Terms and Conditions

1. App Terms
1.1 By installing the iSpent19 App and using our services, you agree to be bound by our terms of use (“App Terms”)

1.2 Please review these carefully before you accept them. If you do not agree to these App Terms you are not able to use the iSpent19 App.

1.3 You may only use the iSpent19 App if you are 18 years or older. By using the iSpent19 App, you confirm that you are 18 years or older.

1.4 These iSpent19 App Terms will apply to the relationship between us and you in respect of the period from when you first download the iSpent19 App, until you uninstall it and cease to be registered with us – see section 12 if you wish to find out more.

2. The iSpent19 App
2.1 The “iSpent19 App” means the software application and services available through it called ‘iSpent19’ provided by iSpent19 Ltd (“we”, “us”, “our” or “iSpent19”) to offer personal banking transaction management tools.

2.2 The iSpent19 App can be used on Android and Apple iOS devices.

2.3 We may update the iSpent19 App to add and improve its functions. Depending on the update, you may not be able to use the iSpent19 App until you have downloaded the latest version and accepted any new or additional terms.

2.4 If you have any issues with the iSpent19 App, please contact us at hello@ispent19.com and we will do our best to help you.

2.5 The iSpent19 App is provided for convenience free of charge. You acknowledge that the iSpent19 App (and the services provided through the iSpent19 App) is dependent upon other people (third parties). We try to ensure that the iSpent19 App services are available to you at all times, though we can’t promise that it will always be available or work perfectly (for example, in the case of maintenance, fraud, or a fault in the systems used to host the iSpent19 App). These events are sometimes outside of our control.

3. The App Services
3.1 The iSpent19 App includes the following major functions:

3.2 Account Overview: This lets you combine your personal financial information from UK-based credit cards, current accounts and, in limited cases, other forms of accounts from banks and other financial institutions (“Accounts”), in one consolidated view. To do this, we request Account & Transactional Data from your Banks and such other financial institutions with your consent – find out more in section-6.

3.3 Consolidated view of your bank transactions: This lets you see the combined list of transactions from all banks that you have added to our App in chronological order. Transactions can be easily located through comprehensive search and filter features.

3.4 The ability to interact with any given transaction: iSpent19 allows you to manage your existing transactions on either an individual or batch bases. We believe such capabilities give you more visibility, control and convenience over your banking transactions in ways that are personal to you. The sort of interaction that you may have wished to have but due to a lack of efficient tools. We can think of 19 ways of interaction through the use of features such as tagging, annotation, reminders and attachments. Many of such interactions have been developed into functional features. We will continue to develop features that will give you the greatest flexibility on your mobile devices, based on your feedback.

3.5 Analytics & Insights: iSpent19 offers interactive insights that help make sense of your money by showing you patterns of what you spent on and avoid surprises.These are based upon analyses of your Account & Transactional Data, other information you provide, and your settings.

3.6 You may not be able to access all of your Accounts through the iSpent19 App – details of those that are currently supported are shown within the “Add Bank” or the “+” button in the iSpent19 App. If we do not yet support a particular type of Account, bank or financial institution, you can contact us to clarify if and when it may be added.

3.7 We may use third party suppliers to support us in providing the iSpent19 App. We take reasonable care in selecting our suppliers to protect your data security.

4. Your User Login, Password, PIN and Keeping Them Secure
4.1 You need to register on the iSpent19 App to use it. This will create an account in our system (your “User Login”).

4.2 When you create a User Login, you can choose your own password and PIN, collectively your “Security Details”. As a security precaution, we won’t be able to see your password nor your PIN, but we will store them securely. You must keep them secret. If you lose your password you will need to request to reset your password. You can change your PIN from within the App.

4.3 We’ll never ask you to tell us your security details including your password or PIN, so you shouldn’t share it with anyone, even if you think that they work for iSpent19.

4.4 You are responsible for (and agree to hold us harmless from) unauthorised access or changes to, or transactions on, your Account(s) resulting from shared access to your device or other people having access to your iSpent19 App’s User Login, password or PIN.

4.5 If you find out or suspect that your iSpent19 App’s Security Details have been lost, stolen, or someone has used it without your permission, you must tell us as soon as possible. You can let us know by emailing hello@ispent19.com. If you do so, then we can deactivate your iSpent19 App (including access to your Accounts through the iSpent19 App), but remember that you may also need to inform your Banks as the security of one or more of your actual bank accounts may have been compromised.

