Our Privacy Policy
Last Modified: July 28, 2023
This privacy policy explains what you can expect from us and what we need from you in relation to your personal data. Please read this carefully as this policy is legally binding when you use our Services.
Who we are
We are Lakoos, a trading name of Paymenex Limited (“we”, “our”, “us”, “Paymenex” "Lakoos"), and we own and operate Lakoos Mobile App, OrbitOS Digital Banking, Payment and Agency network.
Paymenex Limited is registered in the England with company number 13573258 and our registered address is at 20 Old Bailey, London EC4M 7AN United Kingdom. Paymenex Limited is authorised by the Financial Conduct Authority as a Payment Institution (Firm Reference Number 591757), and also registered with the UK data protection authority (the Information Commissioner’s Office or “ICO”) under number C1370701.
Lakoos respects your privacy and is committed to protecting your personal data
This privacy notice aims to give you information on how Lakoos collects and processes your personal data through your use of Lakoos website or mobile app, including any data you may provide when you sign up or use our agency network. This notice applies when you download or visit and use our App or Website, and it sets out who we are, and how, and why we use your personal data. It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice, our Cookie Notice, Website and App Terms and Conditions of Use, our partner service terms and conditions, outline how we provide services to you through our App and Website. If you have any questions about this notice or our use of your data, please email us at privacy@lakoos.com
Lakoos is your Data Controller
Paymenex Limited the operator of Lakoos mobile app and website is the Data Controller of your data, we’re responsible for your personal data processed in relation to your use of the products and services accessible on Lakoos and Paymenex network. When you receive services through Lakoos mobile app, website, and agency network, we collect, process, use and are responsible for certain personal data about you. When we do so, we are regulated under the applicable laws on the protection of personal data, privacy and electronic communications.
Complaint
If you have any complaint about our use of your data, please email us at privacy@lakoos.com
If you are not happy with our resolution you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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 feel free to contact us in the first instance, using the contact details above.
Personal data we collect
We collect personal data for a variety of reasons, including to meet our legal obligations, manage our operations, improve our business and deliver our services and products to you. Below is a list of types of personal data that we may collect and use when you apply for, or use, any of our products or services.
| Type | Description | Purpose | Lawful basis |
| Personal and communication details | Your name, date of birth, addresses, country of residence, identity document, selfie, e-mail addresses, mobile phone numbers, Phone book and contact list, social media accounts and other ways in which to contact you. | Managing our relationship with you or your business. Communicating with you about our products and services, and products and services of our partners delivered through us. Delivering the Paymenex products and services to you, including to facilitate your use of the different Paymenex services, including our partner's services via single sign-on If you consent, we will access and retrieve names and mobile numbers of your contact list or phone book to enable you see your contacts on Lakoos app or transact with them. Developing and carrying out marketing or business development activities. |
Fulfilling our contract with you. When it is our legal duty. When you consent to it. When it is in our legitimate interest to:
|
| Transactional | Details about the transactions you carry out and the payments to and from your accounts with us, including your transactions on your accounts with our partners linked to Paymenex super app | Making and managing customer payments. Delivering our and our business partners’ products and services. Managing fees, charges, subscriptions, and interest due on customer accounts. Collecting and recovering money that is owed to us. |
Fulfilling our contract with you. When it is our legal duty. When you consent to it. When it is in our legitimate interest to:
|
| Contractual | Details about the products or services we provide to you, including the products and services of our partners | Carrying out our obligations arising from and exercising our rights set out in our contracts. Collecting and recovering money that is owed to us. Operating our business in an efficient and proper way, including managing our financial position, business capability, planning, and audit. |
Fulfilling our contract with you. When it is our legal duty. When you consent to it. When it is in our legitimate interest to:
|
| Locational | Data we get about where you are. This may come from the IP address assigned to your mobile phone or computer when you connect to the internet. It may also include locations where you used your Paymenex payment card or post codes. | Delivering our and our business partners’ products and services.
Identifying, investigating, reporting and preventing fraud, security breaches, money laundering and other crime. |
Fulfilling our contract with you. When it is our legal duty. When you consent to it. When it is in our legitimate interest to:
|
| Behavioural | Details about how you use products and services offered on the Paymenex Platform from us and other organisations | Studying how our Members use products and services from us and other organisations.
