Ready – Privacy Policy
This Privacy Policy applies to the Ready app and any other application, website or web service (together, the “Platform”) operated by ARGENT LABS LIMITED, company number 11093638, of 5 New Street Square, London, England, EC4A 3TW, doing business as “Ready” (“Ready”, “we”, “our” or “us”). Ready is the controller of personal data where it determines the purposes and means of processing. Third parties whose products or services you access through the Platform (including card issuers, payment providers, digital asset platforms and suppliers of partner benefits) may be separate controllers of information they process for their own purposes. Their privacy notices also apply to that processing.
1. Introduction
This Privacy Policy explains who we are, why and how we process personal data collected through your use of the Platform and, if you are the subject of any of the personal data concerned, what rights you have and how to get in touch with us if you need to.
When you supply any personal data to us we have legal obligations towards you in the way we use that data. We must collect the information fairly and explain to you how we will use it. For ease of reading, we have divided this Privacy Policy into several sections:
Introduction
What information we collect
How and why we use/share your information
How long we keep your information
Security
International Data Transfers
Your Rights
Contact Details
It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice that we may provide at or around the time that we collect or process personal data about you so that you are fully aware of how and why we are using that data.
This Privacy Policy supplements other notices and legal documents including the Terms of Service (“Terms”) and is not intended to override or replace them.
This Privacy Policy is a notice about how personal data is processed, not a contract or a request for your consent. Where we require your consent for a particular use, we will request it separately.
We may update this Privacy Policy as our services, processing activities or legal obligations change. We will make the current version available through the Platform and, where required, draw material changes to your attention before the relevant new processing begins.
Please note that the Platform is not intended for use by nor directed at anyone under the age of 18 and we do not knowingly collect data relating to children. If you believe we have collected personal information about your child, you may contact us at legal@ready.co and request that we remove information about them.
2. What information we collect
2.1 What is personal data?
Where this Privacy Policy refers to ‘personal data’ it is referring to information relating to an identified or identifiable person, directly or indirectly – for example, your name, contact details, online identifiers or a wallet address associated with you.
By law all organisations who process your personal data in the UK and Europe are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the ‘Your Rights’ section of this Privacy Policy.
2.2 How and what types of data we collect from you when you use the Platform
When you use the Platform to register an account, fill in forms provided on the Platform, subscribe to our services or report a problem with the Platform, we may collect, store and use certain personal information that you disclose to us. Some information is necessary to create or maintain an account, provide a feature you request or meet applicable legal requirements. If you do not provide it, we may be unable to provide the relevant service. Information requested solely to redeem an optional partner benefit is not required to use unrelated Platform features.
Depending on the features you use, the information we collect may include: contact and account details (such as your email address, telephone number, account identifiers and login information); information you provide to customer support; wallet addresses, publicly available blockchain transaction references and information about activity involving the Platform; subscription, card, transaction, eligibility and rewards records; and, when you request a partner benefit, the identifiers needed for redemption (such as a Discord username, Twitch ID, WhatsApp number or email address). We collect identity-verification, compliance or payment information only to the extent relevant to services actually offered to you or information lawfully received from their providers. Where identity verification is required, our verification provider may collect a selfie or short video of your face to compare with your identity document (biometric data). Ready does not receive or store these images.
We shall also collect information about you when you visit and interact with the Platform through the use of technologies such as cookies. The following are examples of information we may collect:
information about your device, browser or operating system;
time zone setting;
your IP address;
information about interactions you have with the Platform (such as scrolling and clicks);
information about the way you use and the actions you take within the Platform;
length of time on the Platform and time spent within certain sections;
response times; and
download errors.
You can manage certain technologies through your device, browser or in-app privacy settings. Where applicable law requires consent for cookies, mobile identifiers or other non-essential storage and access technologies, we must obtain that consent or rely on an applicable statutory exception. Disabling a technology may affect particular functions of the Platform.
We may use analytics and other technology providers to help us understand, maintain and improve the Platform. Information received by those providers may include device, event and usage data and is not necessarily anonymous merely because it is used for statistical purposes. We apply the lawful basis and privacy controls appropriate to the particular processing.
