Zilch Privacy Notice

Introduction

Zilch Technology Limited is committed to protecting and respecting your privacy. This privacy notice, together with any agreement you enter into with us, details how we collect, use and disclose your personal data as well as your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Zilch Technology Limited (collectively referred to as “Zilch”, “we”, “us” or “our”) processes personal data about users of our website, mobile application or any other services, technology, or products we may offer from time to time (collectively, “Services”). For purposes of this privacy notice “you” and “your” means you as the user of the 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 notice together with any other privacy notice or fair processing notice 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 notice supplements other notices and privacy policies and is not intended to override them.

Controller

Zilch Technology Limited is the controller and responsible for your personal data. We are registered with the UK data protection authority, the Information Commissioner’s Office (ICO), under registration number ZA522707.

The merchants that we work with are independent of Zilch and may have their own privacy policies which are different from ours. Our merchants may also be data controllers in respect of personal data that you provide to them, and you should contact them if you would like further information about how they use your personal data, or if you would like to view their privacy notice.

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

If you have any questions about this privacy notice or our privacy practices, please contact us in the following ways:

Full name of legal entity: Zilch Technology Limited

Postal address: 111 Buckingham Palace Road, London, England, SW1W 0SR United Kingdom

E-mail address: [email protected].

Changes to the privacy notice

We keep our privacy notice under regular review to make sure it is up to date and accurate and will revise the date at the bottom of this notice to reflect the date when such update occurred. Zilch reserves the right to modify this notice from time to time, so please review it regularly. If we make material changes to this notice, we will notify you by email.

Your duty to inform us of any changes to your personal information.

If you use our Services, 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 and our mobile app 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 or mobile app, we encourage you to read the privacy notice of every website you visit.

2. 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:

Category of personal dataTypes of personal data
Identity data• First name
• Last name
• Username or similar identifier
• Marital status
• Title
• Date of birth
• Gender
Image dataCopy of your id document and a selfie/video
Contact data• Postal address
• Email address
• Telephone number
• Public details from your social media profile
Financial data• Account data: account information, card details, credit reference data, credit limit, account status, balance, and purchase limit.
• Transaction data: transaction information and merchant.
• Loan information data: overdue payments details.
• Open banking data (if you connect your zilch account with open banking): bank account details of those accounts that you choose to connect to the service, transactions, and balances.
Technical data• 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, device id
• Other device information
• Mobile operating system
• Other technology on the devices you use to access this website and our mobile app.
Profile data• Your username
• Password
• Your interests
• Preferences
• Feedback and survey responses
Usage data• Information about how you use our website, Mobile app and Services.
• Details of the products you viewed or searched for, page interaction information.
Marketing and Communications data• Your preferences in receiving marketing from us and our third parties.
• Your communication preferences

We may need to process Special Categories of Personal Data about you (this is information that can reveal a person’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about their health, and genetic and biometric data). For example, when you submit your identity document and a selfie, we may use identity verification services provided by a third-party provider to verify your identity documents, confirm your identity, and protect against fraud and abuse.

We may also need to process sensitive information, such as health data, in order to support you as a vulnerable customer. This allows us to provide additional assistance if you require extra support due to specific circumstances. For example, we can offer tailored support when you contact customer service.

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 our Services). In this case, we may have to cancel a Service you have with us, but we will notify you if this is the case at the time.

3. How is your personal data collected?

When you use or access our Services, we may collect personal data about you. Sometimes we collect personal data automatically when you interact with our Services and sometimes we collect personal data directly from you. At times, we may collect personal data about you from other sources and third parties.

  • Direct interactions. You may give us your Identity, Image, Contact and Financial Data by filling in forms or by corresponding with us through our website (including when you apply to register with us). This includes personal data you provide when you:
    • apply to use our Services;
    • create a Zilch account;
    • request to make transactions by using our Services;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website or mobile app, we will automatically collect Technical Data about your equipment, browsing actions, device information 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 notice for further details. Third parties or publicly available sources.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
  1. Technical Data from analytics providers such as Google;
  2. Demographic data from advertising sources such as Facebook and Instagram, Twitter, and Google;
  3. Transaction Data from merchants who you make transactions with using our Services;
  4. Affiliate advertising networks such as Awin;
  5. Technical monitoring and error reporting service providers, such as DataDog;
  6. Contact Data, Identity Data and Financial Data (Account Data) from Credit Reference Agencies (CRAs) such as Equifax, TransUnion and Experian. More information about CRAs and how they use your personal information is available at: https://www.transunion.co.uk/crain;
    https://www.equifax.co.uk/crain; and https://www.experian.co.uk/crain.
  7. Confirmation of match Contact Data and Identity Data against public records from KYC (Know Your Customer) providers such as Experian;
  8. Contact, Identity, Technical and Image Data from identity verification providers such as Onfido;
  9. Loan Information Data where our third parties’ debt collection support services help us collect outstanding balance;
  10. Open Banking Data from our third-party providers such as Yapily.
  11. Payment Initiation Service such as Plaid. Identity Data and Contact Data from credit comparison, credit broker and aggregator services, where the Zilch product may be shown and, if you are interested, you will be redirected to Zilch to register and complete your application.

