You should read this notice, so that you know how we are handling your personal data. It explains who we are, how and why we collect personal data from you, how and why it will be processed by us and our commitment to protecting your data.
However, if you do not have time to read it in full we have summarized the key points for you:
This privacy policy is provided in a layered format so you can click through to the specific areas set out below.
Mistho Services Limited (“we”, “us”, “our”) is a company registered in England and Wales under company number 13636487 whose registered office is at 27 Old Gloucester Street, London, WC1N 3AX.
The terms “you” and “your” refers to the user accessing or using the Mistho Service.
To use the Mistho Service, you will be forwarded to the Mistho Service by your selected Partner. Typical Partners of Mistho are service providers such as lenders, buy-now-pay-later services, online real estate services, brokers or landlords, i.e. providers of products or services for which you need to verify your monthly income, amongst other things. You always decide for yourself whether you want to transmit your personal data to the respective Partner. [To find out more about how the Mistho Service works, please read our General Service Terms of Use.]
Mistho respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (www.mistho.io) (regardless of where you visit it from) or use the Mistho Service and will also tell you about your privacy rights and how the law protects you. This privacy policy may change from time to time and, if it does, the up-to-date version will always be available on our website. We will also tell you about any important changes.
We will act as your agent and the processor of your selected Partner where processing your personal data in the context of the Mistho Service, for example when accessing your payslips and making those available to the selected Partner. Otherwise, we will act as a controller of, and be responsible for, your personal data, for example when marketing our services, operating our website or completing any data analytics activities which are not related to a specific Partner contract.
Our website is not intended for children and we do not knowingly collect data relating to children.
This privacy policy is primarily focussed on the data we collect and process when acting as a controller. Please refer to the relevant privacy policy of your selected Partner for details of the types of data we process as a processor on behalf of that Partner, although we set out below some details of the data we process by collecting and providing to them. It is important that you read this privacy policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies, such as those from the Partner, and is not intended to override them.
If you have any questions about this privacy policy or our privacy practices, or you wish to exercise any of your data subject rights, please contact us in the following ways:
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or Mistho Service feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
As a controller, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you or the Partner, and you fail to provide that data when requested, we may not be able to provide the Mistho Services and therefore facilitate the performance of the contract you and the Partner are trying to enter into.
We use different methods to collect data from and about you including through:
Where we collect information about you in the ways described above, we do so on the basis that it is in our legitimate interests to collect and process this data. In most situations this will be anonymised but we collect and process this data to ensure that our site is functioning properly and that our customer experience is to the standard that you and we expect.
No automated decision-making or profiling will take place using your personal data.
When we receive information from other sources, we rely on them having the appropriate provisions in place telling you how they collect data and who they may share it with. We carefully check our sources to ensure that we only receive your information when it is lawful for us to do so.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
We have set out below, in a table format, a description of all the ways we may use your personal data as a controller (in accordance with section 2.2), and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
---|---|---|
To manage our relationship with you which will include:
|
| Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
| Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
| Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you via our newsletter |
| Consent |
To establish, exercise and defend our legal rights | All types of data referred to in section 3.2 | Necessary for compliance with a legal obligation. Necessary for our legitimate interest (for the purpose of establishing, exercising or defending our legal rights) |
We will process your personal data, as a processor, on behalf of your selected Partner for the purposes of providing the Mistho Service to you. This means we will extract the following types of data from your payslip (and any other data included within your payslip) and share this with the Partner so it can provide the Partner Services:
Mistho will process this personal data for the period of time instructed by the Partner, who will act as controller. Please refer to the relevant privacy policy of your selected Partner for further details of the types of data we process as a processor, and the manner and purpose of processing, on behalf of that Partner.
If we do not yet offer your payroll service, you can tell us which service you use to manage your payroll by providing us with your Identity and Contact data and the name of your payroll service. You will then receive an email from us in which we ask you to click a link to confirm that you would like to be notified as soon as your payroll service is available. This notification is sent on the basis of your consent. We will only use your personal information to send you such marketing messages if you have provided your consent.
We want to ensure that you are informed and aware of the best services that we can offer you. By consenting to receive additional communications by email from us we will process your personal data in accordance with this privacy policy.
If you have provided your consent to receive marketing communications from us and you change your mind, you can change your preferences and unsubscribe at any time by following the opt-out links of any marketing message. If you choose not to receive this information we will be unable to keep you informed of new services that may interest you. We may use the services of third party partners to send and manage our marketing communications.
As detailed at section 5, we may send you communications such as those which relate to any service updates. We consider that we can lawfully send these communications to you as we have a legitimate interest to do so, namely to effectively provide you with the best service we can and to grow our business.
We may share your personal data with the parties set out below for the purposes set out in the table above.
External Third Parties:
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
We use the widespread SSL (Secure Socket Layer) method in conjunction with the highest level of encryption supported by your browser. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period if there is a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
When we have no ongoing purpose to justify the processing of your personal data, we will either delete or anonymise it, or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
Where we act as a processor to provide the Mistho Service, as set out in sections 2.2 and 5.3, we will retain your personal data for the period instructed by the Partner, acting as controller, and will securely delete or return the personal data to the Partner at the end of that period, unless we are required to retain a copy to satisfy any legal, regulatory, tax, accounting or reporting requirements.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
If you wish to exercise any of the rights set out above where we are acting as controller over your data, please contact us using the details at section 2.5. If you wish to exercise any of the rights set out above where we are acting as processor in relation to the Mistho Service, please contact your selected Partner directly.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.