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Terms of Use

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First Published: 09/01/2024
Last Updated: 09/01/2024

1. Introduction

1.1 Purpose of the Document:

This document (“Terms of Use”) sets out the terms under which users (“you”) may access and use the Be. Website along with other websites owned and operated by Blukite Group Limited & Blukite Finance Limited (Blukite) (“we,” “our,” or “us”). These terms are designed to ensure a clear understanding of the legal agreement between you and Be. when you use our websites.

1.2 Applicability to Websites:

These Terms of Use apply to Be. Cards Limited (Be.). This includes, but is not limited to, the following websites:

By accessing any of these websites, you agree to comply with and be bound by these terms. It is important that you read this document carefully as it affects your legal rights and obligations.

2. Acceptance of Terms

2.1 Agreement to Terms:

By accessing, browsing, or otherwise using any of the websites operated by Be., you acknowledge that you have read, understood, and agree to be bound by these Terms. If you do not agree with any part of these terms, you must not use our websites.

2.2 Legal Capacity:

In agreeing to these Terms, you represent and warrant that you have the legal capacity to enter into a binding contract. If you are using the websites on behalf of an organisation or entity, you confirm that you have the authority to bind such organisation or entity to these terms.

2.3 Changes to Terms:

We reserve the right to modify or replace these Terms at any time as we deem necessary. It is your responsibility to review these terms periodically for changes. Your continued use of the websites following the posting of any changes to these Terms constitutes acceptance of those changes.

3. User Rights and Responsibilities

3.1 Acceptable Use of the Websites:

You agree to use our websites only for lawful purposes and in a way that does not infringe the rights of, restrict or inhibit anyone else’s use and enjoyment of the websites. Prohibited behaviour includes, but is not limited to:

  • Harassing or causing distress or inconvenience to any other user.
  • Transmitting obscene or offensive content.
  • Disrupting the normal flow of dialogue on the websites.
  • Engaging in conduct that affects the operational performance of the websites.

3.2 User-Generated Content:

If our websites allow you to post content, such as comments, reviews, or articles:

  • You retain all of your ownership rights in your content, but you grant us a non-exclusive, royalty-free, perpetual, and worldwide license to use, store, and copy that content and to distribute and make it available to third parties.
  • You must ensure that your content does not violate any applicable laws or rights of others, including intellectual property rights and privacy rights.
  • We have the right to remove any posting you make on our websites if, in our opinion, your post does not comply with our content standards.

3.3 Responsibility for Account Security:

Where applicable, you are responsible for maintaining the confidentiality of your account details and for all activities that occur under your account. You agree to immediately notify us of any unauthorised use of your account or any other breach of security.

3.4 Reporting Infringements:

If you believe that any content on our websites infringes upon your rights or the rights of others, please contact us with detailed information about the infringement.

4. Modification of Terms

4.1 Right to Modify Terms:

Be. reserves the right, at our discretion, to change, modify, add, or remove portions of these Terms at any time. Such changes shall be effective immediately upon posting unless otherwise specified. We may update our Terms and Conditions to reflect changes in our practices, technologies, legal requirements, or other factors.

4.2 Responsibility to Review Changes:

It is your responsibility to check these Terms for changes. Your continued use of the websites following the posting of changes will mean that you accept and agree to the changes. If you do not agree to the updated terms, you should discontinue your use of the websites.

4.3 Notification of Changes:

Whenever significant changes are made to these Terms; we will endeavour to notify you by prominent notice on the websites or by sending an email to the address you have provided to us. However, it remains your responsibility to review the terms regularly to stay informed of any changes.

4.4 Effective Date of Changes:

The date of the last modification of these Terms will be indicated at the top of this document, making it easy for users to ascertain when the last update was made.

5. Privacy and Data Protection

5.1 Commitment to Data Protection:

Be. Is committed to protecting the privacy and security of our users’ personal information. Our practices are in strict compliance with the General Data Protection Regulation (GDPR) and other relevant data protection laws.

5.2 Data Collection and Usage:

  • Personal Data Collection: We collect personal data when you use our websites, such as name, email address, and contact information. The collection of this data is essential for providing our services, processing transactions, and for internal analytical purposes.
  • Purpose of Data Collection: The data collected is used to improve our websites, tailor the user experience, communicate with users, and comply with legal obligations.
  • Cookies and Tracking Technologies: Our websites use cookies and similar tracking technologies to monitor user interactions and preferences. Users have the choice to accept or decline cookies.

5.3 Data Sharing and Disclosure:

  • We do not sell, trade, or otherwise transfer your personal data to outside parties except when necessary for providing a service you have requested, for legal compliance, or in the event of a business transfer such as a merger or acquisition.
  • Third-party service providers used by us will only receive the necessary information to perform their services and are obligated not to disclose or use the information for other purposes.

5.4 User Rights:

  • Under GDPR and other data protection laws, users have rights regarding their personal data, including the right to access, rectify, erase, restrict processing, and object to processing, as well as the right to data portability.
  • Users can exercise these rights by contacting us using the information provided in the Contact section of the websites.

5.5 Data Security:

  • We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information.

5.6 Changes to Privacy Practices:

  • If there are any changes to our privacy practices, they will be communicated through our websites and, where appropriate, through direct communication with users.

5.7 Contact Information:

  • For any questions or concerns regarding privacy and data protection, users can contact us through the designated channels provided on our websites.

6. Intellectual Property Rights

6.1 Ownership of Website Content:

  • Ownership: All content present on the websites of Be., including but not limited to text, graphics, logos, images, audio clips, digital downloads, and software, is the property of Blukite or its content suppliers and is protected by international copyright and intellectual property laws.
  • Use of Content: The compilation of all content on these websites is the exclusive property of Be.. Unauthorised use of any content or materials on the websites for any purpose is strictly prohibited and may result in legal action.

6.2 Trademarks:

  • Trademarks: The trademarks, logos, and service marks displayed on the websites, including the name ‘Be.‘ and its logo, are registered and unregistered trademarks of Be.. Nothing contained on the websites should be construed as granting any license or right to use any trademark without the prior written permission of Be..
  • Use of Trademarks: Any use of trademarks on any other website or network computer environment, for example, the storage or reproduction of the website in any external internet site or the creation of links, hypertext, links, or deep links between the website and any other internet site, without the written permission of Be., is prohibited.

6.3 Copyrighted Material:

  • Respect for Copyright: Users of the websites must respect the intellectual property rights of others. The use of copyrighted material on the websites without the express permission of the copyright owner is not permitted.
  • Infringement Notifications: If you believe that your work has been copied in a way that constitutes copyright infringement, or if you are aware of any infringing material on the websites, please contact us with detailed information about the infringement.

7. User Conduct and Restrictions

7.1 Acceptable User Conduct:

  • Respectful Interaction: Users must engage with the websites and other users respectfully and responsibly. This includes refraining from using offensive language, harassment, or other disruptive behaviours.
  • Legal Compliance: Users must comply with all applicable local, national, and international laws and regulations while using the websites.

7.2 Prohibited Behaviours:

  • No Illegal Activities: Users must not engage in any illegal activities on the websites, including but not limited to fraud, money laundering, or the distribution of malicious software.
  • No Harmful Content: Users must not upload, post, or otherwise transmit any content that is unlawful, harmful, threatening, abusive, harassing, tortious, defamatory, vulgar, obscene, libelous, invasive of another’s privacy, hateful, or racially, ethnically, or otherwise objectionable.
  • No Interference with Operations: Users must not interfere with or disrupt the websites or servers or networks connected to the websites, nor disobey any requirements, procedures, policies, or regulations of networks connected to the websites.

7.3 User-Generated Content Guidelines:

  • Content Ownership: Users retain ownership of any content they submit, post, display, or otherwise make available on the websites.
  • Content Responsibility: Users are responsible for their content, including its legality, reliability, and appropriateness.
  • License to Use User Content: By posting content, users grant Be. a non-exclusive, worldwide, royalty-free, sublicensable, and transferable license to use, reproduce, distribute, prepare derivative works of, display, and perform the content in connection with the websites and Be.‘s business.

7.4 Reporting Violations:

  • Notice of Infringements: Users are encouraged to report any violations of these conduct and content guidelines to Be.. Appropriate measures will be taken to address such reports.

8. Links to Third-Party Websites

8.1 External Links Disclaimer:

  • Presence of Third-Party Links: The websites operated by Be. may contain links to third-party websites that are not owned or controlled by Be.. These links are provided for your convenience to provide further information.
  • No Endorsement: The inclusion of any links does not necessarily imply a recommendation or endorse the views expressed within them. Be. has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third-party websites.

8.2 User Responsibility:

  • Due Diligence: We encourage our users to be aware when they leave our websites and to read the terms and conditions and privacy policy of any other website that they visit.
  • Risks and Liabilities: You acknowledge and agree that Be. shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with the use of or reliance on any such content, goods, or services available on or through any such third-party websites.

8.3 No Affiliation:

  • Independent Entities: Any dealings with third parties (including advertisers) included within the Be. websites or participation in promotions, including the delivery of and the payment for goods and services, and any other terms, conditions, warranties, or representations associated with such dealings or promotions, are solely between you and the advertiser or other third party. Be. is not responsible or liable for any part of any such dealings or promotions.

9. Disclaimers and Limitation of Liability

9.1 Accuracy of Information:

  • No Warranty for Accuracy: While Be. strives to ensure that the information on our websites is accurate and up to date, we do not warrant or make any representations regarding the accuracy, reliability, or completeness of the information, content, materials, or products included on our sites.
  • Use at Your Own Risk: Any reliance you place on such information is strictly at your own risk. We disclaim all liability and responsibility arising from any reliance placed on such materials by you or any other visitor to our websites, or by anyone who may be informed of any of its contents.

9.2 Website Availability:

  • Service Interruptions: Be. does not guarantee that our websites, or any content on them, will always be available or be uninterrupted. Access to our websites is permitted on a temporary basis, and we reserve the right to withdraw, suspend, discontinue, or change all or any part of our websites without notice.
  • No Liability for Unavailability: We will not be liable to you if for any reason our websites are unavailable at any time or for any period.

