Privacy Policy

Last updated: 6th October 2020
Summary Of Our Privacy Policy

We are Pennyworth Limited (“Pennyworth”, “we”, “us”), registered with the UK Information Commissioner’s Officer (ICO) under the number ZA793054.

At Pennyworth, we appreciate the value of your personal information. We respect your privacy and reflect that in the way we handle and protect your data.

We have drafted this Privacy Notice to be as clear and concise as possible. In some sections we have written a small summary followed by further detail. Please read it carefully.

By using or accessing and any of its pages (“Website”, “our website”) or providing us with your information by any other means, you agree to the collection, use and disclosure of information in accordance with this Notice. This may change from time to time so please check this page periodically for updates, as any changes become effective immediately.

Our Website may contain links to other websites or applications. If you follow these links, please note that each destination may have their own ways of handling your information. We therefore recommend that you review their Privacy Notice as we cannot be responsible or accept liability for these.

You have the right to make a complaint at any time to the ICO. We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO, so please contact us in the first instance by writing to us at We would also welcome any feedback you have on our privacy notices.

For information about how we use cookies, please read our Cookie Policy.

Please also visit our Website Terms establishing the use, disclaimers, and limitations of liability governing the use of our Website.

1 What Information Do We Collect?

Summary: We collect information about you through our interactions. For example, when visiting and using our Website or if you get in touch with us by email. The type and volume of information we collect will depend on the nature of our interaction and can include personal information, such as your email address, first and last name.

The detail:

  • We may collect, use, store and transfer different kinds of personal data about you. Personal data is any information that we can use to identify you for example your name, date of birth or address. It does not include data where the identity has been removed (anonymous data).

  • We collect the following data: 

    • Contact Data such as your e-mail address if you wish to remain up to date with our progress and latest news, or if you sign up to join the Pennyworth feedback community. 

    • Identity Data. This includes your first name and last name if you have signed up to participate in our  Pennyworth feedback community or surveys, which we occasionally undertake to improve our offering based on your feedback.

    • Cookie data. Like many websites, we currently use a small number of cookies to continuously improve our Website and provide you with the best possible experience. Please refer to our Cookie Policy for more detail.

  • Please note that we do not currently collect any Special Categories Personal Data about you. This includes details about 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. We ask you to not share this type of information with us.

2 How We Use This Information And Why?

Summary: We collect and use your data to provide you access to our feedback community and to communicate with you regarding our latest news. We also use cookies to improve our website. In all circumstances, we will comply with data protection laws and process your data lawfully, fairly, and transparently, without adversely affecting your rights.

The detail:

  • Applicable data protection and privacy legislation in force from time to time in the UK including but not limited to the General Data Protection Regulation ((EU) 2016/679), the Data Protection Act 2018, the Privacy and Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426), as amended (“data protection laws”), require that we ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights.

  • We will only process your personal data: 

    • to fulfil a contract with you (this includes any steps prior to entering a contract);

    • to meet our legal obligations;

    • for our legitimate interest, when this does not override your privacy rights. For example:

      • to respond to any questions and queries you may have when you contact us;

      • to improve our Website’s performance, security and functionality in order to enhance your browsing experience; and

      • if you are a member of Pennyworth’s feedback community (however, you will always have the option to unsubscribe from our updates and communications).

  • if we have your consent. For example:

    • to keep you up to date with our latest news, updates and updates including introduction of new products and services, should you wish to stay in touch; 

    • to communicate with you about Pennyworth’s feedback community by email. You can always unsubscribe by email or in your account settings;

    • to enable you to subscribe to our waiting list, should you so wish; and

    • to capture your feedback on products and services that we plan to offer, so that we can design and build products and services that you would value. 

  • necessary to protect the vital interests of you or of another natural person. We do not anticipate processing your personal data routinely on this basis, however there may be rare occasions where it is necessary to process your personal data to protect someone’s life.

  • In some instances, it may be appropriate for us to combine your information with other information that we may be holding about you, such as combining your email address with your browsing history.

  • If you don't want us to use your personal data for any of the other reasons set out in above, you can let us know at any time by contacting us at

  • and we will delete or anonymise your data from our systems. However, you acknowledge this will limit our ability to provide our services to you.

3 How Do We Collect Your Information?

We collect your information in the following ways:

  • When you visit our Website:

    • through cookies;

    • if you sign up to receive updates from us;

  • When you write to us by e-mail and/or provide feedback; 

  • If you participate in our surveys or research; and

  • If you sign up to our feedback community.

4 Who Do We Share Your Information With?

Summary: We share your data with a limited number of third parties, suppliers and with law enforcement bodies and regulators if required by law. When data is shared, we take reasonable steps to ensure your data is handled securely. 

