We operate in the United Kingdom as a private limited company Big Picture Labs Limited.
Our company registration number is 11607177 and our registered office is International House, 24 Holborn
Viaduct, London, England, EC1A 2BN.
We use the trading name ‘bigmo’ to offer our services
This privacy policy aims to give you information on how our company collects and processes your personal
data through your use of this website, including any data you may provide through this website when you sign
up for our services.
This website is not intended for children and we do not knowingly collect data relating to children.
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.
Controller
Big Picture Labs Limited is the controller and responsible for your personal data (collectively
referred
to as ("COMPANY"), "we", "us" or "our" in this privacy policy).
We have appointed a Privacy Manager who is responsible for overseeing questions in relation to this privacy
policy.
If you have any questions about this privacy policy, including any requests to exercise your legal rights,
please contact the Privacy Manager using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our
Privacy Manager in the following ways:
Full name of legal entity: Big Picture Labs Limited
Email address: prasanna@bigpicturelabs.co.uk
Postal address: International House, 24 Holborn Viaduct, London, England, EC1A 2BN
Telephone number: 07377509531
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO),
the UK 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.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
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.
Third-party links
This website may include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections may allow third parties to collect or share data about
you.
We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy policy of every website you visit.
1. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can
be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped
together as follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier,
marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of
services
you have purchased from us.
• 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 this website.
• Profile Data includes your username and password, purchases or orders made by you, your
interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us
and
our third parties and your communication preferences.
We 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 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 website 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 (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). Nor do we collect any
information about criminal convictions and offences.
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, and you
fail
to provide that data when requested, we may not be able to perform the contract we have or are trying to
enter
into with you (for example, to provide you with goods or services). In this case, we may have to cancel a
product or service you have with us but we will notify you if this is the case at the time.
2. How your personal data is collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in
forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you
provide when you:
a) apply for our products or services;
b) create an account on our website;
c) subscribe to our service;
d) request marketing to be sent to you;
e) give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect
Technical Data about your equipment, browsing actions and patterns. We collect this personal data by
using cookies, server logs and other similar technologies. We may also receive Technical Data about you
if you visit other websites employing our cookies. Please see our cookie policy
for further
details.
• Third parties or publicly available sources. We will receive personal data about you from various third
parties and public sources as set out below Technical Data from the following parties:
(a) analytics providers;
(b) advertising networks; and
(c) search information providers.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery service banks
inside the EU.
• Identity and Contact Data from data brokers or aggregators.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral
Register based inside the EU.
3. How we use your personal data
We will only use 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 perform the contract we are about to enter into or have entered into with you.
• 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 we need to comply with a legal obligation.
• In order to access and use the main functionality of the services we provide, we will direct you to
Plaid Financial Ltd.
• Big Picture Labs Ltd is an agent of Plaid Financial Ltd., an authorised payment institution regulated by the Financial Conduct Authority under the Payment Services Regulations 2017 (Firm Reference Number: 804718). Plaid provides you with regulated account information services through Big Picture Labs Ltd as its agent.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways 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 ground depending on the specific
purpose for which we are using your data. Please contact us if you need details about the specific legal
ground we are relying on to process your personal data where more than one ground has been set out in the
table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer |
(a) Identity
(b) Contact |
Performance of a contract with you |
|
To process and deliver the services we provide:
(a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) transmit and access information relating to banking payment accounts |
(a) Identity (b) Contact (c) Financial including bank account information (d) Transaction (e) Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Consent |
| To enable us to get ongoing feedback on the product for its improvement, based on your consent. We will only contact you based on an agreed appointment time. |
(a) Identity
(b) Contact |
(a) Consent |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey by us contacting you by telephone |
(a) Identity (b) Contact (c) Profile (d) Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of
administration and IT services, network security, to prevent fraud and in the context of a
business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to
develop them, to grow our business and to inform our marketing strategy)
|
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and
services, to keep our website updated and relevant, to develop our business and to inform our
marketing strategy)
|
| To make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business)
|
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for
marketing purposes.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access
cookies. If you disable or refuse cookies, please note that some parts of this website may become
inaccessible or not function properly. For more information about the cookies we use, please see cookie policy
Change of purpose
We will only use 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.
If you wish to get an explanation as to how the processing for the new purpose is compatible with the
original purpose, please contact us.
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.
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.
4. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table
Purposes for which we will use your personal data above.
• External Third Parties as set out in the Glossary.
• 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.
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.
5. International transfers
Many of our external third parties are based outside the EEA so their processing of your personal data will
involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded
to it by ensuring 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 by the European Commission. For further details, see European Commission:
Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission
which give personal data the same protection it has in Europe. For further details, see European Commission:
Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy
Shield which requires them to provide similar protection to personal data shared between Europe and the US.
For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring
your personal data out of the EEA.
6. Data security
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.
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.
7. Data retention
How long will you use my personal data for?
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.
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and
Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further
information.
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.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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 clearly unfounded, repetitive or excessive.
Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a
month if your request is particularly complex or you have made a number of requests. In this case, we will
notify you and keep you updated.
8. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to
enable us to give you the best service/product and the best and most secure experience. We make sure we
consider and balance any potential impact on you (both positive and negative) and your rights before we
process your personal data for our legitimate interests. We do not use your personal data for activities
where our interests are overridden by the impact on you (unless we have your consent or are otherwise
required or permitted to by law). You can obtain further information about how we assess our legitimate
interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data 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.
Comply with a legal obligation means processing your personal data where it is necessary for
compliance with a legal obligation that we are subject to.
Consent means processing your personal data only where we are provided with your specific consent.
THIRD PARTIES
External Third Parties
• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and
insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in
the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
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.
• 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 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.
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.