9.3 Limitation of Liability:

  • Limitation for Direct Damages: In no event will Be., its directors, employees, partners, agents, suppliers, or affiliates, be liable for any direct, indirect, incidental, special, consequential, or punitive damages, including without limitation, loss of profits, data, use, goodwill, or other intangible losses, resulting from (i) your access to or use of or inability to access or use the websites; (ii) any conduct or content of any third party on the websites; (iii) any content obtained from the websites; and (iv) unauthorised access, use, or alteration of your transmissions or content, whether based on warranty, contract, tort (including negligence), or any other legal theory, whether or not we have been informed of the possibility of such damage.
  • Acknowledgement of Terms: Your use of our websites is at your sole risk. The services and products provided on our websites are provided on an “as is” and “as available” basis.

10. Indemnification

10.1 User Agreement to Indemnify:

  • Scope of Indemnification: You agree to indemnify, defend, and hold harmless Be., its directors, officers, employees, consultants, agents, and affiliates, from any and all third-party claims, liability, damages, and/or costs (including, but not limited to, legal fees) arising from your use of our websites, your breach of these Terms and Conditions, or your infringement of any intellectual property or other rights of any person or entity.

10.2 Defence and Control of Claims:

  • Cooperation in Defence: In the event of any claim for which we are entitled to indemnification under this clause, we will (i) provide you with reasonable written notice of the claim; (ii) give you sole control of the defence and settlement of the claim (provided that you may not settle or defend any claim unless you unconditionally release us of all liability and such settlement does not affect our business or service); and (iii) provide to you all reasonable assistance, at your expense.

10.3 Limitation on Indemnification:

  • Exclusions: The indemnification obligation does not apply if the claim for damages result from our own negligence, fraud, wilful misconduct, or any other actions by us that are not in compliance with these Terms and Conditions.

11. Governing Law and Jurisdiction

11.1 Governing Law:

  • Applicable Law: These Terms and Conditions and any separate agreements whereby we provide you services shall be governed by and construed in accordance with the laws of England and Wales, without regard to its conflict of law provisions.

11.2 Jurisdiction for Disputes:

  • Resolution of Disputes: Any disputes or claims arising out of or in connection with these Terms and Conditions, including disputes relating to its validity, breach, termination, or nullity, shall be subject to the exclusive jurisdiction of the courts of England and Wales.
  • User Acknowledgement: By using our websites, you agree that the courts of England & Wales will have exclusive jurisdiction to resolve any disputes or claims.

11.3 International Use:

  • International Application: We make no representation that our websites are appropriate or available for use in locations outside of England and Wales and accessing them from territories where their contents are illegal is prohibited.
  • Compliance with Local Laws: Users who choose to access our websites from other locations do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable.

12. Dispute Resolution

12.1 Initial Attempt to Resolve Disputes:

  • Informal Resolution: Before filing a claim against Be., you agree to try to resolve the dispute informally by contacting us. We will try to resolve the dispute informally by contacting you via email.

12.2 Formal Dispute Resolution:

  • Arbitration Agreement: If the dispute is not resolved within a specified period (e.g., 30 days) after the initial contact, either you or Be. may initiate formal proceedings. You agree that any unresolved disputes will be resolved by final and binding arbitration, except as otherwise provided in these Terms and Conditions.

12.3 Arbitration Process:

  • Arbitration Rules: The arbitration will be conducted by a neutral arbitrator, in accordance with the rules of an established arbitration institution, The Chartered Institute of Arbitrators, which are hereby incorporated by reference.
  • Arbitration Venue: The arbitration will take place in London or Cardiff, or another mutually agreed location.

12.4 Exceptions to Arbitration:

  • Small Claims Court: Either party may bring a claim in a small claims court for disputes or claims within the scope of that court’s jurisdiction.
  • No Class Actions: You may only resolve disputes with us on an individual basis and may not bring a claim as a plaintiff or a class member in a class, consolidated, or representative action.

12.5 Governing Law in Arbitration:

  • Applicability of Jurisdiction Law: The arbitration shall be governed by the same governing law as mentioned in Section 11.1.

12.6 Costs of Arbitration:

  • Arbitration Fees: The payment of filing, administration, and arbitrator fees will be governed by the arbitration institution’s rules, unless otherwise stated in this agreement.

13. Miscellaneous Provisions

13.1 Severability:

  • Validity of Remaining Provisions: If any provision of these Terms and Conditions is found by a court or other binding authority to be invalid, you agree that every attempt shall be made to give effect to the parties’ intentions as reflected in that provision, and the remaining provisions contained in these Terms and Conditions shall continue in full force and effect.

13.2 Entire Agreement:

  • Comprehensiveness of Terms: These Terms and Conditions constitute the entire agreement between you and Be. regarding the use of the websites, superseding any prior agreements between you and Be. relating to your use of the websites.
  • Exclusion of Other Agreements: The failure of Be. to exercise or enforce any right or provision of these Terms and Conditions shall not constitute a waiver of such right or provision unless acknowledged and agreed to by Be. in writing.

13.3 Non-Waiver of Rights:

  • Continued Effectiveness of Rights: The failure of Be. to insist upon or enforce strict performance of any provision of these Terms and Conditions or to exercise any right under them shall not be construed as a waiver or relinquishment of Be.‘s right to assert or rely upon any such provision or right in that or any other instance.
  • Ongoing Right to Enforce Terms: The express waiver by Be. of any provision, condition, or requirement of these Terms and Conditions shall not constitute a waiver of any future obligation to comply with such provision, condition, or requirement.

14. Contact Information

14.1 Contacting Be.:

  • Queries and Concerns: If you have any questions, concerns, or comments about these Terms and Conditions, please feel free to contact us. We value your feedback and are committed to addressing any issues or queries you may have.
  • Contact Methods: You can reach us in the following ways:
    • Email: [email protected]
    • Postal Address: Tondu Enterprise Centre, Bryn Road, Aberkenfig, Bridgend, CF32 9BS
  • Online Contact Form: Online contact tabs are available on all our websites for your convenience. Simply visit any of our websites and look for the contact tab to send us your queries or feedback.
  • In-App Chat Facilities: For users of our apps, we also offer in-app chat facilities, allowing for real-time communication and support.

14.2 Response Time:

  • Acknowledgement of Queries: We strive to respond to all queries in a timely manner. Please allow us a reasonable time frame, we aim to respond within 2 business days to your enquiries.

15. Accessibility Statement

15.1 Commitment to Accessibility:

  • Inclusivity:  Be. is committed to making its websites accessible to the widest possible audience, regardless of technology or ability. We are continually working to increase the accessibility and usability of our websites and in doing so, adhere to many of the available standards and guidelines.
  • Conformity with Standards: Our goal is to conform to the guidelines provided by the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA, which set forth how to make web content more accessible for people with disabilities.

15.2 Ongoing Effort:

  • Continuous Improvement: We view accessibility as an ongoing effort and are continuously seeking solutions that will bring all areas of our websites up to the same level of overall web accessibility.
  • Feedback and Suggestions: Should you experience any difficulty in accessing any part of our websites, or if you have suggestions on how we could improve our services in terms of accessibility, please feel free to contact us. Your feedback is invaluable to us.

15.3 Director of Diversity and Inclusion:

  • DDI’s Role: Our Director of Diversity and Inclusion (DDI) plays a key role in ensuring our commitment to accessibility and inclusion across all our platforms.
  • Contacting the DDI: For further assistance, or to offer suggestions regarding our accessibility services, please contact our DDI at [email protected]

15.4 Assistance and Resources:

  • Providing Support: For assistance with any accessibility issues, please reach out using the contact information provided in Section 14. Our team, including the DDI, is ready to provide support and ensure that you can access all content and features on our websites.

16. Effective Date

16.1 Date of Effectiveness:

  • Commencement of Terms: These Terms and Conditions are effective as of January 9th, 2024.
  • Binding from Effective Date: From the above date, these terms will be binding and applicable to all users of the websites operated by Be..

16.2 Acknowledgement of Users:

  • User Awareness: By using our websites from the Effective Date onwards, you acknowledge that you are bound by these updated Terms and Conditions and agree to comply with all its provisions.

17. Update Processes

17.1 Notification of Updates:

  • Automatic Notification: Customers of Be. will be automatically notified of any changes to our legal documents, including but not limited to these Terms of Use, our Privacy Policy, and any other relevant legal agreements or notices.
  • Method of Notification: Notifications will be provided through a method deemed most effective, which may include email communication, notifications within our apps, or a prominent notice on our websites.

17.2 Clarity on Changes:

  • Details of Updates: Each notification will include clear information regarding the nature of the changes, highlighting any significant amendments made to the documents.
  • Effective Date of Changes: The notification will also specify the date from which such changes will become effective, allowing users adequate time to review and understand the implications of the updates.

17.3 User Acknowledgement:

  • Continued Use as Acceptance: By continuing to use our websites, apps, or services after the effective date of these changes, users indicate their acceptance of the updated terms.
  • Encouragement to Review Updates: We encourage all users to carefully review any updates to our legal documents, as continued use of our services constitutes agreement to be bound by these terms.

Closing Statement: Commitment to Fairness and Equity

Be. is steadfastly committed to ensuring that all our customers, suppliers, and team members experience fairness and accessibility in their interactions with our products and services. We believe that providing equitable service is not just a responsibility, but a cornerstone of our business ethos.

Our dedication to creating an inclusive environment extends beyond the mere provision of services; it is woven into the fabric of our corporate identity. We constantly strive to uphold these values in every aspect of our operations, fostering a culture of respect, inclusivity, and equal opportunity for all.

We recognise that our strength lies in our diversity and in our commitment to accommodating the varied needs and expectations of our community. Be. is devoted to continuously enhancing our practices, ensuring that we remain a leader in providing equitable, accessible, and fair services to everyone we serve.

Cookie Policy

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First Published: 09/01/2024
Last Updated: 09/01/2024

1. Cookie Policy of Be. Cards Limited

Welcome to Be. Cards Limited (Be.). This Cookie Policy applies universally to all digital platforms and services offered by Be., including our website, mobile and web-based applications, and our range of credit and payment initiation services, as well as account information services, provided by Blukite Finance. Our use of cookies extends across all these platforms to ensure a seamless and efficient user experience.

Cookies are small text files stored on your device (be it a computer, mobile phone, tablet, or any other device) when you interact with our digital services. They play a crucial role in enhancing website functionality, enabling ease of navigation, and ensuring the efficiency of our web and mobile applications. Additionally, cookies assist us in gathering insights about the usage patterns and preferences of our users, allowing us to tailor our services and content more effectively.