5. Identification and Verification
5.1 Under the relevant UK and EU anti-money laundering legislations, we are required to check the identify of our users. You agree to cooperate with all requests made by us to identify you and verify your identity and we may make this conditional for granting you continued access to the iSpent19 App and all of its functionalities.

5.2 This verification may include asking you for information so we can identify you, including requiring you to take a photo of your identification documents and a selfie. We may verify your information against third party databases or through other sources.

5.3 You must ensure the information you provide to us through your iSpent19 account is always accurate, up to date and legible (including your identify information). If at any time we believe that your information is outdated, inaccurate or illegible, we may require you to update this information and we may require you to go through the identification and verification process again.

6. Your Account & Transactional Data and Other Information
6.1 To fully benefit from the iSpent19 App, you are invited to add more than one bank or credit card account. You are absolutely free to decide how many and which account of yours to add.

6.2 When you add such accounts to the iSpent19 App, you add information related to your bank accounts and their respective transactions (“Account & Transactional Data”). This is done by instructing us (inside the iSpent19 App) to retrieve Account & Transactional Data held online by the banks and other financial institutions with which you have a customer relationship (your “Banks”). By doing so, you authorise us (and our third party suppliers) to contact your Banks, on your behalf, to retrieve Account & Transactional Data requested by you. You explicitly consent to us (and our third party suppliers) having the right to act in your name to contact the Banks, and to retrieve and (in line with our Privacy Notice) use the Account & Transactional Data. More information below on how this works.

6.3 We will access the Account & Transactional Data from each of your Banks through their Application Programming Interface (API) that are designed specifically for secure data access under the government’s Open Banking initiative. This approach allows us to securely retrieve Account & Transactional Data from the relevant Account that you have with them as authorised by you and to present them to you in the consolidated view in the iSpent19 App.

6.4 Under this API access approach, we do not see or store your login credentials with your Banks. You will be directed away from the iSpent19 App to initiate and complete the online login session at the Banks’ portals before being redirected back to us. This process ensures that your Banks will authenticate you before we can retrieve your Account & Transactional Data that you can then manage in our App.

6.5 When we access and retrieve Account & Transactional Data from your Banks, we act on your behalf, with your explicit consent, and not on behalf of any Bank.

6.6 Once logged in, we will help you keep your Account & Transactional Data up to date on your iSpent19 App by automatically refreshing access to your Accounts on a regular basis (usually, four times daily); each time you log in to the iSpent19 App; and, if you manually refresh Accounts or their transactions within the iSpent19 App.

6.7 Please note that our services are subject to limitations imposed by your banks, as to how soon you can see updates of your latest transactions in the iSpent19 App. Although we believe in and aim to provide you with an ability to obtain transactional updates in real time, we can not currently guarantee achieving it on every account added. Depending on the specific banks connected, there are likely to be delays from when you first see such transactions in your banks’ own apps to when they appear in the iSpent19 App. Nevertheless, you will see them way before receiving your monthly bank statements. Our value proposition is allowing you to take actions on transactions when they are still fresh, which helps you maintain your healthy habit of checking transactions regularly.

7. Your specific consents
7.1 You agree to provide us with information that we may request in order for us to carry out necessary checks.

7.2 For your data security, your explicit consent to us to access specific Accounts or Banks is currently subject to a time limit of 90 days from your initial consent given – we will remind you in advance of the expiration of this time limit so that you can renew your explicit consent through the iSpent19 App, should you wish to continue accessing and retrieving Account & Transactional Data from your relevant Bank(s).

7.3 Your use of the iSpent19 App is entirely voluntary. Many Banks are required by law to allow us to access Account & Transactional Data for your benefits through the iSpent19 App, once you have explicitly consented to us doing so. Some may, however,

    7.3.1 impose restrictions (such as under the terms that you have agreed with them) or

    7.3.2 are not yet supported for API connections by our technological partner TrueLayer Ltd (see section 18 for more detail).

It is your responsibility to check if your Bank stops you from using the iSpent19 App. We will publish the latest list of supported Banks in our App when you try to add a new Account. We have no control over which additional banks will be supported or in what timeframe.