4. 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.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent when the law requires us to do so, for example before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We may use your personal data in de-identified form (de-identification being a process by which we eliminate any personal identifiers and personal details) for research or statistical purposes, business analysis and to assist us in running our business. We may also share de-identified data in aggregated form with third parties for different purposes (i.e., we may aggregate your Usage and Transaction Data and share it with current or prospective retailers). When your personal data is included in anonymised, aggregated data, it becomes impossible to identify you or anything about you from that data.

5. 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. Please 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.

Purpose/ActivityType of dataLawful basis for processing
To register you as a new customer, to verify your identity documents and protect against fraud and abuse    (a) Identity Data
(b) Image Data
(c) Contact Data
(d) Financial
(e) Special Category Data		(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Our legitimate interests in verifying your identity and checking your credit score and history.
(d) Reasons of substantial public interest – to prevent or detect unlawful acts
To assess and approve each proposed transaction related to the Services you request(a) Identity Data
(b) Contact Data
(c) Financial Data

(a) Performance of a contract with you
(b) Our legitimate interests in verifying your identity and checking your credit score and history
To process approved transactions on your behalf(a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data		(a) Performance of a contract with you 
To process rewards, cashback, payments and referral fees(a) Identity
(b) Contact
(c) Financial

(a) Performance of a contract with you
(b) Our legitimate interests in processing and receiving payments owned to us and you 
To manage your account and process repayments that you owe to us(a) Identity Data
(b) Contact Data
(c) Financial Data

(a) Performance of a contract with you
(b) Our legitimate interests in processing repayments for transactions where we have paid on your behalf
To collect and recover money owed to us(a) Identity Data
(b) Contact Data
(c) Financial Data

(a) Performance of a contract with you
(b) Our legitimate interests in pursuing late payment and recovering money that you owe to us
To manage our relationship with you which will include:
(a) notifying you about changes to our terms or privacy notice
(b) asking you to leave a review or take a survey		(a) Identity Data
(b) Contact Data
(c) Profile Data
(d) Marketing and Communications Data		(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests to improve our customers satisfaction by collecting feedback
To process, manage and investigate and resolve any claim or complaint raised by you(a) Identity Data
(b) Contact
(c) Financial

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation

To support our ongoing reporting and usage of Credit Reference Agency data(a) Identity Data
(b) Contact Data
(c) Financial Data		(a) Necessary to comply with a legal obligation
To retain records of our financial transactions and contracts with you in order to maintain adequate accounting records and meet legal requirements(a) Identity Data
(b) Contact Data
(c) Financial Data

(a) Necessary to comply with a legal obligation
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity Data
(b) Contact Data
(c) Technical Data		(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)

To use data analytics to improve our website, products/Services, customer relationships and experiences(a) Technical Data
(b) Usage Data		(a) Necessary for our legitimate interests (to define types of customers for our products and Services, to keep our website updated and relevant and to develop our business strategy)

To make suggestions and recommendations to you about goods or Services that may be of interest to you, and/or to send you other types of marketing communications(a) Identity Data
(b) Contact Data
(c) Technical Data
(d) Usage Data
(e) Profile Data
(f) Marketing and Communications Data		(a) Consent (if we are sending you marketing by text or email)
(b) Necessary for our legitimate interests (to develop our products/Services and grow our business)
To be able to help you as a vulnerable customer (i.e. if you need extra support when contacting us due to particular circumstances).  (a) Special Category Data(a) Legitimate interest, and
(b) Explicit consent, or
(c) Reasons of substantial public interest – Economic well-being, if it’s necessary to protect your economic well-being if you are at risk and you cannot give explicit consent or if this cannot be obtained reasonably.
To access details about accounts you hold with other banks so we can make lending decisions (open-banking)(a) Identity Data
(b) Contact Data
(c) Financial Data		(b) Consent
To facilitate payment initiation service (PIS), allowing you to make payments to Zilch directly from your bank account as an alternative to using a debit or credit card(a) Identity Data
(b) Financial Data		(a) Consent
To ensure account safety, including protecting you from fraud. This includes:   