Where enabled, the Platform may use mobile advertising identifiers (such as Android advertising IDs or Apple advertising identifiers), analytics technologies or similar device-level signals to measure usage or campaigns and, where lawful, to support advertising. We will apply the permissions, user choices and consent requirements relevant to those technologies, including those applicable to non-essential tracking or advertising. We will not treat a device setting or acceptance of this Privacy Policy as a substitute for consent where consent is required.
Sources of personal data
We receive personal data directly from you, automatically through your use of the Platform and, where relevant, from third-party services that you elect to use, including identity-check, payment, card, digital asset, referral, customer-support and benefit-fulfilment providers. Those third parties may tell us, for example, whether you qualify for a feature, whether a redemption has been completed or whether an account or transaction needs support. We may also use information visible on public blockchains where relevant to the Platform. A wallet address or transaction record may be personal data when it can be associated with an identifiable individual.
Updating your information
If you want to update the information you have previously given to us, you can contact us at legal@ready.co.
3. How and why we use/share your information
Lawful basis for processing your information
We process personal data only where we have a lawful basis. Depending on the relevant purpose, this may be performance of a contract with you, compliance with a legal obligation, our or a third party’s legitimate interests where those are not overridden by your rights, or consent where required. The main purposes and our usual bases are described below; a separate, feature-specific notice may provide further detail.
Where you have given valid consent for a specified purpose;
Where we need to do so in order to perform a contract we have entered into with you;
Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and
Where we need to comply with a legal or regulatory obligation.
Purposes for which we use personal data
Providing accounts and requested services: we use account, device, wallet, transaction and contact details to operate the Platform, deliver features you request, administer subscriptions and deal with support requests. Our basis is performance of our contract with you where the processing is objectively necessary for that service, or our legitimate interests in operating and supporting our services where that basis is appropriate. Where you request card-related functionality, we may also use relevant account identifiers, eligibility outcomes, transaction references and support information to facilitate access and coordinate with the Card Issuer and programme providers. Those providers are responsible for explaining any processing for which they act as independent controllers.
Security, prevention of misuse and compliance: we use relevant records to secure the Platform, investigate suspicious activity, respond to complaints and disputes, protect users and enforce applicable terms. We rely, as appropriate, on our legitimate interests in preventing fraud and protecting our business and users, or on legal obligations where applicable.
Analytics, service improvements and business administration: we use usage, diagnostic and operational information to maintain, troubleshoot and improve our products, measure performance and administer our business. We generally rely on legitimate interests in providing secure and effective services, subject to your rights and any separate consent or other requirements that apply to tracking technologies.
Rewards and partner benefits: when you elect to claim a Ready reward or third-party perk, we use eligibility, offer, redemption and relevant account-identifier information to administer the request, check entitlement, transmit the minimum details needed by the fulfilment partner, resolve failures and prevent duplicate or fraudulent claims. We rely on performance of the applicable offer arrangements where processing is necessary to supply the benefit, or otherwise on our legitimate interests in providing and administering user-requested benefits, subject to a balancing assessment. We will obtain consent separately where a specific use requires it.
Marketing and promotional communications: we process relevant contact and preference information on the basis of consent or, where the applicable direct-marketing rules permit, our legitimate interests and a valid existing-customer exception. You may object to direct marketing at any time.
Marketing
We may send you promotional communications where you have consented or where applicable direct-marketing rules permit us to do so, including where a valid existing-customer exception applies. Providing feedback or simply using the Platform does not, by itself, amount to consent to marketing or establish that an exception applies. We do not treat requesting a partner perk as permission for that partner to send you unrelated marketing.
To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email and update your account preferences. You may also contact us to inform us if you do not wish to receive any marketing materials from us.
Sharing your information
Depending on how and why you provide us with your personal data, we may share it in the following ways:
we may share your personal information with any member of our group where there is a valid and lawful reason to do so, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
with relevant card issuers and programme operators, payment and digital asset service providers, identity or eligibility-verification providers, and other independently operated services where this is necessary or appropriate for a service you request, a permitted integration, security or compliance;
with analytics and technology providers that help us measure, secure, maintain and improve the Platform, subject to applicable privacy and tracking requirements.
