. When you want to install or uninstall a service containing a unique application number or when such a service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us. 

7. Purposes for processing personal data 

7.1 We will only use and process your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:  

  • Where we need to provide services or information to you or to perform the contract we are about to enter or have entered with you.  
  • Where we have a legal or regulatory obligation we must comply with.  
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.  
  • Where you have provided your consent.  

7.2 We have set out below a description of the ways in which we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful base depending on the specific purpose for which we are using your personal data. 

Types of personal data  What we use your personal data for Our reasons (legal bases) 

Identity Data  Contact Data  Financial Data Profile Data Marketing and Communications Data  		Providing and managing your access to our site and services, including managing our relationship with you (such as notifying you about changes to our app, services, terms or privacy policy, or asking you to leave a review or take a survey) 
Performance of a contract with you Necessary for our legitimate interests (for example, to keep our records updated and to analyse how customers use out services) Necessary to comply with a legal or regulatory obligation (to inform you of any changes to our terms and conditions)  

Identity Data  Contact Data  Financial Data Device Data  		Installing the Atoa Pay App and/or Atoa Business App and registering you as a new user 
Your consent  

Identity Data  Contact Data  Financial Data Transaction Data Device Data Marketing and Communications Data Location Data  		Processing Atoa Pay App and/or Atoa Business App in-app purchases and deliver services, including managing payments and collecting money owed to us or to third parties 
Necessary for our legitimate interests (to process payments to third parties) Your consent 

Identity Data  Contact Data  Profile Data Marketing and Communications Data Technical Data Usage Data  		Personalising and tailoring your experience on our site and measuring or understanding the effectiveness of any advertising we serve to you 
Necessary for our legitimate interests (for example, to provide users with a good experience and to inform our marketing strategy)  

Identity Data  Contact Data  Technical Data 		Administering and protecting our site and business (including troubleshooting, data analysis, testing, system maintenance etc.) 
Necessary for our legitimate interests (for example, for running of our business, provision of administration and IT services and network security) Necessary to comply with a legal or regulatory obligation  

Identity Data  Contact Data  Profile Data Usage Data 		Being as responsive as possible to you, for example, when answering your queries 
Necessary for our legitimate interests (for example, to provide you with a good service) and for your legitimate interests (for example, to receive assistance promptly)   

Identity Data  Contact Data  Marketing and Communications Data  		Supplying you with information by email, post, or other means that you have opted-in-to (for example, when you have subscribed to receive such information) 
Necessary for our legitimate interests (for example, to provide a good service, grow our business, and develop our services, and for your legitimate interests (for example, to obtain the information you have asked for)  

Identity Data  Contact Data  Device Data Content Data Profile Data Marketing and Communications Data Technical Data Usage Data Location Data  		Using data analytics to improve our site, services, marketing, trends, user relationships and experiences 
Necessary for our legitimate interests (for example, to keep the Platform relevant, to develop our services and business and to inform our marketing strategy) Your consent  

Identity Data  Contact Data  Device Data Profile Data Marketing and Communications Data  		Enabling you to participate in a prize draw, competition or complete a survey 
Performance of a contract with you Necessary for our legitimate interests (to analyse how customers use our services and to develop them and grow our business) Your consent 

Identity Data Contact Data Financial Data Transaction Data 		Enabling you to access and use our account information services (AIS) product 
Your consent 

7.3 We will only use and process your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  

7.4 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

8. Marketing 

8.1 We may send you marketing communications by email, text message, telephone, or otherwise via the Platform. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

8.2 We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which of our business offerings may be relevant to you.  

8.3 We will get in your express opt-in consent before we share personal data with any third party for marketing purposes.  

8.4 We may also collect your personal data and contact details through third parties such as Lusha or Apollo. We will only contact you if your details are listed on those third party providers. You can ask us to stop contacting you at any time. 

8.5 Opting out of marketing:  

  • You can ask us or third parties to stop sending you marketing messages at any time.  
  • Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.  
  • If you choose to object to the communications, unsubscribe or withdraw your consent, this will not make our processing of your personal data before you withdrew your consent unlawful.  

9. Automated Decision Making 

9.1 Automated decisions are made by technological means, mostly based on algorithms subject to predefined criteria. Such automated decision-making, taken solely by technological means without any human intervention, may have legal effects or similarly significant effects on you.  

9.2 In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us. 

9.3 For clarity, we make automated decisions to determine whether to allow a transaction or not. This automated decision is based on the checks carried out through our transaction monitoring service which monitors suspicious transactions based on the following factors: 

  • The age of merchant. 
  • The size of transaction. 
  • The time of day. 
  • The type of transaction - customer present or not present. 

9.4 Depending upon the results of the checks carried out, this could result in our automatically declining a transaction. The right to object to automatic processing of your personal data does not apply in the following circumstances: 

  • The decision is necessary for the entry into, or performance of, a contract between the you and us. 
  • The decision is authorised by law. 
  • You have given you explicit consent. 

