Fair Processing Notice

We are Juni Capital Ltd. (‘we’, ‘our’, ‘us’) and operate under the business name Juni. We are registered with the Companies House (registration number 13687134), and with a registered address at Suite 1, 3rd Floor 11 - 12 St James’s Square, London SW1Y 4LB, United Kingdom.

For the purposes of data protection law, we are a data controller in respect of the personal data we receive from you, or otherwise collect about you, and we are responsible for ensuring that we use your personal data in compliance with applicable data protection laws in the EU, European Economic Area (EEA) and the UK, such as Regulation 2016/679 (‘General Data Protection Regulation’).

This notice (“Fair Processing Notice”) explains what personal data we collect from you and how it will be used by us and why.

Setting the scene

We provide Juni customers with credit lines for their business, with a special focus on ecommerce businesses. We do so in collaboration with Juni Technology AB (registration number 559248-0908), and with a registered address at Kungsportsavenyn 21, 411 36 Gothenburg, Sweden. Juni Technology AB is a distributor of Payrnet Limited (registration number 09883437), with a registered address at Kemp House, 152 City Road, London EC1V 2NX, United Kingdom, a company authorised by the Financial Conduct Authority under the Electronic Money Regulations 2011 (register reference 900594) for the issuing of electronic money.

We are authorised and regulated by the Financial Conduct Authority and registered with the UK data protection authority (Information Commissioner’s Office or ICO) under number ZA841298 and registered as an Annex I financial institution under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 under number 964212.

What we do when you apply

Before we provide services to you, we will need to collect certain details from you for the purpose of entering into an agreement with you to provide you credit, in order to undertake checks for the purposes of preventing money laundering and to verify your identity.

Please note, this Fair Processing Notice only applies to the processing done by Juni Capital Ltd. during and following the application process for the provision of credit to you, including the data processed to provide you with such credit in compliance with applicable law and legislation. It does not include any processing done by Juni Technology AB which may take place for other purposes, including providing you with payment or e-money services. For more information on this processing, please consult the Juni Privacy Policy.

What data we share and process

We will collect and process the following personal data about you:

Information you give us when signing up for Juni, creating an application for credit, interacting with our representatives or that is created when you use the Juni payment services (“Juni Account Information”), including: 

  • Personal details, such as the full name and date of birth of the applicant (authorised representative of the company), the Director(s), and any ultimate beneficial owners of the relevant company.
  • Contact details, such as the address of the applicant, Director(s), any ultimate beneficial owners, and the applicant’s email.
  • Information about your identity, such as a copy of your passport or relevant identification verification document.
  • Information about your Juni cards, including the card number, expiry date, and CVC. 
  • Details about transactions made with your Juni card and on integrated accounts, including the date, time, amount, currencies, exchange rate, beneficiary details, details of the merchant or ATMs associated with the transaction (including merchants’ and ATMs’ locations), IP address of sender and receiver, sender's and receiver's name and registration information, messages sent or received with the payment, details of device
  • used to arrange the payment, and the payment method used.
  • Your email when you contact us via the Juni chat.
  • Your email address and the contents of your communication.
  • Public details from your social media profile (e.g. Facebook) if you reach out to us via these platforms, and the contents of your messages or posts to us.

Information we receive about you from third parties (“Third Party Information”): 

When you register with us, we also run checks on your records at:

  • fraud prevention agencies, KYC (Know-Your-Customer) and anti-money laundering service providers to meet our regulatory obligations; 
  • bank accounts for which we have received transaction information through the integration  between such bank accounts and the Juni website provided by account information service providers (e.g. Yapily Ltd. or Salt Edge Limited);
  • ad networks with which you have integrated through the Juni website to allow us to receive information about your activity on such ad networks (e.g. Google Ads); and
  • credit reference agencies to help us verify your identity, determine whether we can offer you our services, and calculate your risk profile. The information includes financial transactions, balances, identity and investments.

Information we collect about you and your device (“Technical Information”)

Each time you use the Juni website, we will automatically collect Technical Information about your computer or other internet connected device including your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our site, and other technical information. 

You may be able to disable the collection of some of this data through amending the web settings of your device or browser but doing so may impact the functionality of our website. For more information, please consult the Juni Cookie Policy.

We may combine Volunteered Information with Third Party Information (“Combined Information”) and may use both these categories of information and the Combined Information for the purposes set out below.

How we use the data we collect on you

Administration

Identification and verifying information 

This includes the processing of any information so as to identify you; verify such identification; complying with legal, regulatory and compliance obligations that apply to us (for example, anti-money laundering and counter terrorism checks) and detection and prevention of fraud and other crimes; and account management.