7.4 On an ongoing basis, including each time you use the iSpent19 App, you confirm to us that:

    7.4.1 you have the right to use the iSpent19 App in respect of each relevant Bank, Account and its Account & Transactional Data; and

    7.4.2 you are legally authorized to access any 3rd party Account in respect of which you use the iSpent19 App based on such 3rd party Account holder’s explicitly consent. You may not use the iSpent19 App in respect of any Account you are not authorized to use.

7.5 We do not check nor are we responsible for the accuracy, legality or otherwise of your Account & Transactional Data, of the way that your Accounts operate or of products and services offered by others.

7.6 You acknowledge there may be issues with accessing Account & Transactional Data, and this being accurate or up to date. You may be able to request a refresh through the iSpent19 App if it appears to be out of date.

7.7 By uploading or submitting any information, content or materials to the iSpent19 App, you allow us (and our suppliers) a worldwide right to use it to provide services through the iSpent19 App to you. More information about how we use your information, and how it is held securely, is in our Privacy Notice.

8. Compatible Devices
8.1 In order to use the App, you are required to have a compatible device and supported firmware on this. In order to deliver you our services and keep them safe and up-to-date, we might ask you to update your device or may decide to no longer support certain devices or firmware.
9. Proprietary Rights and License
9.1 All trademarks, copyright, database rights and other intellectual property rights of any nature in the iSpent19 App (including its appearance and branding), together with the underlying software code, are owned by iSpent19 Ltd. We may also use open source software code in the iSpent19 App.

9.2 iSpent19 Ltd grants you a revocable right to use the iSpent19 App for your personal (non-commercial) use in accordance with these iSpent19 App Terms.

9.3 Neither you, nor third parties on your behalf, are allowed to

    9.3.1 make and distribute copies of the iSpent19 App;

    9.3.2 attempt to copy, reproduce, alter, modify, reverse engineer, disassemble, decompile, transfer, exchange or translate the iSpent19 App;

    9.3.3 create derivative works of the iSpent19 App;

    9.3.4 rent, lease, sub-license, loan, translate, merge, vary or modify the iSpent19 App;

    9.3.5 make alterations to the iSpent19 App, or permit the iSpent19 App to be combined with, or become incorporated in, any other programs.

9.4 You will comply with all technology control or export laws and regulations that apply to the technology used or supported by the iSpent19 App.

10. Acceptable Use Restrictions
10.1 You must not:

    10.1.1 use the iSpent19 App in any unlawful way or in breach of these iSpent19 App Terms, or act fraudulently or maliciously (for example, by accessing other people’s Accounts through the iSpent19 App without explicit authorisation);

    10.1.2 allow any other person to use the iSpent19 App installed on your device;

    10.1.3 infringe intellectual property rights in relation to the iSpent19 App, or your use of it;

    10.1.4 use the iSpent19 App in a way that could damage, disable, overburden, impair or compromise our systems or security or interfere with other persons (for example, we expect fair levels of use and would not expect you to make a large number of manual requests for Account & Transactional Data to be updated); and

    10.1.5 attempt to intercept, alter or decipher any transmissions to or from the servers running any service (for example, by trying to break the encryption protecting those transmissions).

11. Data Protection
11.1 Any personal information you supply to us (and which we collect from you or other sources) will be used by us in accordance with our iSpent19 Privacy Notice (www.ispent19.com/privacy-notice)

11.2 By using the iSpent19 App, you explicitly consent to us collecting and using technical information about your usage and device to improve our products or services that we provide to you and your experience of using the iSpent19 App.

12. Suspending and Stopping Our Services to You
12.1 We may suspend or end providing our services to you, hence your use of the iSpent19 App (or part of it) at any time. We will usually inform you when this is happening but we can’t always do so. We might take this action:

    12.1.1 if you breach these iSpent19 App Terms, for the reasons outlined below in this section;

    12.1.2 in the event we are unable to identify you or authenticate your identity or validate other personal information of yours for legal reasons; and

    12.1.3 in other circumstances where we believe that there is a valid reason (such as for risk or fraud management, or at your request if you suspect fraud as described in section 4.5).

12.2 We have no obligation to resume provision of the iSpent19 App or services to you, or to re-activate your User Login, if suspended or closed. If we permanently end your use of the iSpent19 App then:

    12.2.1 the rights granted to you in these iSpent19 App Terms end, and

    12.2.2 you must stop using the iSpent19 App and remove it from your devices.