10. How we may share your personal data 

10.1 We may share your personal data with certain parties as set out below:  

  • External third parties such as:  
    • Professional advisors including lawyers, bankers, auditors, and insurers.  
    • HM Revenue & Customs, FCA and other regulators and authorities, whether in the UK, EEA, US, or any other applicable jurisdiction.  
    • Service providers and business partners whom we work with in connection with the running of our business and our providing the Platform and/or services in order to facilitate authorised payments and refunds via Atoa Pay App, Atoa Business App and our websites, such as: 
      • Merchants, in order to enable payments to be made to the merchants using our Platform, we share limited amounts of information (including bank type, amount paid and the last three digits of the customer's bank account. 
      • Promotional events and marketing organisations. 
      • Our technical infrastructure provider, Yapily Limited (and possibly their license-holding subsidiary, Yapily Connect Limited) for account verification, AML and KYC purposes. 
      • Sales intelligence platforms such as Lusha and Apollo. 
      • Other banks such as ClearBank Limited, in the case of businesses that opt-in to our ‘Aggregation Service’ and in order to enable the bank to conduct random scans of our accounts for money laundering and suspicious activity purposes. 
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy. 

10.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

10.3 International transfers. Whenever we transfer your personal data out of the UK and/or EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:  

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. 
  • If we transfer your personal data to any other country which is not subject to an adequacy decision of the UK or the European Commission (as applicable) regarding an adequate level of protection of personal data, we will ensure that there is a legal basis and, if required, a relevant safeguard method for such data transfer so that your personal data are treated in a manner that is consistent with, and respects the applicable laws and regulations on data protection in the UK or the EEA (as applicable). 
  • Where we use certain service providers outside of the UK and/or the EEA (as applicable), we may use specific contracts approved for use in the UK and/or the EEA (as applicable) which give personal data the same protection it has in the UK and/or the EEA (as applicable).   

10.4 Please note that our chat support services are supported by third parties. Any data provided under the chat boxes will be shared with the third parties providing the support. 

10.5 Atoa Pay App allows other users to see your name in their phone contact list when you consent. This may include other users to see your name, profile photo and Atoa ID under their phone contacts that use Atoa and to send money to those same people. 

10.6 Atoa Business App allows other users to see your business name when they receive a SMS payment link or scan a QR code associated with your business account. Customers may be able to view your account number and sort code but cannot debit funds or interfere with your account in any way. 

11. Data Security 

11.1 All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer (SSL) technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. 

11.2 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed.  

11.3 In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.  

11.4 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

11.5 We will collect and store personal data on your device using application data caches and browser web storage (including HTML5) and other technologies. 

11.6 Certain services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users. 

12. How we will retain your personal data 

12.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of providing our services to you and satisfying any legal, regulatory, tax, accounting or reporting requirements.  

12.2 We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is prospect of litigation in respect of our relationship with you.  

12.3 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purpose for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements. 

12.4 As regards Atoa Pay App and Atoa Business App: 

  • By law we have to keep basic information about our customers (including Contact Data, Identity Data, Financial Data and Transaction Data) for five years after they cease being customers. 
  • In the event that you do not use the Atoa Pay App for a period of 12 months, we will treat the account as expired and your personal data may be deleted. 

12.5 As regards Atoa’s websites, we delete your account information six months after your last application with us. Other information related to your account will be deleted two years after your account has become inactive. 

12.6 In some circumstances you can ask us to delete your data (see your legal rights below).  

12.7 In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

12.8 Otherwise, we securely erase or anonymise your personal data where we no longer require your information for the purposes collected. 

13. Your Legal Rights 

13.1 Under UK/EU data protection laws (as applicable), you have a number of rights (subject to certain conditions) when it comes to your personal data. Your legal rights include:  

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 
    •  if you want us to establish the data’s accuracy;  
    • where our use of the data is unlawful but you do not want us to erase it;  
    • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or  
    • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 
  • Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you. 
  • Withdraw consent at any time where we are relying on consent to process your personal data. For example, you can withdraw your consent to our processing your personal data for data analytics purposes at any time by adjusting your browser settings. However, your withdrawing of consent will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent. 

13.2 If you want to exercise any of the rights set out above or have any questions on them, please contact us. We usually act on requests and provide information free of charge but may charge a reasonable fee to cover our administrative costs of providing the information for baseless or excessive/repeated requests or further copies of the same information. 

13.3 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

13.4 We may also be entitled under some circumstances to refuse to act on the request and will notify you if this is the case.   

13.5 We try to respond to all legitimate requests as soon as we can. Generally, this will be within 4 weeks from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know. 

13.6 You also have the right to lodge a complaint about the way we handle or process your personal data with the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk).  We would, however, appreciate the chance to deal with concerns before you approach the ICO, so please contact us in the first instance. 

13.7 If you are a data subject in the EU/EEA, you should contact the relevant supervisory authority in your territory. A list of the supervisory authorities across the EEA can be found at https://edpb.europa.eu/about-edpb/about-edpb/members_en.  

14. Third Party Links 

Our Platform may include links to third party websites, plug-ins, and applications. Clicking on third-party links or enabling third-party connections may allow third parties to collect or share data about you.  Third-party sites are not under our control, and we are not responsible for its content.  When you leave our Platform, we encourage you to read the privacy policy of every website you visit.  

15. Changes to this Privacy Policy 

15.1 We keep this Privacy Policy under regular review and may update it from time to time. We reserve the right to make amendments to our Privacy Policy at any time. Historic versions can be obtained by contacting us.  

15.2 Any changes we may make to this Privacy Policy will be posted on our Platform and, where appropriate, notified to you.  

15.3 Unless otherwise provided in this Privacy Policy, it is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.  

This Policy was last updated on 18 June, 2025