By engaging with any of Be.‘s services or platforms, you agree to the use of cookies as described in this policy. We provide detailed information on the types of cookies we use, their specific purposes, and guidance on how you can manage or remove them, ensuring you have control over your privacy and data.

2. Types and Purposes of Cookies Used at Be.

At Be., our use of cookies is designed to enhance and streamline your experience on our website and applications. Here, we detail the types of cookies we use, their specific functions, and the impact of disabling them:

2.1 Necessary Cookies:

  • Purpose: These are fundamental to the operational integrity of our platforms. They facilitate core functions such as securing user data, managing network traffic, and maintaining user session continuity.
  • Examples: Authentication cookies that keep you logged in, security cookies that protect against malicious activities, and session cookies that ensure consistent user experience.
  • Impact of Disabling: Without these cookies, our platforms may not function properly or securely. For instance, you might encounter frequent disconnections or inability to access certain features.

2.2 Performance Cookies:

  • Purpose: These cookies collect anonymised data about user interactions, providing us with insights into usage patterns, popular content, and potential issues like error messages or slow loading pages.
  • Examples: Cookies that track page visits, user engagement time, and interaction with site features.
  • Impact of Disabling: Opting out of these cookies will not hinder your ability to use our services, but it will limit our capacity to enhance user experience and platform efficiency based on user behaviour analysis.

2.3 Functionality Cookies:

  • Purpose: They remember your individual preferences and settings, offering a more personalised and convenient experience each time you visit.
  • Examples: Cookies that store your language preferences, region selection, or customisations in layout or content display.
  • Impact of Disabling: If these cookies are disabled, you may find that your experience becomes more generic, lacking personalisation. Settings like language or region may need to be reselected on each visit.

2.4 Targeting/Advertising Cookies:

  • Purpose: These cookies are essential for delivering advertising content that is relevant to your interests. They also help us track the effectiveness of our advertising campaigns and control the frequency of ad exposure.
  • Examples: Cookies that analyse which adverts you have seen, how often you have seen them, and how you interact with them.
  • Impact of Disabling: Disabling these cookies means the advertisements you see may be less relevant to your interests. However, it will not reduce the number of ads you see, just their relevance.

Please be aware that disabling cookies, particularly Necessary and Functionality cookies, may significantly affect your user experience and the efficiency of the services we offer.

3. Accessibility & Cookies: Supporting Users with Disabilities and the Ageing Community

At Be., we are committed to ensuring that our digital platforms are accessible and user-friendly for everyone, including people living with disabilities and members of the ageing community. Cookies play a vital role in this commitment by enabling us to optimise our website and applications to suit the diverse needs of all our users.

  • Enhanced Navigation and Readability: Cookies can store user preferences like text size, font preferences, and contrast settings, making our platforms easier to read and navigate for users with visual impairments.
  • Remembering Accessibility Preferences: For users who require specific accessibility settings, functionality cookies remember these preferences. This means that once a user has set their accessibility preferences, our platforms will maintain these settings during subsequent visits.
  • Assistive Technologies Compatibility: We use cookies to ensure that our website and applications function seamlessly with assistive technologies such as screen readers and keyboard-only navigation, offering an inclusive experience for users with mobility or dexterity challenges.
  • User Feedback and Continuous Improvement: By analysing how all our users, including those with disabilities and ageing users, interact with our platforms, we can continuously refine and enhance accessibility features.

We encourage users to enable cookies that support these accessibility functions. However, we also understand the importance of choice and control over personal data. If you choose to disable certain types of cookies, we strive to maintain as much of the accessibility functionality as possible, but some personalisation features may be affected.

Be. is dedicated to ongoing improvement in accessibility and inclusivity, and we welcome feedback from our users to help us in this endeavour.

3.1 Accessibility Support via Chatbot

To further support our commitment to accessibility and user assistance, Be. is pleased to introduce a chatbot feature on our cookie policy page. This feature is designed to provide real-time support and clarification regarding our cookie policy, especially beneficial for users who might have specific questions or need additional guidance.

  • How to Access: The chatbot can be accessed by clicking on the easily identifiable ‘Accessibility Assistance’ (EA) logo located on our cookie policy page.
  • User-Friendly Interaction: The chatbot is designed to be intuitive and user-friendly, offering clear, concise answers to your questions regarding our cookie use, and how it pertains to accessibility and personal preferences.
  • Personalised Assistance: Whether you need more information about a specific type of cookie, help in managing your cookie preferences, or have questions about accessibility options, our chatbot is here to provide tailored assistance.
  • Feedback and Improvement: Your interactions with the chatbot will also help us to continually improve our services and ensure that our cookie policy and practices remain transparent and user centric.

We believe that this chatbot feature will make understanding and navigating our cookie policy more accessible and straightforward, aligning with our goal to create an inclusive digital environment for all our users.

4. Cookie Duration

At Be., we use different types of cookies, each with its own duration on your device. Understanding these durations helps you better manage your data and privacy preferences:

4.1 Session Cookies:

These cookies are temporary and are designed to last only while your browser is open. They are automatically deleted once you close your browser. Session cookies are typically used to maintain your session as you navigate through our website or app, ensuring a consistent and seamless experience.

4.2 Persistent Cookies:

Unlike session cookies, persistent cookies remain on your device for a pre-defined period, even after you close your browser. The duration of these cookies can vary depending on their purpose but is usually set to a standard timeframe that best serves the intended functionality. For example:

  • Functionality Cookies: Might last for several months to remember your preferences and settings between visits.
  • Performance Cookies: Could remain for a year or more to help us understand long-term patterns and improvements.
  • Targeting/Advertising Cookies: These may have varying durations based on the advertising campaigns and are often set by third-party advertising partners.

4.3 Cookie Renewal:

It is important to note that the duration of cookies can be reset. For instance, every time you visit our website or use our app, some persistent cookies may renew, extending their lifespan from that point.

4.4 User Control:

You have control over cookie management on your device. Most web browsers allow you to view, manage, and delete cookies. Remember, deleting or blocking certain types of cookies, especially necessary and functionality cookies, might affect your user experience on our platforms.

At Be., we regularly review and update our cookie practices to ensure they align with best practices and regulatory requirements, keeping the privacy and preferences of our users at the forefront.

5. Third-Party Cookies

In addition to the cookies that we set directly (first-party cookies), Be. also utilises certain third-party cookies on our website and applications. These cookies are set by external companies or services, and their purposes vary from enhancing user experience to providing us with valuable insights or advertising content. Here is an overview of how these third-party cookies operate and their purpose:

  • Analytics Services: We use third-party analytics services, such as Google Analytics, to gain insights into how our services are being used and how we can improve them. These cookies help us understand user behaviour, such as which pages are most frequently visited, how much time users spend on our site, and how they navigate through it.
  • Advertising Partners: Some cookies are set by our advertising partners. They collect data about your browsing habits and interests, allowing us to show you advertising that is more relevant and interesting to you. These cookies also help in limiting the number of times you see an ad and measuring the effectiveness of advertising campaigns.
  • Social Media Plugins: Our website and applications may include social media features, such as the Facebook “like” button or the Twitter “tweet” button. These features may set cookies on your device by these third-party sites to track your use of their services.
  • How They Operate: Third-party cookies are managed by external organisations, and their use of cookies is governed by their respective privacy and cookie policies. We do not have direct control over the information that is collected by these cookies.
  • User Consent and Control: Your consent and preferences regarding third-party cookies can be managed through our cookie consent tool. Additionally, you have the option to adjust your browser settings to block third-party cookies.

Please be aware that if you choose to block or disable third-party cookies, it may impact certain features and functionalities provided by external services on our platforms.

Be. is committed to ensuring transparency in the use of third-party cookies and we encourage users to review the privacy policies of these third-party services for more detailed information.

6. User Consent and Accessibility Assistance

At Be., we are dedicated to making our cookie consent process both legally compliant and accessible to all users, including those with disabilities and the ageing community.

6.1 Consent Mechanism:

Our website and applications feature a cookie consent banner or pop-up upon your first visit. This tool informs you about our cookie usage and allows you to give explicit consent for different cookie categories (Necessary, Performance, Functionality, Targeting/Advertising), along with the option to customise your preferences.

6.2 Accessibility in Consent Process:

  • EA Icon for Additional Assistance: For users who require extra help, clicking on the ‘Enhanced Accessibility’ (EA) icon within the consent banner provides tailored assistance. This can include guidance through the consent process, explanations of cookie functions, and help in setting preferences.
  • Screen Reader and Keyboard Navigation: The consent banner is fully accessible via screen readers and can be navigated using a keyboard, accommodating users with visual or mobility impairments.
  • Design for Visibility and Clarity: High-contrast colours and clear fonts are used for better readability, aiding users with visual impairments.
  • Simple Language: We use straightforward language to make the information easily understandable for everyone, including the ageing population and those not familiar with technical jargon.

6.3 Managing Preferences:

You have complete control over your cookie preferences and can modify them anytime. Detailed instructions are provided in the consent banner and our cookie settings tool.

6.4 Consent Records and Updates:

We maintain a record of your preferences and periodically prompt you to review and confirm your settings to ensure they remain current.

Be.‘s commitment to accessibility is reflected in our user-centric approach to cookie consent. By integrating features like the EA icon, we ensure that our cookie consent process is accessible and easy to navigate for all our users.

7. How to Control and Delete Cookies

At Be., we believe in empowering you to manage your data privacy. You have the ability to control and delete cookies through your web browser settings. Here’s how you can do this in some of the most commonly used browsers:

7.1 Google Chrome:

  • To control cookies: Click the three dots in the top right corner > ‘Settings’ > ‘Privacy and security’ > ‘Cookies and other site data’. Here, you can choose your preferred settings.
  • To delete cookies: Go to ‘Cookies and other site data’ > ‘See all cookies and site data’ > ‘Remove all’.

7.2 Mozilla Firefox:

  • To control cookies: Click the three horizontal lines in the top right corner > ‘Options’ > ‘Privacy & Security’. Under the ‘Cookies and Site Data’ section, adjust your settings.
  • To delete cookies: In the ‘Privacy & Security’ section, go to ‘Cookies and Site Data’ > ‘Clear Data’.