General administration 

This includes tax administration; auditing; reporting and accounting functions; statistical analysis and market research; market, regulatory and operational risk management.

On which basis we process your personal data

Contractual obligations

To meet our contractual obligations towards you and be able to offer you our services, we need to use the personal data as described above.

Legal obligation

In some cases, we need to collect and retain your personal data in order to comply with applicable laws and regulations. For example, we must keep certain personal data about our customers to meet legal obligations imposed by anti-money laundering legislation.

Legitimate interest

We might use this legal basis to collect and process your personal data, or share it with other organisations, to pursue our legitimate interests provided that the latter are not overridden by your interests, rights, or freedoms.

Consent

This legal basis applies when you have affirmatively consented to us collecting your personal data. This is usually the case when you indicate that you agree that your personal data is collected, e.g. by ticking a box. In cases where we process personal data based on your consent, you reserve the right to revoke this consent at any time. For more information, please refer to section “How to exercise your rights”.

Substantial public interest

Sometimes we will collect your personal data in order to perform a task in the public interest that is set out in law.

Credit search facility

If you decide to proceed with an application with us, we will use your information to obtain credit and identity checks on your business with one or more credit reference agencies (“CRAs”).

To do this, we will supply your business registration number  to CRAs and they will give us information about your business. This will include information from your credit application and about your business’ financial situation and financial history. CRAs will supply to us both public and shared credit, financial situation and financial history information and fraud prevention information.

We will use this information to:

  • Assess your creditworthiness;
  • Verify the accuracy of the data you have provided to us;
  • Prevent criminal activity, fraud and money laundering;
  • Manage your account(s);
  • Trace and recover debts; and
  • Ensure any offers provided to you are appropriate to your circumstances.

We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.

When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.

The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail at any of these three links: www.callcredit.co.uk/crain; www.equifax.co.uk/crain; www.experian.co.uk/crain.

Data retention and storage

All personal data you provide to us, or which we obtain from third parties, will be stored on our secure servers (or those of third parties or contractors we engage to help us run our business). All personal data is stored on our secure servers in accordance with the (United Kingdom) General Data Protection Regulation within the EEA and the UK. Where data is processed outside the EEA and/or the UK by our (sub)processors, we shall ensure that any related transfers are compliant with GDPR which can include transfers to countries that have been deemed compliant or transfers on the basis of Standard Contractual Clauses. 

To meet our regulatory obligations under anti-money laundering and e-money laws in the UK, we are required to keep your personal data as long as you are using our services, and some of your personal and transactional data for 6 years after our contract with you is terminated. In some cases, such as a potential or ongoing court claim, we might need to keep your personal data for longer.

Who we share your data with

Companies that provide services to Juni‍

In order to be able to offer our services and deliver a smooth and tailored experience to you, we have business relationships with a number of companies with whom we share your personal data. We will share as little information as possible with the third parties mentioned below:

  • KYC service providers that help us with verifying your identity and carry out fraud checks (iDenfy);
  • Cloud computing power and storage providers, and web hosting providers (Amazon Web Services);
  • Companies that allow you to connect your financial data (SaltEdge, Yapily/Safeconnect);
  • Banking-as-a-Service provider (Railsbank);
  • CRAs as described above; and
  • API providers allowing us to integrate with the CRAs (Noble).

 

We will share your personal data with fraud prevention agencies to verify your identity when you apply for an account with us. While you are our customer, we might need to share your information with them to assist in preventing fraud and money laundering when it is in our legitimate interest. Bear in mind that if fraud is detected, other organisations might also use this information to refuse their services, finance, or employment.

Law enforcement and other external parties

Juni may share your personal data with the following law enforcement and other external parties:

  • Police, courts, alternative dispute resolution bodies, and any other third party (for example, our regulators) to meet our legal obligations.
  • Other financial institutions, such as banks or e-money institutions, to assist their investigation of tracing your funds in case you have been a victim of fraud or there is an ongoing dispute claim about a payment.
  • Competent authorities that carry out financial crime, money laundering, terrorism and tax evasion investigations, if we are required to do so.

How to exercise your rights

If you wish to exercise any of the rights mentioned in the previous section, you may contact us via chat at the Juni website or send us an email at privacy@juni.co.  You may also contact us the same way in case you have any questions about this Fair Processing Notice. For security purposes, we will ask you to verify your identity when you submit a request.

How to lodge a complaint

You have the right to lodge a complaint with the Information Commissioner’s Office, the UK’s supervisory data protection authority.