1. General Information
The Juno services, which are accessible through either an application or and web browser (Juno Services) are provided by BillX Limited a company registered in England and Wales with company number 11741401 and its registered office at 71-75 Shelton Street, London, WC2H 9JQ (BillX). Juno is authorised and regulated by the Financial Conduct Authority (No. 918796).
This policy applies to your use of the Juno Services and sets out the basis on which any personal data Juno collects from you, or that you provide to Juno, will be processed by Juno.
2. What information does Juno collect?
Juno collects the following data from you.
(i) Juno collects and processes the following personal data relating to you when you register for or use the Juno Services:
- username (which may or may not contain your name, and may therefore not always be personal data);
- email address;
- telephone number;
- bank account details, including account number, sort-code, bank name and bank balance (Bank Details);
- transaction details (and sums owed or owing);
- profile picture;
- IP address;
- browser type and version; and
- user’s operating system.
3. What is your data used for?
Juno processes the following data in the following ways, and on the following legal bases:
- Your name, username, email, telephone number, address, age and date of birth for the purposes of your login credentials and verifying your identity if required. Juno does this on the bases that:
- it is necessary for the performance of Juno contract with you under which it is obliged to provide you with the Juno Services; and
- it is necessary in Juno’s legitimate interest in providing the Juno Services in an effective manner.
- To send you email marketing about similar products and services which we may provide to you. You will always have the option to opt-out of these marketing emails.
- To carry out Juno obligations arising from any contracts entered into between Juno and you, including to carry out the delivery of the Juno Services by facilitating payments and notifying your bank and other users of payments made and requested. Juno does this on the basis that it is necessary for the performance of Juno’s contract with you.
- To personalise your experience of the Juno Services, to help Juno respond better to your individual needs and to improve the Juno Services. Juno does this on the basis that it is necessary in Juno’s legitimate interest to ensure that the Juno Services are being provided in the best possible way.
- To send you periodic emails, text messages or notifications about the Juno Services, your use of them, and any updates or changes to them. Juno does this on the bases that:
- it is necessary in Juno’s legitimate interest to keep you up to date on the Juno Services; and
- some communications with you are necessary for the performance of Juno’s contract with you under which it is obliged to provide you with the Juno Services.
- To verify users’ contact details, and to confirm the identity of and maintain security and safety standards in relation to, users of the Juno Services. Juno does this on the bases that:
- it is necessary for the performance of Juno’s contract with you, as part of that contract includes an obligation on Juno to vet users, including you, for safety and security purposes; and
- it is necessary in Juno’s legitimate interest to ensure that all users of the Juno Services are safe and secure at all times.
- Your Bank Details to direct transaction requests to your bank and to inform your bank that you wish to allow Juno to send and receive money to and from your bank account as part of the Juno Services. Juno does this on the bases that:
- it is necessary in Juno’s legitimate interest to trigger payments as part of the Juno Services; and
- it is necessary for the performance of Juno’s contract with you under which it is obliged to provide you with the Juno Services.
Juno may review your personal data if it has reason to believe that the Juno Services have been used unlawfully or illegally, or in a manner which has resulted in an unlawful or illegal act. Juno does this on the bases that:
- it is necessary in Juno’s legitimate interest to ensure that the Juno Services are being used appropriately and lawfully; and
- where relevant, it is necessary to protect you, your bank, any other user or any third party’s vital interests.
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.
As part of the registration process Juno reserves the right to use any personal data provided to obtain further personal data from third parties in the interest of safety and security of Juno Services and its customers. It does this on the basis that it is necessary in Juno’s legitimate interest to ensure that all users of the Juno Services are safe and secure at all times.
4. Does Juno disclose any information to third parties?
Juno uses third parties to help process and deliver the Juno Services, including:
- by receiving data from your bank in order to allow other users to verify your identity; and
- to deliver communications (including any marketing communications) to you.
Juno does not allow third parties to use your personal data for their own purposes and only permits them to process your personal data for specified purposes and in accordance with Juno’s instructions.
Juno does not currently transfer your personal data outside the EEA. If it does so in the future, Juno will ensure that adequate safeguards are in place in relation to that data and have entered into arrangement with third parties to ensure that is the case.
Juno will disclose your personal data to third parties:
- if Juno sells or buys any business or assets, in which case Juno will disclose your personal data to the prospective seller or buyer of such business or asset;
- if Juno or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or
- if Juno is under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of Juno, you, other users or any third party. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
5. How does Juno handle and protect your personal data?
Juno has 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, Juno limits 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 Juno’s instructions and they are subject to duties of confidentiality.
Juno implements a series of security measures to maintain the safety of your information, including password protection and encryption. Juno has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where it is legally required to do so.
6. How long does Juno hold your personal data?
Juno will only retain your personal data for as long as reasonably necessary to fulfil the purposes it collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Juno may retain your personal data for a longer period in the event of a complaint or if Juno reasonably believes there is a prospect of litigation in respect to its relationship with you.
To determine the appropriate retention period for personal data, Juno considers the amount, nature and sensitivity of the personal data, the general time between customers returning to Juno to re-access the Juno Services, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which Juno processes your personal data and whether it can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
7. Your Rights
Where Juno relies on consent as the condition for processing your personal data, you have the right to withdraw that consent at any time.
You have various statutory rights in relation to your personal data. In particular, you have the right to:
- object to direct marketing communications at any time;
- request access to your personal data;
- rectification or erasure of your personal data, in certain circumstances;
- object to or restrict the processing of your personal data in certain circumstances;
- have your personal data stored in a manner in which it is portable from the Juno environment to another environment; and
- file a complaint with the Information Commissioner’s Office.