7.3 Safari (for Mac):

  • To control cookies: Go to ‘Safari’ in the menu bar > ‘Preferences’ > ‘Privacy’. Here, you can manage your cookie preferences.
  • To delete cookies: In the ‘Privacy’ tab, click ‘Manage Website Data’ and then ‘Remove All’.

7.4 Microsoft Edge:

  • To control cookies: Click the three dots in the top right corner > ‘Settings’ > ‘Cookies and site permissions’ > ‘Manage and delete cookies and site data’.
  • To delete cookies: Under ‘Manage and delete cookies and site data’, select ‘See all cookies and site data’ > ‘Remove all’.

7.5 Mobile Devices:

  • On mobile devices, you can usually find cookie settings in the browser’s app settings, under ‘Privacy’ or a similar section.

Please note that if you choose to block or delete cookies, it might affect the functionality of our website and the services we offer. Some preferences and settings might be lost, and you may need to re-enter information that was previously stored in cookies.

For more detailed guidance, we recommend referring to the ‘Help’ section of your browser or visiting the browser’s official website.

8. Policy Updates

At Be., we are committed to staying up to date with the latest data protection practices and legal requirements. To reflect this commitment, our cookie policy may be updated periodically.

8.1 Update Frequency:

We review our cookie policy annually to ensure it aligns with any new legal requirements, technological advancements, and best practices in data privacy and protection. Additionally, we may perform more frequent reviews and updates as necessary, especially in response to significant changes in legislation or our own data processing activities.

8.2 Notification of Changes:

Whenever we make changes to our cookie policy, we will take steps to ensure you are informed:

  • Notification on Website/App: A notification will be displayed on our website and within our applications informing you of any significant changes to our cookie policy.
  • Email Communication: For registered users, we may also send an email notification outlining the key changes and how they may affect you.
  • Clear and Accessible Updates: All updates will be clearly indicated in the policy document, with major changes summarised at the beginning for ease of understanding.

8.3 Version and Date:

Each update to our cookie policy will include the version number and the date of the most recent revision, so you can easily track any changes made.

8.4 Ongoing Accessibility:

We are committed to ensuring that notifications of policy updates are accessible to all users, including those with disabilities or those part of the ageing community. Notifications will be compatible with screen readers and other assistive technologies, and presented in clear, easy-to-understand language.

We encourage you to review our cookie policy periodically to stay informed about how we use cookies and protect your data. Your continued use of our website and services after any changes indicates your acceptance of these updates.

9. Contact Information

We at Be. value open communication with our users. If you have any questions, concerns, or need further clarification about our cookie policy, please feel free to contact us. Our team is ready to assist you with any inquiries you may have.

  1. Email: For direct communication, you can email us at contact@be.cards We aim to respond to all email inquiries within 48 hours.
  2. Online Contact Form: You can also reach us through the contact form available on our website. Just fill in your details and query, and we will get back to you as promptly as possible.
  3. Mailing Address: For written correspondence, feel free to send your letters to Be. Cards Limited, Unit 36-37 Tondu Enterprise Centre Bryn Road, Aberkenfig, Bridgend, Wales, CF32 9BS.
  4. Accessibility Support: If you require any assistance due to a disability or need an accessible format of our cookie policy, please let us know, and we will be happy to accommodate your needs.

We encourage you to reach out with any feedback or inquiries regarding our cookie usage. Your input is valuable to us and helps in enhancing our services and policies.

10. Legal Compliance and Framework

Be. is committed to upholding the highest standards of data privacy and protection, ensuring our cookie policy and practices comply with all applicable laws and regulations. This includes adherence to major data protection regulations such as the General Data Protection Regulation (GDPR) and the ePrivacy Directive, among other regional laws.

  • GDPR Compliance (Regulation (EU) 2016/679): Our use of cookies aligns with the GDPR’s principles, focusing on lawfulness, fairness, transparency, and the safeguarding of individual rights. We obtain clear and affirmative consent for any cookies that are not strictly necessary for the operation of our platforms. For more details, users can refer to the official GDPR text.
  • ePrivacy Directive (2002/58/EC): In line with this Directive, we ensure that our users are fully informed about the use of cookies and similar technologies on our platforms, and that their consent is obtained where required. This Directive’s provisions guide our approach to obtaining and managing user consent.
  • Adaptability to Regional Laws: We recognise that data protection laws can vary by region. Thus, our policies and practices are regularly reviewed and adjusted to conform to any new legal requirements or changes in existing laws.
  • User Rights and Data Protection: Respecting and facilitating user rights, such as the right to access, correct, or delete personal data, is a cornerstone of our policy. We are proactive in ensuring our practices enable these rights effectively.
  • Continuous Monitoring and Training: Our team is continuously educated on the latest in data protection laws and regularly monitors our compliance with these laws to ensure our practices are up to date.

Be.’s dedication to legal compliance in data privacy is unwavering. For any concerns or inquiries regarding our compliance with data protection laws, please feel free to contact us. We are committed to addressing all queries and ensuring our users’ data is handled responsibly and in line with all legal standards.

Closing Statement

Thank you for taking the time to understand our Cookie Policy at Be.. We are deeply committed to respecting your privacy and ensuring the highest standards of data protection. Our use of cookies is designed to enhance your experience on our platforms, always keeping in mind the importance of your privacy and the trust you place in us.

We encourage you to revisit this policy periodically for any updates, as we continually strive to improve our practices and maintain transparency. Your continued use of our website and services signifies your understanding and acceptance of this policy.

If you have any questions, concerns, or feedback about this policy or how we handle your data, please do not hesitate to contact us. We value your opinions and are always here to assist you.

Privacy Policy

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First Published: 09/01/2024
Last Updated: 09/01/2024

1. Introduction to Be. Group Limited’s Privacy Policy

Welcome to Be.™ Rewards and Credit! Your privacy and trust are paramount to us and to our subsidiaries and affiliate partners, collectively referred to hereinafter as ‘Be.‘. This Privacy Policy is crafted to help you understand how Be. collects, uses, protects, and shares your personal information across all our operations, and to inform you about your privacy rights.

As a service provider operating under various entities and partnerships, we understand the importance of a unified approach to privacy and data protection. This policy reflects our commitment to safeguard your personal information across all branches of Be. Cards Limited, ensuring consistency and reliability in how we handle your data, no matter which part of our group subsidiaries you interact with.

1.1 What is a Privacy Policy?

This Privacy Policy is a statement or a legal document that explains how our organisation collects, handles, stores, and protects your personal data. It serves as a pledge of our commitment to safeguard your privacy and ensure that your personal information is handled responsibly.

1.2 Why is a Privacy Policy Necessary?

Respecting user privacy is not just a matter of ethics; it’s a legal requirement. A Privacy Policy is essential for several reasons:

  • Legal Compliance: It ensures that we comply with the law. In the United Kingdom, data protection and privacy are governed by the General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018. These laws mandate organisations to transparently disclose how personal data is collected, used, and managed.
  • Transparency: It builds trust with you, our users, by being transparent about how we use your personal data.
  • User Empowerment: It empowers you to make informed choices about the use of your data, providing clarity on your rights, including the right to access, rectify, and erase your personal data.

1.3 UK Legislation Governing Privacy Policies

In the UK, the key pieces of legislation that require the use of Privacy Policies are:

  • General Data Protection Regulation (GDPR): As a regulation in EU law on data protection and privacy, GDPR impacts UK businesses as it sets guidelines for the collection and processing of personal information from individuals who live in the European Union.
  • UK Data Protection Act 2018: This Act controls how personal information is used by organisations, businesses, or the government. It is the UK’s implementation of the GDPR.

We are committed to upholding these legal standards, ensuring the highest level of data protection and privacy for our customers.

1.4 Point of Contact for GDPR and Data Protection Inquiries

At Be., we take your privacy and the protection of your personal data seriously. To ensure transparency and address any concerns or queries you may have regarding data protection and your rights under GDPR, we have designated a specific point of contact.

Data Protection Officer:

Dr. Ian Vickers is appointed as the person responsible for overseeing GDPR compliance and data protection strategies within Be.. He is committed to ensuring that your personal data is protected and processed in accordance with the relevant data protection laws.

Contacting Dr. Ian Vickers:

Should you have any questions, requests, or concerns regarding how we handle your personal data, or your rights under the GDPR, Dr. Ian Vickers can be reached through the following means:

  • Email: You can contact Dr. Vickers directly at contact@Be.cards. This email address is monitored regularly to ensure timely responses to your data protection inquiries.
  • Via Be.’s Websites: You can also reach out to Dr. Vickers through the contact forms available on any of Be.‘s websites. Simply mention your GDPR or data protection query, and your message will be directed to him.

We encourage you to reach out with any questions or concerns you may have regarding your personal data. Be. is committed to ensuring that your privacy rights are respected and upheld.

2. How We Use Your Personal Information

Your personal information is handled with utmost care and responsibility by Be.. This section of our Privacy Policy is dedicated to explaining our commitment to safeguarding your personal information. It encompasses the details you share with us, the insights we gain while you are a customer, and the preferences you set regarding our marketing communications.

2.1 Our Promise to You:

  • Transparency and Control: We pledge to be transparent about the data we collect and how we use it, ensuring that you have control over your personal information.
  • Learning from Our Interactions: The information we gather through our interactions with you, as a customer, helps us tailor our services and improve your experience.
  • Marketing Preferences: We respect your choices regarding the marketing communications you wish to receive. You will have the option to opt-in or opt-out of our marketing messages, in accordance with your preferences.

2.2 Your Privacy Rights:

  • Access and Rectification: You have the right to access the personal information we hold about you and to request corrections if any details are inaccurate.
  • Data Portability and Erasure: You can request the transfer of your data in a structured, commonly used format, and under certain conditions, you may also request the deletion of your personal information.
  • Objection and Restriction: You have the right to object to certain types of processing of your personal data and to request restrictions on how we use your information.

2.3 Legal Protection and Compliance:

  • Adherence to Laws: Our practices are designed to comply with applicable data protection laws, including the GDPR and the UK Data Protection Act 2018. These laws provide a framework that ensures your data is processed lawfully, fairly, and transparently.
  • Security Measures: We implement robust security measures to protect your data against unauthorised access, alteration, disclosure, or destruction.

