Privacy policy
This is the privacy policy for Octo Partners Limited (trading as COMBINE), a company registered in England & Wales (company number 10538304) with a registered office at 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ ("we", "us", "our", "app"), in relation to the use of personal information provided in relation to the use of the website and online account and personal finance management services provided at www.getcombine.com and www.combine.money ("the Service").

1. Our Privacy Policy

1.1. At Combine, we are committed to respect and protect your privacy. This Privacy Policy sets out the type of information we collect from you and what we do with that information. The terms set out should be read together with our Terms and Conditions.

1.2. By using the service offered by Combine you confirm that you accept the terms of this Privacy Policy and that you agree to be bound by them in your use of the service. If you do not agree, please do not use the service.

2. Data Controller (or Owner)

2.1. For the purposes of this Privacy Policy, the Data Controller is Octo Partners LTD ("Combine", the "App" or "us") of 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ

2.2. We are also registered with the Information Commissioner under registration number: ZA256685.

2.3. You may contact us at: a info@getcombine.com

3. Data Processor

3.1. Amazon Web Services (AWS). AWS is appointed Data Processor by Combine. AWS provides the processing service of the Data collected through the use of the App in accordance with Combine's processing instructions. The processing of Data is carried out in respect of AWS Security Standards at all times. The information collected by AWS may be transferred to, or stored at, a location outside the European Economic Area ('EEA'). To this end, AWS has enacted Model Clauses that allow the transfer of Data outside the EEA in compliance with European Data Protection law (Directive 95/46/CE). By providing us with your Personal Data, you agree to this and processing of your Data. Additionally, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies). The updated list of these parties may be requested from the Data Controller at any time

4. Personal Data you give us

4.1. Combine collects, by itself or through Third Parties, Personal Data that includes: Full Name; Email; Date of Birth; Country of Residence and Address; Nationality; Bank Account. The primary goals in collecting information are to provide and improve our Service, to administer your use of the Service and to enable you to enjoy it.

4.2 Other types of Personal Data collected may be described in other sections of this Privacy Policy.

4.3 Failure to provide Personal Data may make it impossible for the App to provide its Service.

5. Information we collect from other sources

5.1. When you use our App we may receive or collect your IP address, URL, Browser information, operating system and platform as well as your login information. We may collect and store information about your location by converting your IP address into a rough geolocation or by accessing your mobile device's GPS coordinates or coarse location if you enable location services on your device. This information may be used to improve and personalize our service.

6. Bank Account and Financial Details.

6.1. The Service requires the processing of your financial details and data of your bank accounts. To ensure the maximum level of protection of your Data, Combine collaborates with the following service providers that store and process User's Data:

6.2. We use a company called Yodlee (yodlee.com) to provide software that lets you add details of the accounts which you want to include in the service ("account aggregation"). When you aggregate an account Yodlee collects and securely uses log in details, such as User name and password to get read-only access to your bank account information. This information is never stored by us nor subsequently disclosed to us and is subject to Yodlee's privacy policy. For further information on how Yodlee keeps your information secure please visit https://www.yodlee.com/legal/privacy-notice/ and https://www.yodlee.com/legal/yodlee-security/.

Combine will never receive nor store User's personal online login credentials, except for your Bank Account number, and will receive from Yodlee only the information required to provide the service.

• Collected Data: Full name, Email, Date of Birth, Nationality, Country of Residence and Address, Bank Account, as specified in Yodlee's Privacy Policy.

7. Other uses of the Data collected

The Data we collect from Users are also used for the following purposes:

• Analytics.
The services described in this section allow the Data Controller to control and analyze traffic data. The services also allow the tracking of the User's behavior.
– Mixpanel is an analytics service provided by Google, Inc. Data collected: different types of Personal Data, such as Usage Data, as specified in the Privacy Policy of Fabric. Place of processing: US – Privacy Policy.

• Email and Contact Management.
These services allow the managing of email contacts and other contacts used to communicate with the User. The services may also allow the collection of Data concerning the date and time of display of the message by the User.
– Mailchimp is an email management and storage service provided by Mailchimp Inc. Data collected: Email. Place of processing: US – Privacy Policy.

• Newsletter
By registering to the newsletter service, the User's email address is inserted in a mailing list. They will receive emails containing information, also of commercial and promotional nature, regarding Combine. Data collected: Email and Name.

• Advertising
This type of services allows User Data to be utilised for advertising communication purposes displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
– AdWords is a remarketing and behavioral targeting tool to advertise across websites provided by Google, Inc. Data collected: various types of Data, as specified in AdWords' Privacy Policy. Place of Processing: US – Privacy Policy.

– Facebook Conversion.
Facebook Conversion is a tracking tool for ads on the social network Facebook provided by Facebook, Inc. Data collected: various types of Data as specified in Facebook's Privacy Policy. Place of processing: US – Privacy Policy.

8. Mode and Place of Processing the Data

8.1. Security and Mode of processing

8.1.1 Combine processes Users' Personal Data in a proper manner and shall adopt appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. Even where all precautions are adopted we cannot guarantee complete security in all events.

8.1.2. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.

8.2. Place of processing

8.2.1. The Data is processed at the Data Controller's operating offices and where the Data Processor's operating offices or other parties involved with the processing are located.

