Privacy Policy for the My Money Matters
App and Platform 

Within this Policy, the words ‘we’, ‘us’ and ‘our’ refer to AVC Wise Ltd (t/a My Money Matters). 

We respect your privacy and are committed to protecting your personal data. This Privacy Policy will tell you how we look after the personal data that you provide to us. It will also tell you about your privacy rights and how the law protects you. The security of your personal information is our highest priority.  

Our app and platform use an encryption system which protects your communications with us and keeps them private. 

We regularly change and update our Privacy Policy. Please check back frequently for any updates.

This policy aims to give you information on how we collect and process your personal data. 

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It is important that you read this privacy policy, together with any other privacy policy or fair processing policy we may provide on specific occasions 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. 

If you have any questions about this privacy policy or our privacy practices, please contact us at:  

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AVC Wise Ltd (t/a My Money Matters) 

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Email address: support@my-money-matters.co.uk  

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Telephone: 01252 959 779 

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Postal address:  AVC Wise Ltd (t/a My Money Matters),  First Floor, 5 Fleet Place, London, United Kingdom, EC4M 7RD. 

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You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK’s supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance. 

We keep our privacy policy under regular review. 

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This version was last updated on 05/03/2025. 

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It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes. 

A piece of information constitutes personal data if it relates to an individual, directly or indirectly. In other words, personal data is any information relating to an identified or identifiable living person; such a person is called a data subject.   

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We, may collect, use, store and transfer different types of personal data about you, which we have grouped together in the following ways: 

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• Identity Data includes first name, last name, username or similar identifier, Employee Number, NI Number, date of birth, gender, salary and any existing AVC Plan information. 
   

• Contact Data includes address, email address and telephone numbers. 
   

• Transaction Data includes details about products and services you have selected. 
   

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, device model, operating system(OS) version, platform (iOS/Android), UUID (Unique Identifier for Each Service), and other technology on the devices you use to access the My Money Matters platform at https://www.my-money-matters.co.uk  
   

• Profile Data includes your username and password, feedback and survey responses. 
   

• Usage Data includes information about how you use the My Money Matters platform and services. 
   

• Communications Data includes your communication preferences. 
   

We also collect, use and share with third parties Aggregated Data such as statistical or demographic data. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect 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. We do not collect any Special Categories of Personal Data about you (such as your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we, collect any information about criminal convictions and offences. 

Where we need to collect your personal data by law, or for the performance of a contract to which you are party, if you fail to provide that personal data, those lawful purposes for collecting and processing it cannot be met. Consequently, for example, you may have your request for services rejected. 

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

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• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: 
   

  • make an application for products or services; 

  • create an account; 

  • subscribe to publications; 

  • enter a competition, promotion or survey; or 

  • give us feedback or contact us. 
     

• Automated technologies or interactions. As you interact with the App and platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. For further details, please see the Cookies section later on in this Privacy Policy. 
   

• Third parties or publicly available sources. We will receive personal data about you from analytics providers such as Google. 

We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances: 

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• Where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.  
   

• Where it is necessary for the purposes of legitimate interests pursued by us.  
   

• Where it is necessary for compliance with a legal obligation that we are subject to. 
   

• Where you have consented to the use of your personal data for a further purpose. 

We have set out below a description of all the ways in which we plan to use your personal data: 

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Purpose/Activity 1 

To register you and to introduce you to other employee services. 

Types of data: (a) Identify; (b) Contact 

Lawful bases; 

Performance of a contract with you – Art.6(1)(b) Legitimate interests – Art.6(1)(f) 

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Purpose/Activity 2
To process and deliver your request for services, including managing payments, fees and charges and collecting and recovering money owed to us.  

Types of data: (a) Identify; (b) Contact; (c) Transaction; (d) Communications 

Lawful basis: Performance of a contract with you – Art.6(1)(b) 

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Purpose/Activity 3

To manage our relationship with you, including notifying you of changes to our Terms or Privacy Policy and asking you to leave a review or take a survey.

Types of data: (a) Identify; (b) Contact; (c) Profile; (d) Communications 

Lawful bases: Performance of a contract with you – Art.6(1)(b) 

Necessary to comply with a legal obligation – Art.6(1)(c) 

Legitimate interests – Art.6(1)(f) 

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Purpose/Activity 4

To enable you to [consensually] partake in a prize draw or competition, or to complete a survey. 

Types of data: (a) Identify; (b) Contact; (c) Profile; (d) Usage (e) Communications 

Lawful bases: Consent – Art.6(1)(a) 

Performance of a contract with you – Art.6(1)(b) 

Legitimate interests – Art.6(1)(f) 

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Purpose/Activity 5

To administer and protect our organisation and this platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). 

Types of data: (a) Identify; (b) Contact; (c) Technical 

Lawful bases: Performance of a contract with you – Art.6(1)(b) 

Necessary to comply with a legal obligation – Art.6(1)(c) 

Legitimate interests – Art.6(1)(f) 

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Purpose/Activity 6

To deliver relevant website/platform content to you and measure or understand the effectiveness of the communications. 