This privacy notice is reflective of our commitment to upholding your privacy rights and safeguarding your personal data in accordance with the law.

2.4 Our Privacy Promise

At Be., we are deeply committed to the privacy and security of your personal information. Our promise to you encompasses the following key principles:

  • Safeguarding Your Information: We pledge to keep your personal information safe and private. We employ advanced security measures to protect your data against unauthorised access, disclosure, alteration, or loss.
  • Respect for Your Personal Data: We assure you that we will not sell your personal information to third parties. Our respect for your privacy is integral to our ethics and operations.
  • Control Over Marketing Communications: You have complete autonomy to manage and review your marketing preferences at any time. We provide easy and accessible ways for you to adjust these choices, ensuring that you receive marketing communications only as per your consent.

In addition to these promises, we are continuously monitoring and updating our practices to align with evolving data protection laws and standards. Our goal is to not only comply with legal requirements but to exceed them in safeguarding your privacy.

3. Personal Information and the Law

3.1 Who We Are

Be. Cards Limited is the legal entity that holds and processes your personal information, committed to managing it responsibly and lawfully.

3.2 Contacting Us About Data Privacy

If you have questions or need more information about how we use your personal information, there are several convenient ways to get in touch with us:

  • In-App Chat: For immediate assistance, you can use our in-app chat feature. This is a quick and easy way to get responses to your data privacy questions.
  • Website Contact Form: Visit our website and use the contact form for your queries. This method is suitable for detailed questions or feedback.
  • Direct Contact with Data Protection Officer: If your query is specific to data protection or if you are not satisfied with the initial response, you can directly message our Group Data Protection Officer as detailed in Section 1.4 of this document.

3.3 How the Law Protects You

In addition to our Privacy Promise, your privacy is safeguarded by law. The legal framework under which we operate ensures your data is handled in a compliant and secure manner.

  • Legal Basis for Processing: Our processing of your personal data is always based on legal grounds, complying with GDPR and the UK Data Protection Act 2018. This includes processing necessary for fulfilling contracts, complying with our legal obligations, protecting vital interests, or processing based on your explicit consent.

4. Legal Basis for Using Your Personal Information

In addition to our commitment outlined in the Privacy Promise, your privacy is also protected by data protection laws. This part of our Privacy Policy explains how we abide by these laws in using your personal information.

4.1 Grounds for Processing Personal Information:

Data Protection Law stipulates that we can only process your personal information if we have a valid reason for doing so. These reasons can include:

  • Contractual Necessity: When processing is necessary to fulfil a contract we have with you.
  • Legal Obligation: When we are required to process your data to comply with a legal duty.
  • Legitimate Interests: When we use your information for our legitimate business interests. We will clearly inform you about such interests and ensure that processing for these reasons does not unfairly impact your own interests and rights.
  • Consent: When you have given explicit consent to the processing of your personal data for a specific purpose.
  • Public Interest: When processing is necessary for reasons of substantial public interest.

4.2 Special Categories of Personal Data:

Certain types of sensitive information are classified as ‘special categories of personal data’ under data protection laws. This includes data concerning your health, race, religious beliefs, sexual orientation, and other similar information. We adhere to the following principles in handling such data:

  • We will not collect or use these categories of data without your explicit consent, unless legally permitted or required.
  • If we do process such data, it will only be under circumstances where it is necessary for substantial public interest, or for establishing, exercising, or defending legal claims.

4.3 How We Use Your Information and Our Legitimate Interests:

Below is a detailed list of how we may use your personal information and the specific reasons we rely on for each type of use. For instances where we rely on our legitimate interests, we provide a clear explanation of those interests, ensuring transparency and safeguarding your rights.

4.4 Detailed Use of Personal Information and Legal Basis

To ensure full transparency, we provide below a comprehensive table that details all the ways in which we may use your personal information. This table also outlines the legal reasons we rely on for each type of data usage and explains our legitimate interests where applicable.

The table is structured to offer you clear insights into our data processing activities, helping you understand:

  • The Specific Type of Data Usage: What we do with your personal information in various contexts.
  • Legal Basis for Use: The legal grounds under which we process your data, such as contractual necessity, legal obligation, legitimate interests, consent, or public interest.
  • Our Legitimate Interests: Where we rely on legitimate interests as the basis for processing, we explain what these interests are, ensuring that your rights and interests are considered and protected.

4.5 Serving you as a customer

What we use your personal information forOur reasonsOur legitimate interests

·       To manage our relationship with you or your business

·       To develop and carry out marketing activities

·       To study how our customers use products and services from us and other organisations

·       To communicate with you about our products and services

·       To develop and manage our brands, products and services.

·       Your consent

·       Fulfilling contracts

·       Our legitimate interests

·       Our legal duty

·       Keeping our records up to date, working out which of our products and services may interest you and telling you about them

·       Developing products and services, and what we charge for them

·       Defining types of customers for new products or services

·       Seeking your consent when we need it to contact you

·       Being efficient about how we fulfil our legal and contractual duties

·       Managing competitions and promotions

4.6 Business improvement

What we use your personal

information for

Our reasonsOur legitimate interests

·        To test new products

·        To manage how we work with other companies that provide services to us and our customers

·        To develop new ways to meet our customers’ needs and to grow our business

·        Fulfilling contracts

·        Our legitimate interests

·        Our legal duty

·        Developing products and services, and what we charge for them

·        Defining types of customers for new products or services

·        Being efficient about how we fulfil our legal and contractual duties

4.7 Managing our operations

What we use your personal

information for

Our reasonsOur legitimate interests

·       To deliver of our products and services

·       To make and manage customer payments

·       To manage fees, charges and interest due on customer accounts

·       To collect and recover money that is owed to us

·       To manage and provide treasury and investment products and services

·       Fulfilling contracts

·       Our legitimate interests

·       Our legal duty

·       Being efficient about how we fulfil our legal and contractual duties

·       Complying with rules and guidance from regulators

 

4.8 Managing security, risk and crime prevention

What we use your personal

information for

Our reasonsOur legitimate interests

·        To detect, investigate, report, and seek to prevent financial crime

·        To manage risk for us and our customers

·        To obey laws and regulations that apply to us

·        To respond to complaints and seek to resolve them

·        Fulfilling contracts

·        Our legitimate interests

·        Our legal duty

·        Developing and improving how we deal with financial crime, as well as doing our legal duties in this respect

·        Complying with rules and guidance from regulators

·        Being efficient about how we fulfil our legal and contractual duties

 

4.9 Business management

What we use your personal

information for

Our reasonsOur legitimate interests
·        To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, adding and testing systems and processes, managing communications, corporate governance, and audit

·        Our legitimate interests

·        Our legal duty

·        Complying with rules and guidance from regulators

·        Being efficient about how we fulfil our legal and contractual duties

·        To exercise our rights set out in agreements or contracts·        Fulfilling contracts 

4.10 For processing special categories of personal information

What we use your personal

information for

Our legitimate interests
·        Substantial public interest

·        Using criminal records data to help prevent, detect, and prosecute unlawful acts and fraudulent behaviour

·        Using criminal and health information as needed to provide insurance products

·        Responding to regulatory requirements

·        Showing whether we have assessed your situation in the right way

·        Passing information to the regulator as needed to allow investigation into whether we have acted in the right way

·        Legal claims·        Using any special categories of data as needed to establish, exercise or defend legal claims
·        Consent·        Telling you that we need your consent to process special categories of personal information, when that is what we rely on for doing so

5. Groups of Personal Information

In adherence to data protection laws, we recognise the importance of understanding the various types of personal information we handle. Our approach categorises this information into different groups, ensuring that each type is processed appropriately based on its nature and sensitivity.

5.1 Understanding the Categories:

Below, you will find a comprehensive listing of the groups of personal information we may collect and process. This categorisation is designed to give you a clear view of the potential scope of information we have about you. This could range from data obtained through your interactions with our services to insights derived from your purchasing habits in different shops.

5.2 Diverse Uses of Personal Information:

It is important to note that not all personal information is used in the same manner:

  • For Marketing and Service Provision: Some data is instrumental for marketing purposes or for providing you with our services more effectively.
  • Sensitive and Private Data: Other types of information are more sensitive and private. We accord these categories the highest level of confidentiality and protection, handling them with the utmost care and in accordance with strict data protection standards.

5.3 Upcoming Detailed Table:

Following this section, we have included a detailed table that breaks down these categories further. The table will provide you with specific examples of the types of personal information in each group, helping you understand how and why we use each category of data.

Type of personal informationDescription
FinancialYour financial position, status and history
ContactYour name, where you live and how to contact you
Socio-DemographicThis includes details about your work or profession, nationality, education and where you fit into general social or income groupings
Type of personal informationDescription
TransactionalDetails about payments to and from your accounts with us, and insurance claims you make
ContractualDetails about the products or services we provide to you
LocationalData we get about where you are. This may come from your mobile phone or the place where you connect a computer to the internet. It can also include shops where you buy something with your card
BehaviouralDetails about how you use products and services from us and other organisations
TechnicalDetails on the devices and technology you use
CommunicationsWhat we learn about you from letters and emails you write to us and conversations between us
Social RelationshipsYour family, friends and other relationships
Open Data and Public RecordsDetails about you that are in public records, such as the Electoral Register, and information about you that is openly available on the internet
Usage DataOther data about how you use our products and services
Documentary DataDetails about you that are stored in documents in different formats, or copies of them. This could include things like your passport, drivers’ licence or birth certificate
Gender IdentityInformation relating to the gender that you identify as
Type of personal informationDescription
Special types of data

The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if the law allows us to do so:

·        Racial or ethnic origin

·        Religious, political or philosophical beliefs

·        Trade union membership

·        Genetic and bio-metric data

·        Health data

·        Information that could identify aspects of your sex life

·        Sexual orientation

·        Criminal records of convictions and offences

·        Allegations of criminal offences.

·        You can read how we may use special types of data in the table ‘How the law protects you’.

ConsentsAny permissions, consents or preferences that you give us. This includes things like how you want us to contact you, whether you get paper statements, or prefer large-print formats
National IdentifierA number or code given to you by a government to identify who you are, such as a National Insurance number or social security number, or Tax Identification Number (TIN)

6. Where we collect personal information from

In this section, we detail the diverse sources from which we collect personal information about you or your business. This information may come from other companies within the Be. Group Limited, as well as from a variety of external sources.