Partner rewards and perk redemptions
If you choose to claim a perk supplied by a third-party partner (for example, a Twitch subscription, community access or another promotional benefit), we may ask you for the contact details or service identifier needed for that perk, including a Twitch ID, Discord username, email address or WhatsApp number. We may disclose that information, your redemption reference and relevant eligibility or fulfilment status to the named partner or its fulfilment provider solely as reasonably necessary to validate, provide, support or administer the selected perk. We will identify the relevant fulfilment partner and the information required at or before the redemption step. If you do not provide information needed for a particular perk, we may be unable to arrange it, but that will not by itself prevent you using unrelated features of the Platform.
A partner may act as an independent controller when it determines how to fulfil a benefit through its own systems, accounts or services; in that case its privacy notice applies to its independent processing. In other cases a provider may process data on Ready’s instructions. Sharing data to fulfil your request does not, by itself, authorise the partner to use it for its own unrelated marketing or other incompatible purposes. A partner’s separate use of information is subject to its own legal obligations.
We may also disclose your personal information to third parties in the following events:
if we were to sell or buy any business or assets, in which case we might disclose your personal information to the prospective seller or buyer of such business or assets;
if Ready or substantially all of its assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets; or
if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply the Terms; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Service Providers
We use service providers for hosting, communications, analytics, support, security, technical operations, payments and other functions. We provide them with personal data appropriate to the services they perform. Where a provider acts as our processor, we require appropriate contractual terms addressing permitted use, confidentiality, security, sub-processors and assistance with data-protection obligations. Providers and integrations may change over time; the categories above, additional notices in the relevant feature and any information supplied on request should be used to understand the recipients relevant to a particular service. Some third-party providers also act as independent controllers, rather than processors acting only on our instructions.
Other Disclosures
During your use of the Platform, your app store provider and mobile network operator may also collect personal information about you regarding your use of the Platform such as your identity, your usage and location.
These third parties shall act as separate and independent controllers of that personal data and shall process it in accordance with their own privacy policy.
Links to third party sites
The Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. We may also provide links to third party websites that are not affiliated with the Platform. Third party websites are out of our control and are not covered by this Privacy Policy. If you access third party sites using the links provided, the operators of these sites may collect information from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those websites.
4. How long we keep your information
We will hold your personal information on our systems only for as long as required to provide you with the products and services you have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
For account, subscription, reward and perk-redemption records, we consider the time required to deliver and verify the service or benefit, deal with support issues, prevent abuse, keep necessary audit records, meet accounting and regulatory obligations and establish or defend claims. We do not retain information merely because a particular promotion has ended where there is no continuing purpose for retaining it. Retention periods and criteria may differ for transaction, security and compliance records and for information independently held by third-party providers.
In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
5. Security
We implement technical and organisational measures designed to protect personal data against accidental loss, unauthorised access, alteration and disclosure. Depending on the data and service, these may include access controls, encryption, monitoring and incident-response processes. No system can be guaranteed completely secure, and the appropriate safeguards may change as our technology evolves. Ready’s non-custodial wallet model does not mean that Ready has custody of your private keys or can reverse transactions recorded on public blockchains.
Where we have given you a password that enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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. Providers acting as our processors must act on our instructions under appropriate contractual and confidentiality safeguards. Independent controllers remain responsible for their own processing.
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.
6. International Data Transfers
Some providers and collaboration partners with whom we share personal data may be located outside the UK or the European Economic Area (“EEA”), or may access information from those locations. International transfers may arise in connection with hosting, support, payment or card services, verification and requested partner benefits.
Where a transfer is restricted by applicable UK or EEA data-protection law, we use a permitted transfer mechanism and any supplementary measures or assessments required in the circumstances. Depending on the destination and the parties involved, the transfer may be based on:
to a country recognised by the European Commission and/or the UK Secretary of State as providing an adequate level of protection; or
an appropriate transfer mechanism, such as the European Commission’s standard contractual clauses, the UK International Data Transfer Agreement or UK Addendum, together with additional safeguards where needed; or another mechanism permitted by applicable data-protection law.