Types of data: (a) Identify; (b) Contact; (c) Profile; (d) Usage (e) Communications; (f) Technical 

Lawful bases: Performance of a contract with you – Art.6(1)(b) 

Legitimate interests – Art.6(1)(f) 

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Purpose/Activity 7

To use data analytics to improve the platform, products/services, communications, customer relationships and experiences. 

Types of data: (a) Technical; (b) Usage 

Lawful bases: Performance of a contract with you – Art.6(1)(b) 

Legitimate interests – Art.6(1)(f) 

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Purpose/Activity 8

To make relevant suggestions and recommendations to you about goods or services that may be of interest to you. 

Types of data: (a) Identify; (b) Contact; (c) Profile; (d) Usage (e) Communications; (f) Technical 

Lawful bases: Performance of a contract with you – Art.6(1)(b) 

Legitimate interests – Art.6(1)(f) 

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Purpose/Activity 9

To enable access to third party service providers via the platform, and to facilitate their provision of those services to you. 

Types of data: (a) Identify; (b) Contact 

Lawful basis: Consent – Art.6(1)(a) 

You will receive communications from us if you have registered on the My Money Matters platform. 

When you complete a registration, application or enter details on our App and platform, your personal information is encrypted (more specifically, our SSL certification operates with 256 bit encryption and supports TLS 1.2 and TLS 1.3). This encryption prevents anyone else from reading your personal information while it is in transit. On the website, you will see a padlock symbol at the bottom of the screen which confirms that you are in a secure area. Your personal information will also be protected on our internal systems, with secure firewalls and other measures to prevent any unauthorised access. 

Our app and platform use the Google AdWords remarketing service. We advertise to previous visitors to our app and platform using third party services, including Google. We may advertise to visitors who haven’t completed a task on our app and platform (for example, using the contact form to make an enquiry). This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third party vendors, including Google, use cookies to show ads based on someone’s past visits to our app and platform. Of course, any data collected will be used in accordance with this privacy policy and Google’s privacy policy. 

This app and platform have also implemented Google Analytics Demographics and Interest Reporting, so that we can monitor the visits to our app and platform. You can set preferences for how Google advertises to you using the Google Ad Preferences page ; and if you want to, you can opt out of interest-based advertising entirely via cookie settings or by permanently using a browser plugin. 

You can ask us to stop sending you communications at any time by contacting My Money Matters or by clicking the unsubscribe link in any message. 

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Where you opt out of receiving communications, this will not apply to messages concerning the fulfilment of services, or when we want to notify you regarding other important developments. 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. For more information about the cookies used, please see the My Money Matters Cookie Notice https://www.my-money-matters.co.uk/cookies  

We will only use your personal data for the purposes for which it is collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us. 

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If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

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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. 

We may share your personal data with the parties set out below for the purposes set out in the table in Section 4 above. 

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• Internal third parties related to your employer acting as joint controllers or processors. 
   

• External third parties such as: 
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  • Service providers acting as processors who, for example, provide administration services or payroll services.

  • Professional advisers acting as processors or joint controllers including lawyers, tax advisors and auditors. 

  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances. 

  • Providers of services that are freely accessible by you via the My Money Matters platform. 
     

• Other parties to whom we may choose to sell, transfer or merge parts of our organisation or our assets. Alternatively, we may seek to acquire other organisations or merge with them. If a change happens to our organisation, then the new owners may use your personal data in the same way as set out in this privacy policy.  

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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 undisclosed purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. If we need to share any of your personal data with third party service providers on the My Money Matters platform, we will notify you of this and seek your consent to that transfer of data. 

Neither My Money Matters nor any of its Sub-Processors transfer your personal data outside the European Economic Area (EEA). If that ever became necessary, we would ensure that appropriate safeguards were in place to provide adequate protection to the data transferred, and to your data rights. 

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. 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. 

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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. 

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 satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

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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 purposes 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. 

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In some circumstances, you can ask us to delete your data: see the ‘Your legal rights’ section below for further information. 

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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. 

In certain circumstances, you have rights under data protection law in relation to your personal data. 
 

You have the right to: 
 

a. 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 processing it lawfully. 
 

b. 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. 
 

c. 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. 
 

d. 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 
 

e. 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: 
 

i. If you want us to establish the data's accuracy. 

ii. Where our use of the data is unlawful but you do not want us to erase it. 

iii. 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. 

iv. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 
 

f. Request the transfer of your personal data to you or to a third party. We will provide to 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. 
 

g. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

 

If you wish to exercise any of the rights set out above, please contact us at: 
 

AVC Wise Ltd (t/a My Money Matters) 
 

Email address: support@my-money-matters.co.uk  
 

Telephone: 01252 959 779 
 

Postal address:  AVC Wise Ltd (t/a My Money Matters), First Floor, 5 Fleet Place, London, United Kingdom, EC4M 7RD. 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is ‘manifestly unfounded or excessive’. Alternatively, we could refuse to comply with your request in those circumstances. 

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. 

Normally, we will respond to all legitimate requests within one month. In exceptional cases, it could take us longer than a month if your request is particularly complex or you have made several requests. In such a case, we will notify you and keep you updated.