12.3 If you are inactive then your User Login could automatically be suspended for security reason and you will be required to create a new User Login.

12.4 If we suspect that that the iSpent19 App’s security has been breached, or we suspect unauthorised or fraudulent use of the iSpent19 App, then we may suspend its use. If we do this, then we will (as permitted by law) try to contact you (normally by email) to let you know.

12.5 We may also need to limit, block or stop your usage if we are required to do so by law.

12.6 In some cases, to enable us to lift a suspension or other stop on your use of the iSpent19 App, we may need you to provide us with further information.

12.7 You may stop your use of the iSpent19 App at any time by removing the iSpent19 App from your device. Doing so will not automatically delete your user information that we hold. You can request to delete your user information in the iSpent19 App. If you forget to do this before removing the iSpent19 App then you can contact us at hello@ispent19.com and we can delete it for you. We will also stop making your information available for active use after 30 days of inactivity on the iSpent19 App. Upon receipt of your deletion request, your user account will be deactivated for a period of 30 days for reasons of regulatory compliance. Your personal data will be permanently deleted from our system after the deactivation period in accordance with our Privacy Notice.

13. Limitation of Liability
13.1 The iSpent19 App has not been developed to meet your individual circumstances. It is your responsibility to ensure that the iSpent19 App meets your needs.

13.2 The iSpent19 App does not provide financial planning services, or tax or financial advice. The App is designed to make your daily bank account management easier. We do not assume any responsibility or liability for your personal financial or tax obligations.

13.3 We only supply the iSpent19 App for domestic/personal use. You may not use the iSpent19 App for commercial, business or resale purposes, and we have no liability to you for any loss of profit, loss of revenue, loss of business, business interruption, or loss of business opportunity. We also have no liability to you for any damage or alteration to your equipment including your devices as a result of the installation or use of the iSpent19 App.

13.4 All information, content and material displayed on the iSpent19 App is provided for information only. It is not financial nor professional advice. You should not rely on information, content or materials on the iSpent19 App as the sole basis for making a financial decision. You should use your own judgment, and seek professional advice if appropriate. Accordingly, you agree that we are not responsible or liable to you for:

    13.4.1 any action (or inaction) resulting from use of or reliance on information, content and materials displayed in the iSpent19 App (or any loss or damage you suffer as a result);

    13.4.2 third party sites or services linked to or accessed from the iSpent19 App (or your use of, or reliance on, those sites or services); or

    13.4.3 any dealings you have with third parties (including your Banks and other services providers) through the iSpent19 App.

13.5 We shall have no liability to you in connection with your use of the iSpent19 App (whether in contract, tort including negligence or any other cause).

13.6 We are not responsible or liable if the relevant cause arises from your breach or action (such as your fraud or us following your instructions), events outside of our control, or the need to comply with our legal obligations. Other sections of these iSpent19 App Terms explain further things that we are not responsible or liable for.

13.7 You agree to reimburse us for any losses we incur as a result of your breach of, or failure to comply with, these iSpent19 App Terms or if we suffer any losses as a result of your use of the iSpent19 App.

14. Disclaimer
14.1 To the maximum extent permitted by law, we disclaim all implied warranties with regard to the iSpent19 App. We do not promise that the information, content or materials displayed on the iSpent19 App are accurate, sufficient or error-free. We do not promise that the information on our system is, when accessed by you, up-to-date or complete. The iSpent19 App and software are provided “as is” and “as available” without warranty of any kind.

14.2 Mobile devices may allow apps to draw or run over other apps, or otherwise interact with other apps (“Overlay Functionality”). This functionality could be abused by third parties to capture the content of the iSpent19 App and therefore poses a security threat. We have disabled this functionality in our App for your protection. Please do not modify your device or our App to attempt to override this restriction. If you do permit other apps or use your device to deploy the Overlay Functionality or otherwise then (unless it’s caused by our failings) you are responsible for (and agree to hold us harmless from) any unauthorised access or changes to, or transactions on, your Account(s) resulting from the use of the Overlay Functionality or otherwise similar approaches.