6.1 Directly from You:

Much of the personal information we process is provided directly by you. This may occur in several situations, including but not limited to:

  • Product and Service Applications: When you apply for our products or services.
  • Communications: This includes information you provide when you talk to us on the phone (note that these calls may be recorded for quality and training purposes), in person, through our websites, mobile apps, or web chat.
  • Written Correspondence: The information contained in emails, letters, or other forms of written communication.
  • Financial Reviews and Interviews: Personal data collected during any financial assessments or interviews.
  • Customer Surveys: Information you provide when participating in customer surveys.

6.2 From People Associated with You or Your Business:

We also collect information from individuals associated with you or your business. This could include:

  • Joint account holders, trustees, or fellow company directors.
  • Representatives or agents acting on your behalf.

It’s important to note that we handle all personal information, regardless of its source, with the same level of confidentiality and security. Our aim is to ensure that your data is protected and processed in accordance with applicable data protection laws and our internal policies.

6.3 Data We Collect When You Use Our Services

This section outlines the kinds of personal data we collect and process when you access and use our services. It encompasses two main categories: transactional details and profile and usage data.

  1. Payment and Transaction Data:

When you use our services for financial transactions, we collect data that includes, but is not limited to:

  • Transaction Details: The amount, frequency, type, and location of your transactions, as well as the origin and recipients involved.
  • Credit Information: If you borrow money, this will also encompass details of repayments, including whether they are made timely and in full.
  1. Profile and Usage Data:

This category involves information related to how you interact with our services:

  • Security Information: The security credentials you create and utilise to access our services, such as passwords or biometric data.
  • Service Settings and Marketing Preferences: Your chosen settings within our services and your preferences regarding marketing communications.
  • Device Data: We collect data from the devices you use to access our internet, mobile, and telephone banking services. This includes, but is not limited to, hardware models, operating system versions, unique device identifiers, and network information.
  • Cookies and Tracking Technologies: Our use of cookies and similar technologies helps us understand how you interact with our websites and mobile apps. These tools gather data about your usage patterns, including how you respond to emails we send you. For more detailed information on how we use these technologies, please refer to our Cookies Policy.

Please note that all the data we collect is used in accordance with our Privacy Promise and is aimed at enhancing the quality, security, and personalisation of the services we offer you.

6.4 Data from Outside Organisations

In the course of our operations, we may receive personal information about you from various external organisations. The following list provides an overview of these external sources:

  1. Introduction and Referral Sources:
    • Companies that introduce you to us, such as price comparison websites, brokers, stores, car dealerships offering finance through us.
  2. Financial Service Providers:
    • Financial advisors.
    • Credit card providers such as Visa and Mastercard.
    • Credit reference agencies, including TransUnion, Equifax, and Experian.
    • Other financial services companies for payment fulfilment or fraud prevention.
  3. Insurance and Retail Partners:
    •  
    •  
    • Loyalty scheme operators.
  4. Online and Technology Platforms:
    • Comparison websites.
    • Social networks and tech providers (e.g., interactions with our ads on platforms like Facebook or Google).
  5. Fraud Prevention and Legal Entities:
    • Fraud prevention agencies.
    • Government and law enforcement agencies.
  6. Employment and Real Estate Related:
    • Employers (e.g., for references in mortgage applications).
    • Payroll service providers.
    • Land agents (e.g., for property valuations).
  7. Public Records and Information Sources:
    • Public information sources such as the Electoral Register or Companies House.
  8. Business and Consulting Services:
    • Agents, suppliers, sub-contractors, and advisers.

We collaborate with various firms that assist us in managing accounts and providing services to you. This collaboration extends to specialist companies who offer consultancy and advice on business development and improvement. The data collected from these entities plays a crucial role in enhancing our service offerings and operational efficiency. By understanding how these firms contribute to our operations, we can ensure that the data we receive is relevant and used effectively to benefit our customers.

  • Market research firms.

Market research firms play a vital role in helping us understand your needs and experiences. These firms might contact you directly on our behalf to gather your opinions and feedback. They often combine the insights you provide with data from other sources to conduct comprehensive analyses. The findings from these studies are used to generate reports and offer advice that is instrumental in understanding our customers’ perspectives. This information is crucial for us to continuously improve our business practices and enhance the services we offer to you.

  • Firms providing data services.
  1. Medical Professionals:
    • Medical professionals (for insurance products, subject to your consent).

This list is not exhaustive but covers the primary sources from which we might receive data about you. We ensure that all data received from these external sources is handled with the same level of security and privacy as the data we collect directly from you. We also ensure that our use of this data is in line with the legal bases outlined in our Privacy Policy.

7. How Long We Keep Your Personal Information

Understanding the duration for which we retain your personal information and the reasons for it is crucial. Our data retention policies are designed to ensure that we keep your information for no longer than necessary.

7.1 While You Are a Customer:

  • We retain your personal information for the entire duration of your relationship with us as a customer.

7.2 After You Cease Being a Customer:

  • Post the end of your relationship with us, we may retain your personal data for up to 10 years. The reasons for this extended retention period include:
    • To Address Inquiries or Complaints: To respond to any questions or complaints and to demonstrate whether we treated you fairly.
    • For Internal Research: To conduct studies and analyses as part of our internal research to improve our services.
    • Compliance with Legal and Regulatory Obligations: To adhere to legal and regulatory requirements that dictate record-keeping. For example, the Money Laundering Regulations mandate retaining certain data for a minimum of 5 and a maximum of 10 years.

7.3 Exceptions to the 10-Year Limit:

In specific instances, we may retain your data for periods longer than 10 years if we are legally unable to delete it due to regulatory, legal, or technical constraints.

In all cases, we assure you that your personal information will be used solely for the stated purposes, and we are committed to protecting your privacy throughout this period.

8. If You Choose Not to Give Personal Information

In this section, we explain the potential consequences of your decision not to provide personal information to us. While you have the right to withhold information, it is important to understand the impact this may have on our ability to provide services to you.

8.1 Mandatory Information for Legal and Contractual Reasons:

  • Certain personal information may be required by law or for the purposes of entering into or fulfilling a contract with you. This could include data needed to comply with legal obligations or to provide the products and services you request from us.
  • If you choose not to provide this mandatory information, it may lead to delays or prevent us from fulfilling our contractual obligations. In some cases, it could also hinder our ability to comply with legal requirements.

8.2 Potential Consequences:

  • Non-provision of necessary data may result in our inability to manage or provide certain accounts or services to you. This might lead to the cancellation of a product or service you have with us.

8.3 Optional Information:

  • At times, we may request information that is useful for enhancing our services but is not required by law or a contract. Whenever this is the case, we will clearly indicate that the provision of such information is optional.
  • Choosing not to provide this optional information will not impact the existing products or services you have with us. It is entirely at your discretion to decide whether to share these additional details.

9. Cookies and Similar Tracking Technologies

In this section, we detail how we use cookies and other tracking technologies on our websites and apps, as well as in the emails we send to you. Understanding these technologies is important for you to know how your data is being collected and used.

9.1 Cookies:

  • What Are Cookies?: Cookies are small text files stored on your computer or mobile device when you visit a website. They are sent back to the originating website on subsequent visits or to another website that recognises that cookie.
  • Purpose of Cookies: Cookies are used to store information about your visits and preferences each time you visit our website. They help in enhancing your user experience by remembering your preferences and settings.
  • Types of Information Stored: While some cookies may store personal information, many only gather data related to your website usage or preferences. This data, whether or not it includes personal details, is protected under this Privacy Policy.

9.2 Email Tracking:

  • Purpose of Email Tracking: We employ tracking within our emails to improve the effectiveness of our communications. This includes the use of tiny graphics known as pixels.
  • What We Track: These pixels can tell us if and when you opened an email, how many times it was viewed, and the device used to view it. We may also use cookies to track whether you clicked on any links within the email.

9.3 Further Information:

  • For more comprehensive details on how we use cookies and email tracking, including how to manage your preferences or opt-out, please refer to our Cookie Policy.

The Control You Have

Empowering You to Manage Your Personal Information

In this key part of our Privacy Policy, we focus on the control you have over your personal information. It is important for us to not only inform you about how we use your data but also to empower you with the ability to manage, review, and update your data as needed. This section outlines the various tools and processes we have in place to help you exercise your data rights and preferences.

10. How to Complain

Your Feedback and Concerns Regarding Data Privacy

We take your concerns about privacy and data protection seriously. If you are unhappy with how we have used your personal information, we encourage you to let us know so that we can address your concerns.

10.1 Contacting Us:

  • You can reach out to us via our secure online contact form. We are committed to resolving any issues concerning your personal data promptly and fairly.

10.2 Your Right to Complain to the Regulator:

Besides contacting us, you have the right to make a complaint directly to the relevant data protection authority. In the UK, this is the Information Commissioner’s Office (ICO).

  • Information Commissioner’s Office (ICO): The ICO is responsible for enforcing data protection laws and handling complaints about data privacy. You can find out how to report a concern to the ICO on their website.
  • Appealing Decisions: If you are not satisfied with the outcome of your complaint, either with us or the ICO, you have the right to lodge an appeal.

We are dedicated to ensuring that all your data privacy concerns are addressed respectfully and efficiently.

11. How to Withdraw Your Consent

Your Right to Change Your Mind

We understand that your preferences and decisions regarding your personal information may change over time. This section explains the process for withdrawing consent that you have previously given us.

11.1 Withdrawing Your Consent:

  • If you wish to withdraw your consent at any time, please reach out to us directly. You can use our secure online contact form, or any other contact method provided in our Privacy Policy.
  • Withdrawing consent will affect only those data processing activities that are based on consent. For more comprehensive options regarding the restriction of your information use, please refer to the section titled ‘Your Rights’.

11.2 Implications of Withdrawing Consent:

  • It is important to note that withdrawing your consent may impact our ability to provide you with certain products or services. If such a situation arises, we will inform you accordingly.
  • We ensure that any withdrawal of consent is processed promptly and that it ceases any further processing of your data for the purposes for which consent was originally given.

Your control over your personal information is a priority for us, and we are committed to facilitating your rights in a transparent and accessible manner.

