This policy applies to your use of:
• Accountabl mobile application software (“App”) once you have downloaded or streamed a copy of
the App onto your mobile telephone or handheld device (“Device”)
• Accountabl website (“Website”) accessible via https://accountabl.eco and online web applications
(“Expense Portal”) accessible via https://portal.accountabl.eco
• Any of the services accessible through the App or Expense Portal or which we otherwise agree to
provide to you or your employer through any third-party software or application (“Services”)
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will
be processed by us. The App, Portal and Website are not intended for children and we do not knowingly
collect data relating to children. Please read the following carefully to understand our practices regarding
your personal data and how we will treat it.
2. Who we are
We are Expensemate Limited, trading as Accountabl (CRN: 12384812) (“we”, “us” or “our”). We are
responsible for the App, Expense Portal and Website and we are the controller in respect of all personal
data collected via the Services. We are registered as a controller with the Information Commissioner’s
Office and our registration number is: ZA743843.
3. Contact details
We will be happy to deal with any queries or requests regarding the data we hold about you.
You can contact us by:
• Email: firstname.lastname@example.org
• Post: Data Compliance Officer, 2 Humber Quays, Wellington Street, Hull, HU1 2BN
• Telephone: 01482 386 666
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, if you have any concerns with regard to the way in which we
have processed your personal data.
th June 2022. It may
change and if it does, these changes will be posted on this page and, where appropriate, notified to you.
The new policy may be displayed on-screen and you may be required to read and accept the changes to
continue your use of the App or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if
your personal data changes during our relationship with you.
5. Third party links
Our App, Expense Portal and Website may, from time to time, contain links to and from the websites of our
partner networks, advertisers and affiliates. Please note that these websites and any services that may be
accessible through them have their own privacy policies and that we do not accept any responsibility or
liability for these policies or for any personal data that may be collected through these websites or services,
such as Contact and Location Data. Please check these policies before you submit any personal data to
these websites or use these services.
6. Third Parties
Ordinarily, we will be the party collecting your information directly from you. However, there may be
situations where this information is obtained by us from third parties. Examples of this would include:
• Directly from a third party – e.g.
o credit reference agencies
o data providers for business development
• From a third party with your consent- e.g.,
o your bank or building society
o professional body
• From a third-party data profiling company, where you have given your consent for that company to
pass such information on to us from publicly available sources – e.g.,
o Electoral Roll,
o Companies House,
o HM Land Registry
o Government VAT checker
Sharing data with third parties including our service providers and suppliers;
We will never sell or rent our customer data to other organisations for marketing purposes. We will not sell,
distribute or lease your personal information to third parties for their control unless we have your permission
or another lawful basis to do so (e.g., our legitimate interests (so long as our interests are not overridden by
the impact on you), a contractual obligation to you or a legal requirement to do so). Where we do seek your
permission, we will name the relevant third party at the time we seek such permission from you and any
such permission shall be limited to that third party. Please note that we may provide information for
processing to certain third parties as outlined in the following paragraph and also in section 9 below.
In order to make certain services available to you, we may need to share your personal data with some of
our service partners. These include:
• The Accountabl app (available through the Apple Store and Google Play Services)
• The ERP ecosystems for customer management (available through Hubspot.)
• We may also appoint third party data profiling companies to (on our behalf) establish trends and
other buying/profile data to the extent that we’re lawfully able to do so.
Accountabl only allows its service providers to handle your personal data when we have confirmed that they
apply appropriate data protection and security controls. We also impose contractual obligations on service
providers relating to data protection and security, which mean they are only authorised by us to use your
data to provide services to Accountabl and to you, and for no other purposes.
6. The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
• Identity Data (for example, first name, last name, username or similar identifier, marital status, title,
date of birth, gender)
• Contact Data (for example, address, email address and telephone numbers)
• Financial Data (for example, your Accountabl card or other Accountabl account details)
• Transaction Data (for example, information regarding purchases made using your Accountabl card
or other Accountabl account, information from your accounting package regarding your purchase
ledger and sales ledger if authorised by you)
• Device Data (for example, the type of mobile device you use, a unique device identifier, the MAC
address of the Device's wireless network interface, or the mobile phone number used by the Device,
mobile network information, your mobile operating system, the type of mobile browser you use and
time zone setting)
• Content Data (for example, information stored and uploaded onto the App, Expense Portal, or
• Profile Data (for example, your username and password, preferences, feedback and survey
• Usage Data (for example, details of your use of the App, Expense Portal, and Website)
• Marketing and Communications Data (for example, your marketing preferences)
• Location Data (for example, your current location disclosed by GPS technology)
We may 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 App feature. However, if we combine
or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat
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.
7. How is your personal data collected?
We will collect and process the following data about you:
• Information you give us. This includes information (including Identity, Contact, Financial, and
Marketing and Communications Data) you give us when downloading, accessing and using the App,
logging in to the Expense Portal, visiting the Website, using our Services and by corresponding with
us (for example, by email). If you contact us, we may keep a record of that correspondence.
• Information we collect about you and your device. Each time you use the App, Expense Portal,
or Website we will automatically collect personal data including Device, Content and Usage Data.
We collect this data using cookies and other similar technologies.
• Location Data. We also use GPS technology to determine your current location. Some of our
location-enabled Services require your personal data for the feature to work. If you wish to use the
particular feature, you will be asked to consent to your data being used for this purpose. You can
withdraw your consent at any time by disabling Location Data in your settings.