(a) To prevent, detect, or protect against actual or suspected fraud, unauthorised transactions, claims, liability, and financial or other crimes.  
(b) To keep our anti-fraud measures effective, we can’t always share all the details about how we prevent fraud; 
(c) As part of our efforts to keep our Services safe and secure  		(a) Identity Data
(b) Usage Data
(c) Contact Data
(d) Technical Data
(e) Special Category Data		(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation 
(c) Necessary for our legitimate interests to detect, prevent, and investigate fraud, money laundering and other crimes to protect our business and our customers.  
To ensure your device is secure and has not been tampered with, we check its integrity when you launch our app (for example, to see if it is jailbroken or rooted). This helps us protect your account, prevent fraud, and keep our services safe(a) Technical Data(a) Necessary for our legitimate interests to detect and prevent fraud and to safeguard our services. This includes ensuring that our app operates only in secure environments, protecting our systems from misuse.
To deliver targeted advertising and competitions on social media platforms and other advertising networks (using customer data matched with platform data)


(a) Identity Data
(b) Contact Data


(a) Necessary for our legitimate interests to promote our products, services, and competitions while respecting your right to object.  

Marketing

We may contact you about product or Services offered by us. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may opt out of receiving marketing communications at any time by responding via the channel in which you received the marketing communication, or by contacting us at [email protected]

Promotional offers from us

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 products, Services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or requested to use our Services and you have not opted out of receiving that marketing.

Competitions and Prize Draws
Our competitions and prize draws may be open to both Zilch customers and non-customers. When you enter, we use your personal data to run the promotion, check eligibility, select and contact winners, and deliver prizes or rewards. This may include your name, contact details, Zilch account and, for social media competitions, your social media information or delivery details. We may share limited information with trusted partners who help administer the competition or deliver prizes.

Opting out

You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you, by contacting us at any time.

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 our cookie notice.

6. Automated Decision Making

We use your personal data for solely automated decision-making. We receive credit score information from credit reference agencies and use it to assess whether a credit limit is appropriate for you, and what that limit should be. We may also use automated decision-making during your relationship with us to review and adjust your credit limit.

You have the right to request a manual review of any such decision by a person. You can also share your perspective and challenge the outcome. If you would like us to review a decision, you can contact us by emailing [email protected]

7. 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 above.

  • Merchants, to process your purchases, refunds and rewards.
  • Credit reference agencies, to assess your creditworthiness, report late or missed payments, and to inform them (monthly) about your account status.
  • Professional and advisory service providers, including, lawyers, auditors, accountants, and other professional advisors and consultants who support our operations.
  • Service providers for activities such as web- and app-hosting services, website optimisation services, website usage service, email service provision, mobile push notification services, data management platform provision, digital gift card distribution services, customer relationship management services, marketing tracking partners, messaging services, social media platforms, online and offline marketing services, research and profiling services, to handle, store or use certain personal data on behalf of us.
  • Advertisers and advertising networks to select and serve relevant advertisements to you and others. This includes social media networks (with whom we share data like your mobile number and email address in a secure format) so they can match this to personal data they already hold about you. They can then display messages to you and others about our products and services, or make sure you do not get irrelevant ads (for example, if you’re already using the Zilch product that we want to advertise).
  • Our affiliates and partners involved in transactions, to make funds available, and to provide cashback and rewards.  Affiliate Networks-when you click on a sponsored link or make a purchase for Zilch rewards on our website and/or mobile app, you may be redirected to another company’s website via a third-party affiliate network. These networks process your personal information in accordance with their own privacy policies. The affiliate network that processes your data is determined by the store you visit through the sponsored link, and typically, each store partners with just one network.
  • Regulators, law enforcement agencies, and public authorities, including judicial and administrative courts, if we are under a duty to disclose or share your personal data in response to a court order, properly constituted police request or as otherwise required by law, or in order to enforce or apply our customer agreement and other applicable agreements, or to protect the rights, property, or safety of Zilch, our customers, our employees, or others.
  • Fraud prevention agencies and providers of fraud prevention services to prevent, detect, or protect against actual or suspected fraud, unauthorised transactions, claims, liability, and financial or other crimes, including conducting or co-operating with investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so, or where required by law.
  • CIFAS: The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, see Cifas’ Fair Processing Notice.
  • Debt collection support services or other debt management companies, to support us when you are late in repaying us and to recover debt or in relation to your insolvency.
  • Open banking providers, to allow transactions [Banks or other financial institutions]  to provide you our services (such as supporting the execution of payments, or provision of the Zilch account). These third parties act as independent, separate data controllers who determine why and how they will process your data.
  • Business process outsourcing providers (BPOs), who support us in delivering our services (for example, customer support, IT services).
  • VISA, payment and digital wallet providers, we share information about you and your purchases when you use the Zilch card with VISA and members of the VISA card network. If you add your Zilch card to your digital wallet, or choose to make payments via Zilch through your digital wallet, we may need to share your information with the provider of that wallet. In such cases, your data will be processed in accordance with the wallet provider’s privacy notice.
  • Consumer loan comparison sites or credit broker service that Zilch partners with, we may share information about what Loan rates we might offer you.
  • Other Zilch companies may assist in providing our Services to you, improving our operations, and supporting business functions such as customer support, technology, marketing, fraud prevention and compliance.
  • 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 notice.

