Contact details:

Post: Fox Court, 14 Gray's Inn Road, LONDON, WC1X 8HN, GB
Email: compliance@lapay.co.uk

What information we collect, use, and why:

We collect or use the following information to services and goods, including delivery:

• Names and contact details
• Addresses
• Dateof birth
• Purchase or account history
• Payment details (including card or bank information for transfers and direct debits)
• Account information
• Website user information (including cookie tracking)
• Photographs or video recordings
• Identification documents

We also collector use the following information toprovide services and goods, including delivery:

• Biometric information (where used to identify someone)

We collect or use the following information forthe operation of customer accounts and guarantees:

• Names and contact details
• Addresses
• Payment details (including card or bank information for transfers and direct debits)
• Purchase history
• Account information, including registration details
• Information used for security purposes
• Marketing preferences

We also collector use the following information forthe operation of customer accounts and guarantees:

• Biometric information (where used to identify someone)

We collect or use the following information forservice updates or marketing purposes:

• Names and contact details
• Marketing preferences
• Location data
• IP addresses

We collect or use the following information tocomply with legal requirements:

• Name
• Contact information
• Identification documents
• Financial transaction information

We also collector use the following information tocomply with legal requirements:

• Biometric information (where used to identify someone)

We collect or use the following personal information fordealing with queries, complaints or claims:

• Names and contact details
• Address
• Payment details
• Account information
• Purchase or service history
• Customer or client accounts and records
• Financial transaction information

Lawful bases and data protection rights:

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’swebsite.
Which lawful basis we relyon may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.You can read more about this right here.
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.You can read more about this right here.
• Your right to erasure - You have the right to ask us to delete your personal information.You can read more about this right here.
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information.You can read more about this right here.
• Your right to object to processing - You have the right to object to the processing of your personal data.You can read more about this right here.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organization, or to you. You can read more about this right here.
• Your right to withdraw consent - When we use consent as our lawful basis you have the right to withdraw your consent at anytime.You can read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data:

Our lawful bases for collecting or using personal information to provide services and goods are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carryout a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests – we’recollecting or using your information because it benefits you, our organization or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  We process your personal data for particular purposes in connection with your payment or engagement with us or use of the Services, and the management and administration of our business. We are required by law to always have a so-called “lawful basis” (i.e. a reason or justification) for processing your personal data. Please note that where we have indicated that our processing of your personal data is either:
  (a) necessary for us to comply with a legal obligation; or (b) necessary for us to take steps, at your request, to potentially enter into a contract (including for payments) with you, or to perform it, if you choose not to provide the relevant personal data to us, we may not be able to accept your payment or otherwise provide our services to you.

Our lawful bases for collecting or using personal information for the operation of customer accounts and guarantees are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carryout a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests – we’recollecting or using your information because it benefits you, our organization or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.

Our lawful bases for collecting or using personal information toprevent, detect, or investigate crimes are:

• Legal obligation - we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for service updates or marketing purposes are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at anytime.
• Legitimate interests - we’recollecting or using your information because it benefits you, our organization or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.

Our lawful bases for collecting or using personal information for legal requirements are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at anytime.
• Contract - we have to collect or use the information so we can enter into or carryout a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation - we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at anytime.
• Contract - we have to collect or use the information so we can enter into or carryout a contract with you. All of your data protection rights may apply except the right to object.
• Legal obligation - we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests - we’recollecting or using your information because it benefits you, our organization or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.

Where we get personal information from

• Directly from you
• Publicly available sources
• Suppliers and service providers

How long we keep information

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this notice, including to comply with legal, regulatory, tax, accounting, or reporting requirements. Below is an overview of our retention periods:

• Directly from you
• Publicly available sources
• Suppliers and service providers

Category of Data	Purpose	Retention Period	Legal Basis
Customer Identification Data	To meet anti-money laundering (AML) and KYC obligations	5 years after the business relationship ends or the last transaction	Legal obligation under AML regulations (e.g., UK MLR 2017)
Transaction Data	To process payments and provide transaction history	6 years after the transaction date	Legal and regulatory requirements (FCA rules)
Contractual Data	To manage contractual obligations and disputes	6 years after the termination of the contract	Statutory limitation period for legal claims (Limitation Act 1980)
Marketing Preferences	To provide direct marketing communications	Until consent is withdrawn or data becomes inactive for 12 months	Consent or legitimate interest
Customer Support Data	To resolve queries and disputes	3 years after the last interaction	Legitimate interest in handling customer queries
Financial Records	To comply with tax and accounting laws	6 years from the end of the financial year	Legal obligation (HMRC requirements)

Category of Data	Purpose	Retention Period	Legal Basis
Regulatory Compliance Data	To comply with FCA and other regulatory requirements	6 years after the business relationship ends	Legal obligation
Security and Monitoring Data	For fraud prevention and security (e.g.,login records)	12 months unless required longer for investigations	Legitimate interest in ensuring security

Exceptions to Retention Periods

In some cases, we may retain your data for longer periods if:

• Required by applicable law or regulation.
• Necessary to establish, exercise, or defend legal claims.

Anonymized Data

Where feasible, we will anonymize your personal data to retain it for statistical or analytical purposes without further notice.
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Who we share information with:

Data processors (Sum and Substance Ltd. (Sumsub)):
This data processor does the following activities for us: To provide Services, Sumsub processes Personal data according to our instructions.

Others we share personal information with:

• Organizations we need to share information with for safeguarding reasons
• Financial or fraud investigation authorities
• Relevant regulatory authorities
• External auditors or inspectors
• Professional consultants
• Organizations we’re legally obliged to share personal information with

How to complain:

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Information Commissioner’s Office Wycliffe House
Water Lane Wilmslow
Cheshire SK9 5AF
Helpline number: 0303 123 1113
Website:https://www.ico.org.uk/make-a-complaint

Last updated

21 January 2025