Delivering more personalised user experiences to our Members. Developing and carrying out marketing or business development activities. |
Fulfilling our contract with you. When it is our legal duty. When you consent to it. When it is in our legitimate interest to:
|
| Technical | Details on the devices and technology you use, for example your website browser settings, mobile app operating system version details and marketing choices. | Delivering our products and services to you. Delivering our and our business partners’ products and services. Identifying, investigating, reporting and preventing fraud, money laundering and other crime. Developing and carrying out marketing or business development activities. |
Fulfilling our contract with you. When it is our legal duty. When you consent to it. When it is in our legitimate interest to:
|
| Communication | Any emails, SMS, InApp messaging, calls or other communications you’ve sent to us or we’ve sent to you
What we learn about you from communications between us |
Investigating and responding to your enquiries, complaints and feedback. | Fulfilling our contract with you. When it is our legal duty. When you consent to it. When it is in our legitimate interest to:
|
| Public and third-party records | Details about you that are in public records, such as the Electoral Register, Companies House, and data about you that is publicly available on the Internet. We also collect data about you which we receive from other companies, such as credit reference, our partners or fraud protection agencies like the CIFAS register. | Identifying, investigating, reporting and preventing fraud, money laundering and other crime. Registering you with a Paymenex account. Developing and carrying out marketing or business development activities. |
Fulfilling our contract with you. When it is our legal duty. When you consent to it. When it is in our legitimate interest to:
|
| Usage data | Other data about how you use our products and services | Studying how our Members use products and services from us and other organisations Testing or Piloting new products Managing how we work with other companies that provide services to us and our Members |
Fulfilling our contract with you. When it is our legal duty. When you consent to it. When it is in our legitimate interest to:
|
| Documentary data | Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport, driver’s licence, national identity card, voter's card, photographs or birth certificate. |
Identifying, investigating, reporting and preventing fraud, money laundering and other crime.
Complying with laws and regulations.
|
Fulfilling our contract with you. When it is our legal duty. When you consent to it. When it is in our legitimate interest to:
|
| Consents | Any permissions, consents or preferences that you give us | So we know what your preferences are in regards to marketing, automated decision-making and profiling (where this activity is based on your consent), cookies and any other relevant processing activities that you can opt-out of. Developing and carrying out marketing or business development activities. |
Fulfilling our contract with you. When it is our legal duty. When you consent to it. When it is in our legitimate interest to:
|
| Special category data and criminal offence data | Categories of data defined as ‘special category’ or ‘sensitive’ by applicable laws, including personal data related to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union members, genetic data, biometric data, health, sex life or sexual orientation. We may also process data about your criminal offence history. In particular, we may collect data related to your health (such as disability data), biometric data (photos of you) and racial or ethnic origin (how you identify your ethnicity). |
Understanding our community and the type of Members we work with, including about ethnicity, gender and health.
Operating our business in a proper way, including corporate responsibility. |
Fulfilling our contract with you. When it is our legal duty. When you provide explicit consent. It is in the public interest. It is in your vital interest to protect yours or someone else’s life. |
| Your customer or employee data | Any data that you provide us with about your employees or customers including contact details, personal details (e.g., name, date of birth, bank account information) in our capacity as your data processor. | Delivering our and our business partners’ products and services to you. | When you have instructed us to do so and by virtue of your existing contractual relationship with us. |
Who does Lakoos share my personal information with?
We may share your information with selected third parties who provide data processing services to us, or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.
Affiliates, business partners, suppliers and sub-contractors for the performance and execution of any contract we enter into with them or you.
Advertisers and marketing networks solely to select and serve relevant adverts to you and others.
Analytics and search engine providers that assist us in the improvement and optimisation of our website, such as Google.
The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found via the following link https://www.cifas.org.uk/fpn
Where we store your personal data
We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include: physical access control systems, a physical security presence, role-based access control, encryption, firewall, vulnerability management.
The data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom or the European Economic Area ("EEA"). It may also be processed by staff operating outside the UK and EEA who work for Paymenex or for one of our business partners or suppliers. Such partner or staff may be engaged in, among other things, the fulfilment of your payment order, processing of your payment details and provision of account support service. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
Data Retention
We will keep your personal data as long as you are a customer of Paymenex. We may keep your personal data after you stop being a customer. The reasons we may do this are:
To respond to a question or complaint, or to show whether we gave you fair treatment
To establish, exercise or defend our legal claims
To study customer data as part of our own research when this will not cause harm to your privacy and personal data protection rights
To comply with legal rules that apply to us about keeping records or information in which case we will retain your data for a minimum of six years after your account has been terminated or longer depending on domestic laws.
We will always delete data that is no longer required by a relevant law or jurisdiction in which we operate.
Cookies and other tracking technologies
Paymenex Services use cookies to distinguish you from other users. This helps us to provide you with a good experience and also allows us to improve our Services. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.
Your rights
You have the right to ask us not to contact you for marketing purposes by contacting us at privacy@Paymenex.com, or by adjusting your notification preferences in the Paymenex Mobile app or online account area.
You have the right to ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which Paymenex Limited is subject to.
You have the right to transfer your personal data between data controllers, for example, to move your account details from one online platform to another.
You have the right to correct any personal information we hold on you that is inaccurate, incorrect, or out of date.
Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.