We require all third parties to respect the security of your personal data and process it in accordance with the law. Some third parties may act as independent controllers, while others may process your personal data on our behalf as data processors. In both cases, we ensure that any processing is carried out for specified purposes and complies with applicable data protection laws. 

8. International transfers

We may store or transfer your personal data we collect from you to locations outside the UK. This includes transferring your personal data to organisations based in other countries. When we do this, we ensure that your data remains protected by taking appropriate safeguards, including:

Adequacy Decisions: Confirming that the UK Government has deemed the destination country or organisation to provide an adequate level of protection for personal data.

Approved Contracts: Where no adequacy decision exists, we use specific contracts approved for use in the UK, such as the UK International Data Transfer Agreement, which provide your data with the same level of protection it has in the UK.

These transfers are always carried out in compliance with the UK Data Protection Laws.

If you would like further information about how we transfer and protect your personal data, please contact us at [email protected]

9. 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. 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.

Access to your Account is password-protected for your privacy and security. While we do our best to protect your personal information you also must protect yourself. What does this mean?

  • Keep your password or other access information secret.
  • Ensure no-one else uses your account or our Services while your machine is “signed in” to our site or app.
  • Make sure you sign out from your Account when not using it.

10. Data retention

How long will you use my personal data for?

We will only keep your personal data for as long as necessary to fulfil the purposes for which we collected it. This includes meeting legal, regulatory, tax, accounting, or reporting obligations.

By law, we must retain certain personal data for at least seven years after your account is closed. After this period, the information will be securely deleted or anonymised so it can no longer be linked to you.

In some circumstances, we may retain your personal data for a longer period. This may occur where it is necessary for anti-money laundering checks, fraud prevention, the establishment or defence of legal claims, or if we reasonably believe there is a prospect of litigation relating to our relationship with you. In such cases, retention will be based on legal requirements or our legitimate business interests.

When determining how long to retain your personal data, we consider factors such as why we hold it, how sensitive it is, and the potential risk of harm from unauthorised use or disclosure.

11. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

  • Request access to a copy of your personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of any inaccurate or incomplete personal data that we hold about you, provided such correction is verified by us.  
  • Request erasure of your personal data, however, we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you.
  • Object to processing of your personal data where we are relying on a legitimate interest, if you feel it impacts on your fundamental rights and freedoms, or if we are processing your personal data for direct marketing purposes.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain scenarios.
  • Request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format.
  • 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.
  • You have the right to request a human review if Zilch makes an automated decision that has a legal effect on you or significantly affects you in a similar way.
  • Lodge a complaint with the Information Commissioner’s Office. We ask that you first contact us to give us an opportunity to address any concerns.

If you wish to exercise any of the rights set out above, please contact us at [email protected]

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.

How to make a complaint

If you have a complaint or concern about how we handle your personal data, please contact us first so we have the opportunity to resolve the issue. You can get in touch through the Zilch app or by emailing us at [email protected]

If you are not satisfied with our response, 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. For more information on how to do this, please visit their website: www.ico.org.uk

Last update: January 2026