12. Letting Us Know if Your Personal Information Is Incorrect

Your Right to Accurate Information

Maintaining the accuracy of your personal information is a key priority for us. If you believe that any information we hold about you is incorrect, incomplete, or outdated, you have every right to have it corrected.

12.1 How to Notify Us:

To raise concerns about the accuracy of your personal information, you can easily contact us through the following methods:

  • Online Contact Form: The most direct way to notify us is via the contact form available on our website.
  • In-App Chat: You can also use our in-app chatbot for a swift response and assistance in updating your information.

12.2 Our Commitment to You:

  • Upon receiving your query, we will take reasonable steps to verify and, if necessary, correct the information in question.
  • We are committed to responding to your concerns promptly and ensuring that your personal information is accurate and up to date.

Your confidence in the accuracy of the information we hold is fundamental to our relationship, and we are dedicated to upholding your right to correct any inaccuracies in your personal data.

13. How to Get a Copy of Your Personal Information

Accessing Your Data

We acknowledge and support your right to access the personal information we hold about you. Whether you need a copy for personal use or to share with others, we have made the process straightforward and accessible.

13.1 Requesting Your Information:

You can request a copy of all the personal information we have about you. To do so, you can either:

  • Write to Us: Send a written request to the following address:

Be. Cards Limited Unit 36-37 Tondu Enterprise Centre, Bryn Road, Aberkenfig, Bridgend, Wales, CF32 9BS

  • Online Request: Alternatively, you can make this request online through our website or via our in-app features.

13.2 Digital File for Ease of Use:

  • Upon request, we can provide your personal data in a digital format. This makes it easy for you to use, store, or share the information as needed.

13.3 Response Time:

  • We strive to respond to your requests promptly and efficiently, in line with data protection laws.

Your right to access your personal information is a key aspect of data transparency and control. We are committed to facilitating this right in a user-friendly and efficient manner.

13.4 Data Portability: Sharing Your Data with Outside Companies

Your Right to Use and Transfer Your Personal Information

In addition to accessing your personal data, you have the right to use your data for your own purposes and share it with other organisations as you see fit.

13.5 Getting Your Data in a Digital Format:

We can provide you with your personal information in a digital file format. This format is designed to be easily reusable, allowing you to keep, use, or transfer your data as needed.

  • Electronic Transfer: On your request, we can furnish your data in an electronic format that facilitates easy use and transfer.

13.6 Passing Your Data to Other Organisations:

If you wish, we can also directly transfer your personal data to other organisations on your behalf.

To initiate this process, you can reach us through:

  • Online Contact: The most efficient way to make this request is via our online contact form or through our in-app chat service.

13.7 Maintaining Your Data Integrity:

  • We ensure that all data transfers are conducted securely and in a manner that protects the integrity of your personal information.
  • Our commitment is to make the process of data portability as seamless and user-friendly as possible, respecting your rights to control and distribute your personal data.

14. Your Rights

Understanding and Exercising Your Data Privacy Rights

This section explains your rights regarding your personal data and how you can exercise them. We are committed to not only respecting these rights but also to assisting you in exercising them.

14.1 Right to Object:

  • You have the right to object to our processing of your personal information. If you feel that your data should not be used in a certain way, you can raise an objection.

14.2 Right to Erasure (‘Right to be Forgotten’):

  • You can request the deletion or removal of your personal data when there is no compelling reason for its continued processing. This right is known as the ‘right to erasure’ or the ‘right to be forgotten’.

14.3 Exceptions to Data Deletion:

  • There may be circumstances under legal or regulatory obligations where we need to retain or use your data. However, we encourage you to inform us if you believe we should not be using your data.

14.4 Right to Restrict Processing:

In certain situations, you have the right to ‘restrict’ or limit the ways in which we can use your personal information. These situations include:

  • If you contest the accuracy of the data.
  • If the data has been used unlawfully but you do not want it deleted.
  • If the data is no longer needed but you wish to keep it for use in legal claims.
  • If you have objected to our use of your data but are awaiting verification of our grounds for processing.
  • While your data is restricted, we will not use or share it in other ways.

14.5 Contacting Us to Exercise Your Rights:

  • If you wish to exercise any of these rights, you can contact us through our secure online contact form or via our in-app chat service.
  • We are here to help you understand and exercise your rights effectively, ensuring your data is handled in accordance with your wishes.

14.6 Legislation and Regulatory Compliance

In addition to outlining your personal data rights, it is important to acknowledge the legal and regulatory framework that underpins these rights. Be. operates in compliance with several key regulations and legal requirements, especially concerning our consumer credit license and payment services. This includes, but is not limited to:

  • Financial Conduct Authority (FCA) Regulations: We adhere to FCA guidelines, which govern fair and responsible lending and financial services practices.
  • Payment Services Regulations: Our payment services are in line with the regulatory standards set out in the Payment Services Regulations, ensuring secure and efficient processing of payment transactions.
  • Consumer Credit Legislation: We operate our consumer credit services under strict compliance with relevant consumer credit legislation, which provides a framework for consumer rights and protections in credit agreements.
  • Data Protection Legislation: This includes the General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018, which provide the foundation for your rights to access, rectify, erase, or restrict the processing of your personal data.

Understanding these regulations helps contextualise your rights and our obligations. Our commitment to these legal and regulatory frameworks ensures that we not only protect your personal data but also uphold your rights as a consumer in our credit and payment services.

15. How Personal Information is Used

Who We Share Your Personal Information With

At Be., we may share your personal information with a range of outside organisations to provide you with our products and services, for business operations, and to comply with legal obligations. Below is a detailed list of the types of organisations we may share your information with:

  1. Within Be. Cards: Other companies affiliated with Be. Cards, such as Blukite Finance Limited in relation to both your Rewards and Credit data and Bespoke Hotels in relation to your Rewards & Loyalty Membership only.
  2. Authorities: This includes central and local government, HM Revenue & Customs, regulators, tax authorities, the UK Financial Services Compensation Scheme, deposit guarantee schemes, law enforcement, and fraud prevention agencies.
  3. Banking and Financial Services: Entities that are part of providing banking and financial services, including credit reference agencies (like TransUnion, Equifax, and Experian), and other financial services companies for payments or fraud prevention.
  4. Service Providers and Business Partners:
    • Agents, suppliers, sub-contractors, and advisers that help run accounts, policies, and services.
    • Credit and collection agents.
    • Independent Financial Advisors, with your consent.
    • Price comparison websites and similar companies.
    • Employers, for verification purposes (e.g., mortgage references).
    • Open Banking partners, as directed by you.
  5. Additional Services and Schemes:
    • Card transaction processors such as Visa and Mastercard.
    • Direct Debit scheme operators.
    • Loyalty scheme operators.
    • Insurance and benefit providers.
    • Other lenders for joint loans or mortgages.
  6. General Business Operations:
    • Joint venture partners and other business collaborators.
    • Market research firms for customer insights.
    • Advisers and consultants for business development.
    • Advertisers and technology providers for marketing purposes.
  7. Mergers, Acquisitions, and Business Transfers:
    • Potential buyers or partners in business sales, mergers, or acquisitions. We ensure data protection terms are agreed upon in these situations.
  8. Anonymised Data Sharing:
    • We may share aggregated, anonymised data with outside companies for research and analysis. This data is grouped to prevent identification of individuals.

In all instances of data sharing, our priority is to ensure your personal information is protected and used in accordance with this Privacy Policy.

16. How We Work Out What Marketing You Receive

Personalised Marketing and Your Choices

Understanding how we use your personal information to tailor and present marketing to you is important. This section explains our approach to determining the marketing content that may interest you and how you can control what you receive.

16.1 Marketing Decisions Based on Your Information:

  • We use your personal information to make informed decisions about the products, services, and offers that may be of interest to you. This process involves analysing data from your interactions with our services, information you provide, and data from external sources.
  • This method of using personal information for marketing is often referred to as ‘profiling’.

16.2 Consent and Legitimate Interest:

  • We only send you marketing communications if we have your explicit consent or a ‘legitimate interest’. A legitimate interest means a business or commercial reason that justifies the use of your information, without unfairly impacting your own interests.

16.3 Your Marketing Preferences:

  • The marketing material you receive, be it online, in apps, via email, mobile phone, post, or through other digital channels, is dependent on your marketing preferences.
  • You have the right to alter these preferences at any time or to opt out of marketing communications entirely.
  • If you choose not to have your data collected via our websites or mobile apps, you may still see marketing from us, but it will not be specifically tailored to you. Our Cookies Policy details how this data is used.

16.4 Receiving Essential Information:

  • Regardless of your marketing preferences, you will continue to receive essential information, such as statements and updates about changes to your existing products and services.

16.5 Protection of Your Personal Information:

  • We do not sell your personal information to outside organisations.

16.6 Updating Your Preferences:

  • We may request you to confirm or update your marketing preferences in certain scenarios, such as when you acquire new products or services from us, or if there are changes in laws, regulations, or our business structure.
  • You can update your choices anytime by contacting us.

17. How We Use Your Information to Make Automated Decisions

Understanding Automated Decision-Making and Your Rights

This section explains how we use automated systems to make decisions based on your personal information. These decisions can significantly impact the products, services, or features we offer you, including their pricing.

17.1 Automated Decision-Making Processes:

  1. Pricing: Automated systems help determine prices for some products and services. For example, online mortgage calculators use your financial details to estimate mortgage offers, and insurance applications may use data to assess claim likelihood.
  2. Tailoring Products, Services, and Marketing: We categorise customers into segments to better understand and meet needs, influencing our product and service design. This includes using segments from external partners, like social networks, to identify potential new customers with similar interests.
  3. Detecting Fraud: We use automated systems to identify unusual activities that may indicate fraud or money-laundering in personal or business accounts.
  4. Opening Accounts: When opening an account, automated checks ensure the product or service is suitable and that you meet the necessary criteria, such as age, residency, nationality, or financial standing.

17.2 Your Rights Regarding Automated Decisions:

  • Right to Challenge: You have the right to object to decisions made by automated systems. You can request that a person reviews an automated decision to ensure fairness and accuracy.
  • Further Information: For more information about these processes or to exercise your rights, please contact us using the methods outlined in our Privacy Policy.

18. Credit Reference Agencies (CRAs)

How We Use CRAs for Credit and Identity Checks

This section explains our collaboration with Credit Reference Agencies (CRAs) to conduct credit and identity checks, essential for decisions about lending through products like credit cards or loans.