The detail:

  • We may disclose your personal information to: 

    • Third parties you give us permission to share it with, for example, google analytics;

    • Suppliers that are required for the functionality of our Website; and

    • Law enforcement and other external parties where we have a legal obligation to do so;

  • The following list of third parties have access to your information, where relevant: 

    • cloud computing power and storage providers;

    • google analytics, provided we have your consent to store cookies; 

    • companies that help us with functional analytics (to help us solve technical issues with the Website for instance); and

    • companies that provide communication channels for our Pennyworth feedback community. 

  • Where we share your data, we will take reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under relevant Data Protection Legislation.

5 Where Do We Store Your Information?

Summary: We try to ensure that we do not send your information outside the UK and EEA, however, sometimes this is not possible. Data security is of great importance to us, and to protect your data we have put in place strict procedures and security features to try to prevent unauthorised access.

The detail:

  • We try to ensure that we do not send your information outside the UK and EEA, however, sometimes this is not possible. Your data may be stored in data centers located in the United States of America, Ireland, Japan, and Israel. 

  • If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the Data Protection Legislation. Such steps may include, but not be limited to, legally binding contractual terms between us and any third parties we engage with and the use of the EU-approved model clauses agreements.

  • By giving us your personal data, you agree to this arrangement.

  • Data security is of great importance to us, and to protect your data we have put in place strict procedures and security features to try to prevent unauthorised access. This includes physical, electronic, and managerial procedures to safeguard and secure data collected, including backup procedures, usernames, and passwords. 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 and, where applicable, data processing agreements.

  • 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.

  • Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure. You are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.

6 How Long Do We Store Your Information?

Our policy is to store personal data for no longer than needed for the legitimate business purpose for which we collect it; unless we are required to keep it for a longer period of time to ensure we comply with our legislative and regulatory requirements.

This means the exact length of time will depend on our relationship and the type(s) of interaction we are involved in:

  • If you browse our website, we will hold your cookie data for a maximum of 90 days;

  • If you participate in our research and surveys, we will hold your information for as long as you continue to do so and for a maximum of 12 months after you unsubscribe;

  • If you become a member of Pennyworth’s feedback community, we will keep your data for as long as you are an active member, and we will anonymise data after 12 months of inactivity;

  • If you subscribe to our updates, we will ask for subscription renewals every 2 years. If we do not hear from you, we will take reasonable steps to delete your data as soon as we can; and

  • If you have emailed us for feedback or to inquire about a particular matter, we will hold your personal information for a maximum of 12 months since our last interaction.

7 Your Rights

Summary:  You have certain rights under the law and under this notice. This includes the right to request access to your information, to manage it, and to request us to delete or transfer information about you or restrict the way it is used. You also have a right to complain. To do any of these things, please contact us by email on Please also contact us whenever your circumstances change – having accurate data enables us to deliver the best possible client service.

The detail:

  • When you submit information via our Website, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the email address provided above). Please note that this may, however, impact your experience.

  • Under data protection legislation you have the right to:

  • request access to, deletion of or correction of, your personal data held by us at no cost to you;

  • request that your personal data be copied or transferred to another person (data portability);

  • be informed of what data processing is taking place;

  • restrict processing, for example, withdrawing any consent you have given us;

  • object to processing of your personal data; and

  • complain to a supervisory authority.

  • You also have rights with respect to automated decision-making and profiling. However, these do not apply as we currently do not use automated decision-making or profiling.

  • You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.

  • Please note that there may be a few circumstances where we cannot ‘delete’ or block your data, for example:

  • where we are required to retain it by law;

  • where your information may be impossible to permanently delete. If this is not reasonably possible, we will put that information beyond reasonable use; and

  • where you have shared your information with others and therefore made it public.

8 How To Contact Us Or Make a Complaint?

If you have any questions about any of our privacy notices, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us on

If you have a complaint about how we use your personal information, we will do our best to fix the problem. If you are still not happy, you can refer your complaint to a data protection supervisory authority in the EU, country you live or work, or where you think a breach has happened. The UK’s supervisory authority is the Information Commissioner’s Office (ICO). For more details, you can visit their website at

For the purposes of the data protection laws, the data controller is Pennyworth Limited, registered in England and Wales, no. 12375981, with a registered office at 1 Cornhill, London EC3V 3ND.


Pennyworth is in pre-application to become an authorised bank in the UK. As we are not yet authorised, please do not take any information on this website as an invitation or inducement to apply to us for any services.

Copyright © 2021 Pennyworth Limited. 

PENNYWORTH ® is a registered trademark of Pennyworth Limited, registered in England and Wales, no. 12375981, with a registered office at 1 Cornhill, London EC3V 3ND.

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