You may contact legal@ready.co for further information about the safeguards relevant to a transfer and, where applicable, how to obtain a copy. This Privacy Policy and the act of providing personal data are not, by themselves, consent to an international transfer or a substitute for a legally valid transfer mechanism.
7. Your Rights
As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have as well as how you can exercise them.
Right of Access
You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).
Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, and does not necessarily entitle you to copies of particular documents as such, although relevant documents may be provided where needed to give you access to your personal data.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.
Your Right to Rectification and Erasure
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right.
You may also ask us to erase personal data where a legal ground for erasure applies. There are exceptions, including where information must be retained for a legal obligation or to establish, exercise or defend claims. Some information placed on a public blockchain, including wallet addresses and transaction metadata, may be replicated and technically immutable. Ready cannot generally erase information from an independent public blockchain, although we will assess requests concerning any associated personal data that we control.
We assess erasure requests against the applicable legal grounds and exceptions. We may retain information where the law permits continued processing, for example to comply with a legal obligation or to establish, exercise or defend legal claims.
If erasure is not technically possible or we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you this and our reasoning at the time we respond to your request.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.
Your Right to Restrict Processing
You may ask us to restrict our processing of your personal data in certain circumstances, including while we verify disputed accuracy or consider an objection, where processing is unlawful but you prefer restriction to erasure, or where you need information preserved for legal claims. Your separate right to object to processing based on legitimate interests is explained below.
While a restriction applies, we will generally continue to store the relevant information but will not otherwise use it except where permitted by law, such as with your consent or for the establishment, exercise or defence of legal claims.
If we cannot comply with a restriction request, we will explain the relevant basis for our decision.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are requesting restriction of processing and identifying the relevant information. You do not have to fill in a specific form to make this kind of request.
Your Right to Portability
Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.
This right applies in the circumstances specified by law, generally where information you provided to us is processed by automated means on the basis of consent or contract. It does not automatically apply to every record held by Ready, including information we receive from third parties or derive independently. We will assess any request against the applicable requirements.
Your Right to object to processing
You may object to processing based on our legitimate interests (including profiling based on that basis) for reasons relating to your particular circumstances. We will stop unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is needed for legal claims. You have an unconditional right to object to the processing of your personal data for direct-marketing purposes at any time; we will stop using it for that purpose.
Your Right to stop receiving communications
For details on your rights to ask us to stop sending you various kinds of communications, please contact us.
Your rights relating to automated decision-making and profiling
If we use solely automated processing to make a significant decision about you that has legal or similarly significant effects, we will provide the information and safeguards required by applicable data-protection law, which may include rights to request human involvement, make representations or challenge a decision. Routine automated security, eligibility or analytics checks do not necessarily amount to such decisions. You may contact us to ask whether a significant decision affecting you was made solely by automated means.
Withdrawal of consent
Where we are relying on consent to process your personal data you may withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You can withdraw consent by contacting legal@ready.co or using a relevant preference control where available.
Exercising your rights
We may take reasonable, proportionate steps to verify your identity before disclosing or changing personal data. We will not routinely require a copy of identity documentation where less intrusive verification is sufficient.
Please describe the right you wish to exercise and any information that helps us locate the relevant data. We will respond within the time limits prescribed by applicable law, subject to any lawful extension or exemption, and will explain where further information is genuinely necessary to handle the request.
8. Contact Details
If you have any queries regarding this Privacy Policy, if you wish to exercise any of your rights set out above or if you think that the Privacy Policy has not been followed, please contact us by emailing at legal@ready.co.
You may complain to us about our handling of personal data by emailing legal@ready.co. We will acknowledge a data-protection complaint within 30 days, investigate it appropriately, keep you reasonably informed of progress and inform you of the outcome in accordance with applicable law. You also have the right to complain to the Information Commissioner’s Office (ICO) in the UK (www.ico.org.uk), or to an appropriate EEA supervisory authority where applicable, without first having to obtain a response from us.