15. Problems, Questions & Complaints
15.1 We welcome your feedback, especially if you notify us of a question or problem, so that we can do our best to rectify it. It also gives us the opportunity to improve its service to you and other customers. iSpent19 also has an internal complaints procedure. We aim to handle all problems, questions and complaints efficiently and quickly. If you have questions, problems or complaints, regarding the iSpent19 App then please submit them to hello@ispent19.com and include the following information: your full name, telephone number and a description of your concern. For us to efficiently address your concerns, please notify us in writing within 30 days of first becoming aware of an issue.

15.2 If after we have responded to your complaint you remain unhappy, depending upon the complaint, you may be entitled to refer the complaint to the Financial Ombudsman Services. The Financial Ombudsman Services is a free, independent service for resolving disputes between customers and financial services third party providers like iSpent19 Ltd. More information is available at https://www.financial-ombudsman.org.uk/.

16. Changes to These App Terms
16.1 We may change the iSpent19 App Terms at any time and will inform you of a change either

    16.1.1 from within the iSpent19 App, when you next use it, or

    16.1.2 by e-mail. You may be asked to read and accept the new Terms to continue your use of the iSpent19 App.

16.2 If these changes materially impact you or materially changes your iSpent19 experience, we will strive to inform you through our regular channels with advance warning seeking your confirmation to accept the new Terms.

16.3 We will always act fairly and reasonably when we make these changes. The most common reasons that they will happen are if:

    16.3.1 we’re changing the way that an existing part of the iSpent19 App operates, introducing new functionalities, or withdrawing functionalities;

    16.3.2 we consider that we should take account of developments (or changes we reasonably expect to happen) in technology, security or industry standards and norms;

    16.3.3 there are changes in the way that we operate (which could, for example, lead to some aspects of the iSpent19 App becoming subject to a charge) or we think that we should explain something more clearly; or

    16.3.4 there is a change in law (including industry codes) that we follow, or in response to decisions of a regulator or court.

16.4 If you don’t want to accept a change we tell you about in advance, you can close your iSpent19 App account. You can also end this agreement by closing your iSpent19 App account at any time after we make the change but the change will apply to you until you do so.

17. Keeping in Touch
17.1 We will normally contact you either using the email address which you use to create your User Login or using notifications within the iSpent19 App. We will do this to keep you informed of matters relevant to the iSpent19 App, where we need to in order to comply with our legal obligations – further details are shown in our Privacy Notice. In some circumstances, it may also be appropriate for us to contact you through this or other means (such as telephone) where you have provided your number to us and it’s helpful to talk things through. When we communicate with you (including by telephone) it is common for us to monitor and keep a record of that communication for quality and training purposes.

17.2 Please remember to tell us if your details change. If we discover or suspect fraud or a security threat, we will need to contact you. Equally, for security reasons, we may block your use of the iSpent19 App if we are unable to contact you or don’t receive a response when we try to do so.

17.3 You have access to these iSpent19 App Terms, which can be sent to you by email if you request it. The easiest way to contact us is by emailing hello@ispent19.com.

18. About Us & Our Regulators
18.1 iSpent19 is the trade mark of iSpent19 Ltd, which is a UK registered company (Companies House no. 12146051).

18.2 We provide you with the ability to connect with your bank accounts via the technology designed by TrueLayer Ltd, which is authorised by the FCA as an Authorised Payment Institution ( Reference number: 901096). We are registered with the UK Financial Conduct Authority (FCA) (Reference number: 928953) as an agent of TrueLayer Ltd who is providing the regulated Account & Transactional Data Service. You can find more information about this on the FCA’s website (www.fca.org.uk/firms).

19. Other Important Terms
19.1 We may transfer our rights and obligations under these iSpent19 App Terms to another organisation, but this will not reduce your rights or obligations. You may not transfer your rights or obligations to another person.

19.2 If we fail to insist that you perform any of your obligations, or if we do not enforce our rights against you, or if we delay in doing so, that will not mean that we have waived our rights against you and will not mean that you do not have to comply with those obligations. Any waiver would need to be given by us in writing.

19.3 Each of the conditions of these iSpent19 App Terms operates separately. If any court or competent authority decides that any of them are unlawful or unenforceable, the remaining conditions will remain in full force and effect.

19.4 These iSpent19 App Terms are governed by English law. You and we both agree that the courts of England and Wales will have an exclusive jurisdiction.

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