18.1 Credit and Identity Checks:

  • When you apply for a product or service, we perform checks on your creditworthiness and verify your identity. CRAs assist us in this process.
  • We also periodically review CRA information to manage your account effectively.

18.2 Data Exchange with CRAs:

We share your personal information with CRAs, and they provide us with information about you. The shared data includes:

  • Name, address, and date of birth.
  • Credit application details.
  • Information on shared credit.
  • Financial situation and history.
  • Fraud prevention information.
  • Public information from sources like the Electoral Register, Companies House, media, and social networks.

18.3 Use of CRA Data:

  • We use this data to assess creditworthiness and affordability, verify accuracy, detect and prevent financial crime, manage accounts, recover debts, and ensure offers are appropriate for you.
  • Your information is shared with CRAs as long as you remain a customer, including account balance and transaction details.

18.4 Linked Records:

  • If you apply for a product jointly with someone else or have a financial association (like a spouse, partner, or business associate), we link your records with theirs.
  • It is important to inform these individuals that their records will be linked and subject to credit searches.
  • CRAs also link your records, which remain linked unless you or the other individual request and provide proof to break the link.

18.5 Further Information from CRAs:

More detailed information about CRAs can be found in the Credit Reference Agency Information Notice on their websites. This includes:

  • CRA identity and role.
  • Their function as fraud prevention agencies.
  • The data they hold and its usage.
  • How they share personal information.
  • Data retention periods.
  • Your rights concerning data protection.

19. Fraud Prevention Agencies (FPAs)

Collaboration in Fighting Financial Crime

This section describes how we collaborate with external organisations, including Fraud Prevention Agencies (FPAs), to combat financial crimes like fraud, money laundering, and terrorist financing.

19.1 Identity Confirmation and Fraud Checks:

  • We conduct identity verification and fraud checks before providing products or services. This is crucial for ensuring the security and integrity of our transactions.
  • Once you are a customer, we continue to share information as necessary to combat fraud and other financial crimes.

19.2 Organisations We Share Data With:

  • We exchange data with Registered FPAs, other similar agencies, industry databases, and insurers for fraud prevention purposes.
  • The mutual exchange of data helps us and these organisations in preventing, detecting, investigating, and prosecuting financial crimes.

19.3 Reasons for Using Your Information:

  • The use of your personal information is based on legal obligations or ‘legitimate interests’. We will specify the legitimate interests when they are the basis for processing your data.
  • The purposes include confirming identities, preventing fraud and money laundering, and fulfilling contracts.

19.4 Law Enforcement Access:

  • In certain circumstances, we or an FPA may allow law enforcement agencies to access your personal information to aid in their crime prevention duties.
  • Different organisations may retain personal information for varied durations, up to a maximum of six years.

19.5 Types of Information Used:

The personal information used includes but is not limited to:

  • Name, date of birth, addresses (current and historical), contact details, financial data, fraud victim status, data related to products or services, employment and vehicle details, and online identifiers like IP addresses.

19.6 Automated Decisions in Fraud Prevention:

We and other organisations may use automated systems to detect fraud. These systems analyse patterns in data to identify activities typical of fraudsters or unusual for you or your business.

19.7 Impact of Fraud Decisions:

  • If fraud is suspected, actions may include freezing activity on accounts or blocking access.
  • FPAs may keep records of fraud risks, which could influence other organisations’ decisions to offer you services or employment.

19.8 International Data Transfers:

FPAs may transfer data outside the UK and EEA. In such cases, contracts ensure that the data is protected to EEA standards, including adherence to international data sharing frameworks.

19.9 FPA Information Notice:

For more details on how FPAs operate, please visit the CIFAS information notice page: CIFAS – Fraud Prevention Agency Information Notice

20. Sending Data Outside the UK and EEA

Safeguards for International Data Transfers

This section details the measures we take to protect your personal information when it is transferred outside the UK and the European Economic Area (EEA).

20.1 Circumstances for Data Transfer:

  • Following Your Instructions: For instance, if you use a card to book a hotel abroad, we transfer necessary details to fulfil the payment.
  • Legal Compliance: We share information as required by law, such as reporting to foreign tax authorities.
  • Working with International Suppliers: To manage your accounts and services, we might need to transfer data to suppliers outside the UK and EEA.

20.2 Safeguards for Protection:

We ensure that your data is protected to the same standards as within the UK and EEA. This is achieved through:

  • Adequacy Decisions: Transferring data to countries deemed by the European Commission to have adequate data protection laws. More information is available on the European Commission Justice website.
  • Standard Contractual Clauses: Implementing contracts with recipients that obligate them to protect data to UK and EEA standards. Further details can be found on the European Commission Justice website.

20.3 Restriction on Marketing Data Transfer:

Be.’s Policy: It is important to note that Be. does not transfer personal data outside of the UK for marketing purposes. This policy is in place to ensure greater control and protection of your personal data.

21. Data Security Measures

Protecting Your Personal Information

At Be., we understand the importance of securing your personal data against unauthorised access, alteration, and loss. We implement a range of technical and organisational measures to ensure the highest level of data protection.

21.1 Our Security Practices:

  1. Encryption: We use advanced encryption technologies to protect data during transmission and while stored on our systems.
  2. Access Control: Access to personal data is strictly controlled. Only authorised personnel have access to sensitive information, and only for designated purposes.
  3. Regular Security Audits: We conduct regular audits and reviews of our security measures to ensure they are up to date and effective against emerging threats.
  4. Secure Data Storage: Personal information is stored in secure facilities with restricted physical access. Online data is housed in servers with robust cybersecurity protections.
  5. Data Processing Protocols: Our data processing protocols are designed to safeguard data integrity and prevent unauthorised access or leakage.
  6. Employee Training: Staff receive regular training on data protection and security protocols, emphasising the importance of confidentiality and handling data responsibly.
  7. Incident Response Plan: We have a comprehensive incident response plan to address any potential data breaches quickly and effectively, minimising any potential impact on your data.
  8. Compliance with Standards: We adhere to internationally recognised standards and frameworks for data security, ensuring our practices meet global benchmarks.

21.2 Commitment to Data Security:

Our commitment to data security is ongoing. We continually monitor and update our security practices in response to new threats and advancements in technology. Protecting your personal information is a responsibility we take very seriously, and we are dedicated to maintaining the confidentiality, integrity, and availability of your data.

22. Third-Party Links

Disclaimer for External Links

Our website and services may include links to third-party websites, applications, and platforms that are not operated or controlled by Be.. This section addresses our position and disclaimers regarding these external links.

22.1 Understanding Third-Party Links:

  • When you follow a link to an external website, you are leaving our site and are subject to the privacy policy and security practices of that external website.
  • These third-party sites are not under our control, and we are not responsible for their content, privacy policies, or security practices.

22.2 Our Recommendations:

  • We recommend that you review the privacy policies of these third-party websites to understand how they collect, use, and share your personal information.
  • Be cautious when providing personal information on any external site, especially if the privacy practices are unclear or seem inadequate.

22.3 Disclaimer:

  • Be. does not endorse, guarantee, or make any representations regarding the accuracy, reliability, or any use of information on third-party websites.
  • The inclusion of a third-party link on our website or services does not imply an affiliation, sponsorship, endorsement, approval, investigation, verification, or monitoring by Be. of any information contained in the linked website.

22.4 User Responsibility:

Your use of any third-party sites and their available services is at your own risk. We encourage users to be aware when they leave our site and to read the privacy statements of other sites that collect personally identifiable information.

23. User Rights in Detail

Your Rights Under Data Protection Laws

Our commitment to your privacy includes ensuring you are fully aware of your rights under data protection laws, such as the GDPR and the UK Data Protection Act. Below is a detailed overview of these rights and how you can exercise them.

  1. Right to Access: You have the right to request access to the personal information we hold about you. This includes the right to obtain confirmation of whether or not personal data concerning you is being processed.
  2. Right to Rectification: If the information we hold about you is inaccurate or incomplete, you have the right to request that we correct or complete it.
  3. Right to Erasure (‘Right to be Forgotten’): You can ask us to delete or remove your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was collected.
  4. Right to Restrict Processing: Under certain conditions, you have the right to restrict the processing of your personal data. For instance, if you contest the accuracy of your data, you can request a restriction on processing until verification.
  5. Right to Data Portability: This right allows you to obtain and reuse your personal data for your own purposes across different services. It applies to data you have provided, where the processing is based on consent or a contract and is carried out by automated means.
  6. Right to Object: You have the right to object to the processing of your personal data based on legitimate interests, direct marketing (including profiling), and processing for scientific or historical research and statistics.
  7. Rights in Relation to Automated Decision Making and Profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

23.1 How to Exercise Your Rights:

  • To exercise any of these rights, please contact us at contact@be.cards
  • We will respond to your request in accordance with applicable data protection laws and within the legally required time frames.

23.2 Further Assistance:

If you have any questions or need assistance regarding your rights, our Data Protection Officer can be contacted at contact@be.cards

24. Policy Updates and Changes

Keeping You Informed About Changes

At Be., we periodically review and update our Privacy Policy to ensure it remains up to date with legal requirements, reflects changes in our data practices, or incorporates feedback from our users and stakeholders.

24.1 Notification of Changes:

  • Proactive Communication: When we make changes to our Privacy Policy, we will proactively inform you. This may be done through email notifications, alerts on our website, in-app messages, or other communication channels we use to engage with you.
  • Publication on Website: The updated Privacy Policy will always be published on our website, allowing you to review the changes at your convenience.

24.2 Reviewing Changes:

  • Highlighting Key Changes: In our communications, we will highlight key changes to the policy, especially those that might significantly impact the way we handle your personal information.
  • Effective Date: The date when the updated policy comes into effect will be clearly stated. We encourage you to review the policy as of this date to understand the current terms.

24.3 Your Acceptance of Changes:

Continued Use: Your continued use of our services after the effective date of these changes constitutes acceptance of the updated Privacy Policy. If you do not agree to the changes, you have the option to discontinue using our services.

24.4 Questions and Concerns:

Should you have any questions or concerns about any changes made to our Privacy Policy, please do not hesitate to contact us. We are committed to addressing your queries and providing clarity on how these changes might affect you.