8.3. Retention time

8.3.1. The Data is kept strictly for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this Privacy Policy.

8.3.2. The User may always request that the Data Controller suspend or remove the Data.

9. Data Transfer

9.1. The User consents to the transfer, selling or dissemination of the collected Data through the Service in the event of rearrangement, merger, sale, joint venture, transfer or any other arrangement method of the whole or part of the Company, of its goods and shares.

10. Legal Action

10.1. Your Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this App or related services

10.2. You acknowledge to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

11. Rights of Users

11.1. You have the right, at any time, to know whether your Personal Data has been stored and may consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any Data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at: info@getcombine.com

12. Changes to the present Privacy Policy

12.1 The Data Controller reserves the right to change this Privacy Policy at any time by giving notice to its Users through this page. It is recommended, therefore, to check this page often and refer to the latest update date at the bottom of the page. If a User objects to all or any of the changes to the Policy, the User must cease using the App and may request that the Data Controller remove his/her Personal Data. Unless stated otherwise, the then-current Privacy Policy applies to all Users' Personal Data possessed by the Data Controller at the time

13. Definitions

13.1. Combine (or the App)

13.1.1.The hardware or software tool by which the Personal Data of the User is collected.

13.2. Personal Data (or Data)

13.2.1. Any information regarding a natural person, which is, or may be, identified or identifiable, even indirectly, by reference to any other information, including a personal identification number.

13.3. Usage Data

13.3.1. Information collected automatically from this App (or Third Party services employed in this App), which may include: IP addresses or domain names of the computers used by the Users, URI addresses (Uniform Resource Identifier), time of the request, method of request submission to the server, size of the file received in response, numerical code indicating the status of the server's answer (successful outcome, error, etc.), Country of origin, features of the browser and the operating system utilized by the User, various time details per visit (e.g., time spent on each page within the App) and details about the process followed within the App, specifically the visited pages sequence and other parameters about the device operating system and/or the User's IT environment.

13.4. Data Controller (or Owner)

13.4.1 The natural person, legal person, public administration or any other body, association or organization, also jointly with another Data Controller, having the right to make decisions regarding the purposes and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this App. The Data Controller, unless otherwise specified, is the Owner of this App.

13.5. User

13.5.1. The individual using this App, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refer.

13.6. Data Processor

13.6.1. The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

14. Customer Testimonials/Comments/Reviews

We post customer testimonials/comments/reviews on our website which may contain personal information. We obtain the customer's consent via email prior to posting the testimonial to post their name along with their testimonial. If you wish to update or delete your testimonial, you can contact us at info@getcombine.com.

15. Blogs/Forums

Our website offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog, contact us at info@getcombine.com . In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

16. Security

We use the same industry-standard security practices as many of the world's leading banks. It's our number 1 priority to make sure all your data is kept safe and secure.

Your money can't be moved. COMBINE is a read-only application, which means it cannot be used for withdrawals, payments or to transfer your funds.

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

17. Links to Other Websites

Our website includes Social Media Features, such as the Facebook Like button and Widgets, such as the "Share this" button or interactive mini-programs that run on our site. These Features may collect your IP address or which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

18. Changes to this Privacy Policy

We may need to modify this privacy policy at any time, so please review it frequently. If we make material changes to this policy, prior to the change becoming effective, we will tell you by email, or by a notice on our homepage so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

19. Cookies and Other Tracking Technologies

The COMBINE website uses cookies to enhance your experience of our website. Cookies are small data files which are placed on a website visitor's computer or mobile device and are stored on the hard drive. The information contained within cookies can only be read by our server. They cannot be used to read or gather personal information that you have not specifically entered yourself.

In order to access our website's full features all cookies must be enabled. For more information on how to manage cookies please refer to our "How to manage cookies" section below.

Our use of cookies provides us with general (non-personal) information about how visitors use this website, i.e. the pages which are viewed most often or the most common traffic sources to our website. Cookies are also used across this website to remember customisable user selections to provide you with a more personalised experience.

As is true of most websites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

We use this information, which does not identify individual users, to analyse trends, to administer the site, to track users' movements around the site and to gather demographic information about our user base as a whole.

We may link this automatically-collected data to personal information in order to allow analysis of the effectiveness of marketing campaigns How to manage cookies.

Your internet browser's security settings or preferences enable you to take control of the information you share online. These can usually be found within your browser's menu tab. You will be presented with the option to accept all cookies, receive an alert when a cookie has been set, or to disable your browser from receiving cookies.

Internet browsers provide the above features in their own distinct ways, so please refer to the help section – located on your browser's menu – for a specific set of instructions on how to change your cookie preferences. For those viewing this website on a mobile device, please refer to your handset guide or technical manual.

Please remember that disabling your browser from accepting cookies may limit your ability to access our website's full set of features and/or page content.

The use of cookies by our partners is not covered by our privacy policy. We do not have access to or control over these cookies.

Our third party partners employ clear gifs (also known as Web Beacons/Web Bugs), images, and scripts that help them better manage content on our site. We may tie the information gathered to our Users' personal information in order to analyse the effectiveness of marketing campaigns.

Our website also contains cookies set by third party websites (i.e. Social networking sites such as Twitter), which provide information and/or services on our website. In order to manage these cookies you will have to visit the websites of our third parties and adjust your settings accordingly.

More information on how to control or manage cookies can be found at http://aboutcookies.org/.

Last updated: 01/06/2017