• Information we receive from other sources including third parties and publicly available
sources. We may receive personal data about you from various third parties such as your
employer and from analytics providers such as Google.
8. How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your
personal data in the following circumstances:
• Where you have consented before the processing
• Where we need to perform a contract we are about to enter or have entered with you
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and
fundamental rights do not override those interests
• Where we need to comply with a legal or regulatory obligation
We will only send you direct marketing communications by email or text if we have your consent. You have
the right to withdraw that consent at any time by contacting us.
Purposes for which we will use your data
9. Disclosures of your personal data
We may share personal data about you:
• with third parties who are directly involved in dealing with any request or enquiry made by you (for
example, we may share your personal data with Quantum Card Services Limited and PayrNet Ltd in
order to enable you to make purchases using your Accountabl card or other Accountabl account);
• where such disclosure is required by law;
• with third parties who are providing us with professional advice;
• where the disclosure is in connection with any criminal investigation, legal proceedings or
prospective legal proceedings where permitted by law;
• where the disclosure is in order to establish, exercise or defend our legal rights (including providing
information to others for the purposes of fraud prevention and reducing credit risk);
• where we have stated or informed you otherwise (e.g. in this policy or on our Website).
We will not pass on your information to any third party for the purpose of marketing.
We may also disclose your personal data to 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
10. International transfers
If we are required to transfer your personal data out of the European Economic Area (EEA), we will ensure a
similar degree of protection is afforded to it by ensuring at least one of the following safeguards is
• Your personal data will be transferred to a country that has been deemed to provide an adequate
level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European
Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the
Privacy Shield which requires them to provide similar protection to personal data shared between
Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring
your personal data out of the EEA.
11. Data security
All information you provide to us is stored on our secure servers. You are responsible for keeping your
password and username for the App and Portal, and any other login details relating to any Accountabl
account, confidential. We ask you not to share a password with anyone.
Once we have received your personal data, we will use strict procedures and security features to try to
prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. We have
put in place procedures to deal with any suspected personal data breach and will notify you and any
applicable regulator when we are legally required to do so.
12. Data retention
We only retain your personal data for as long as we need it for the purpose for which it was collected. Whilst
taking in to consideration our legal obligations, we will on an ongoing basis: review the length of time we
retain your personal data; consider the purpose or purposes for which we hold your personal data for in
deciding whether (and for how long) to retain it; securely delete your personal data if it is no longer needed
for such purpose or purposes; and update, archive or securely delete your personal data if it goes out of
date. For further information on how long we retain your personal data please contact us using the contact
details set out above.
13. Your legal rights
Under certain circumstances you have the following rights under data protection laws in relation to your
• Request access to your personal data (commonly known as a "data subject access request").
This enables you to receive a copy of the personal data we hold about you and to check that we are
lawfully processing it.
• Request correction of your personal data. This enables you to have any incomplete or
inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new
data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal
data where there is no good reason for us continuing to process it. You also have the right to ask us
to delete or remove your personal data where you have successfully exercised your right to object to
processing (see below), where we may have processed your information unlawfully or where we are
required to erase your personal data to comply with local law. Note, however, that we may not
always be able to comply with your request of erasure for specific legal reasons which will be
notified to you, if applicable, at the time of your request.
• Object to processing of your personal data. This is where we are relying on a legitimate interest
(or those of a third party) and there is something about your particular situation which makes you
want to object to processing on this ground as you feel it impacts on your fundamental rights and
freedoms. You also have the right to object where we are processing your personal data for direct
marketing purposes. In some cases, we may demonstrate that we have compelling legitimate
grounds to process your information which override your rights and freedoms.
• Request restriction of processing your personal data. This enables you to ask us to suspend
the processing of your personal data in the following scenarios:
o if you want us to establish the data's accuracy;
o where our use of the data is unlawful but you do not want us to erase it;
o where you need us to hold the data even if we no longer require it as you need it to
establish, exercise or defend legal claims; or
o you have objected to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
• Request transfer or your personal data. We will provide to you, or a third party you have chosen,
your personal data in a structured, commonly used, machine-readable format. Note that this right
only applies to automated information which you initially provided consent for us to use or where we
used the information to perform a contract with you.
• Right to withdraw consent where we are relying on consent to process your personal data.
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 services to you. We
will advise you if this is the case at the time you withdraw your consent.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
The App, Expense Portal and Website use “cookies” to ensure you receive the best possible visitor
experience. Cookies are small files which are sent by a web server to an individual’s computer which are
then stored on that computer’s hard drive. A cookie contains text and is like an identification card which can
only be translated by the server it originated from.
Cookies cannot tell us information such as your email address, which we can only collect where you tell us,
for example if you submit an enquiry to us. Most internet browsers allow you to prevent cookies being stored
on your computer. Alternatively, you may be able to configure your browser to accept all cookies or to notify
you when a cookie is offered by our server. You may also be able to delete all cookies currently stored on
your web browser. For more detailed information on the cookies we use and the purpose for which we use
We may also collect information about where you are on the Internet (e.g. the URL you came from, IP
address, and domain types like .co.uk and .com), your browser type, the country where your computer is
located, the pages of our website that were viewed during your visit and any search terms that you entered
on our website. We will use this information to administer our website, for internal operations (including
troubleshooting, data analysis, testing, research, statistical and survey purposes) and as part of our efforts
to keep our website safe and secure.
For further information about cookies and how they are used, please visit www.aboutcookies.org.