1. Who We Are

DigiCheques Limited is the data controller for the personal data we collect when you use the DigiCheques platform or join our waitlist.

Company number: 16456071
ICO registration: To be inserted on registration.
Data protection contact: richard@digicheques.com

2. What Data We Collect and Why

Waitlist registrants

• Email address: to notify you when DigiCheques launches. Legal basis: consent. You may withdraw consent at any time by emailing us.
• Use case information (optional): to understand how people intend to use DigiCheques. Legal basis: legitimate interests.

Senders (on platform launch)

• Identity data (name, date of birth, nationality, document details): legal obligation under the Money Laundering Regulations 2017.
• Contact data (email, mobile): contract performance.
• Address data: legal obligation.
• Transaction data: retained five years as required by the MLRs 2017.
• Device and technical data (device fingerprint, IP address): fraud prevention, legitimate interests.
• Biometric data (selfie for liveness detection): deleted immediately following successful verification. Legal basis: explicit consent.

Recipients (on platform launch)

• Name and date of birth: contract performance.
• Bank account details: passed to our BaaS partner (an FCA-authorised EMI) for payment execution only. Not stored by DigiCheques after payment is complete.

3. How Long We Keep Your Data

• Waitlist email addresses: until DigiCheques launches and you have been notified, or until you ask us to delete your data, whichever comes first.
• Identity and transaction records: five years from the end of the business relationship (MLRs 2017).
• Contact data: account duration plus three years.
• Biometric selfies: deleted immediately after successful verification.

4. Who We Share Your Data With

We do not sell your personal data. We do not share with advertisers or marketing partners.

We share data only where necessary to operate the service:

• Our BaaS partner (an FCA-authorised EMI): banking infrastructure and payment execution.
• Onfido Ltd: identity verification (KYC).
• Comply Advantage: AML screening (sanctions, PEP, adverse media).
• TrueLayer Ltd: Open Banking account funding.
• Amazon Web Services: encrypted cloud storage in UK data centres.
• Regulatory authorities (FCA, HMRC, NCA, ICO): as required by law, without prior notice where the law requires.

5. Your Rights

Under UK GDPR you have the right to:

• Access the personal data we hold about you.
• Correct inaccurate data.
• Delete your data (the right to erasure).
• Restrict how we use your data.
• Object to processing based on legitimate interests.
• Port your data to another provider.
• Withdraw consent at any time where consent is the legal basis.

To exercise any of these rights, email richard@digicheques.com. We will respond within one calendar month.

If you are unhappy with how we have handled your data, you have the right to complain to the Information Commissioner's Office at ico.org.uk or by calling 0303 123 1113.

6. Cookies and Tracking

The DigiCheques waitlist page uses no third-party tracking cookies. We use browser localStorage solely to display the waitlist counter to you. No data is shared with advertising networks.

7. International Transfers

Your data is stored on Amazon Web Services infrastructure located in UK data centres. Where any data is transferred outside the UK, we ensure appropriate safeguards are in place in accordance with UK GDPR requirements.

8. Changes to This Notice

We will update this notice as the DigiCheques service develops. The version number and date at the top of this page will reflect any changes. We will notify waitlist registrants by email of any material changes.

9. Contact

DigiCheques Limited
Company No. 16456071
richard@digicheques.com