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Privacy Policy

1. Consent to installation of the App

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in our Privacy Policy (the Policy) and it is important that you read that information.
Before installation of the Application, you must indicate your consent to our processing of your personal data as described in this Policy.

How you can withdraw consent

Once you provide consent by selecting “YES”, you may change your mind and withdraw consent at any time by contacting us at compliance@sqr-group.com but that will not affect the lawfulness of any processing carried out before you withdraw your consent. On withdrawal of your consent we will immediately cease all processing of your personal data.

2. Introduction

This policy (together with our SQR application terms of use (Terms of Use)) applies to your use of:

3. Important information and who we are

The SQR Application is operated by SQR Group Limited a company registered in the Isle of Man. Our company registration number is 134592C and our registered office is at Third Floor, Queen Victoria House, Victoria Street, Douglas, IM1 2LF, Isle of Man We are registered with the Isle of Man Information Commissioner. Our registration number is R003674.
We take the protection and security of your personal information very seriously and this policy sets out our responsibilities under the Data Protection Act 2018 (‘UK GDPR’), the General Data Protection Regulation 2016 (‘GDPR’) and other applicable data protection and privacy laws in the Isle of Man and England and Wales relating to the processing and security of personal information.
SQR Group Limited are data controllers and responsible for your personal data.
We co-operate with our group companies regarding the provision of the SQR Application and our Services. This means that we and our group companies may jointly determine if and how personal data of yours is processed. Since we and our group companies are controllers of your data when doing so, we will be joint controllers. Our group companies are:

When we refer to ‘’we’’, “us” or ‘’our’’ we are referring to SQR Group Limited.
We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Email address:

Postal address:

Third Floor, Queen Victoria House, Victoria Street, Douglas, IM1 2LF, Isle of Man

You have the right to make a complaint at any time to:
  • The UK Information Commissioner
  • Isle of Man Information Commissioner, P.O. Box 69, Douglas, Isle of Man, IM99 1EQ Telephone: +44 1624 693260 Email: ask@inforights.im (IOMIC).
We would, however, appreciate the chance to deal with your concerns before you approach the IOMIC so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 24th March 2023. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by in Application notification or when you next start the Application or log onto one of the Services Sites. 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 Application 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 your relationship with us.

Third-party links

Our Sites may, from time to time, include links to and from third-party websites, advertisers, affiliates, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you and they will have their own privacy policies. We do not control these third-party websites and 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.

4. The data we collect about you.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data: first name, maiden name, last name, username, nickname or similar identifier, marital status, nationality, title, date of birth, age and gender.
  • Special Categories of Personal Data limited to:
    Biometric Data includes facial recognition data;
  • Behavioral Data which analyses your digital physical and cognitive behavior to distinguish between cybercriminal activity and legitimate customers, identifying fraud and identity theft.
  • Registration Data includes registration information, demographic information, personal description and photographs of both yourself and your personal documentation including, but not limited to: Passport, Driving licences, National Identity cards, utility bills, and bank statements.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details, source of funds/wealth information, spending history.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us and other third parties, spending history
  • Profile Data includes your username and password, QR codes, user codes, PEP and sanctions information, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our Applications, Services Sites, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Technical Data includes the following each time you visit any of the Services Sites or use the Applications we may automatically collect the following information:
  • Technical Data : technical information, including the type of mobile device you use (“Device”), a unique device identifier (for example, your Device’s IMEI number, 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, time zone setting , internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Applications and/or the Website;
  • Content Data : information stored on your Device, including contact information, friends lists, login information, photos, videos or other digital content, check-ins;
  • Log Data : details of your use of any of the Applications or your visits to our Websites including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access, including the nature of the content that is viewed, related transfer rates, length of viewing, which pages are viewed and other similar data.
  • Unique application numbers : When you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
Save as specified above (in respect of Biometric Data), we do not collect any other 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). We do not collect any information about criminal convictions and offences.
[We 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 Application feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect personal data in order to provide the Services, by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

5. How is your personal data collected?

We will collect and process the following data about you:
  • Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the Applications and the Services Sites (together Our Sites) or by corresponding with us (for example, by e-mail or live chat). This includes personal data you provide when you:
Technical Data from the following parties:
a) analytics providers;
b) search information providers.
Contact, Financial and Transaction Data from providers of technical, payment and delivery functions.
Identity and Contact Data from publicly available sources.


We use cookies to collect information about you and to store your online preferences. A cookie is a piece of data temporarily stored on the user’s hard drive containing information about the user. Cookies allow us to recognize whether you have used our service before and help us store your preferences and other information.
We use the following cookies from Intercom, a third-party integration, on our website:
We also use cookies from Google Analytics, a third-party integration used to track website activity such as session duration, pages per session and bounce rates of individuals using the site, along with information regarding the source of the traffic.
If you prefer that your personal data is not processed on our website, you can activate the private browsing feature of your web browser.
Please note that if you delete or disable our cookies you may not be able to access certain areas or features of our site.

6. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Please see the Glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.
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.
We will never:

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.


Type of data

Lawful basis for processing including basis of legitimate interest

To install the Application and register you as a new Application user

  1. Identity
  2. Registration
  3. Contact
  4. Technical
  5. Behavioural
  6. Behavioural
Your consent.
To deliver the Services to you
  1. Identity
  2. Registration
  3. Contact
  4. Financial
  5. Transaction
  6. Technical
  7. Marketing and Communications
  8. Biometric (incl facial biometric)
  9. Location
Your consent.
Performance of a contract with you.

To manage our relationship with you which will include:

  1. changes to the Applications or any Services
  2. Notifying you about changes to our terms or privacy policy
  3. Asking you to leave a review, provide feedback or take a survey
  1. Identity
  2. Contact
  3. Profile
  4. Marketing and Communications
Your consent
Performance of a contract with you.
Necessary to comply with a legal obligations (to inform you of any changes to our terms and conditions).
Necessary to comply with a legal obligations (to inform you of any changes to our terms and conditions).
To administer and protect our business and the Applications (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  1. Identity
  2. Contact
  3. Technical
  4. Behavioural
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business re organisation or group restructuring exercise).
Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  6. Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve the Applications, our Sites, products/Services, marketing, customer relationships and experiences
  1. Technical
  2. Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
  1. Identity
  2. Contact
  3. Technical
  4. Usage
  5. Profile
  6. Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the parties set out below for the purposes set out in the table above.

Third Party

Type of Data

Length of Time it will be stored

Why it will be stored for this length of time

Emerchant Pay (Optional within the app)
  1. Identity
The least amount of time necessary to fulfill legal or regulatory obligations and for our business purposes. They may retain Personal Data for longer periods than required by applicable regulatory requirements, if it is in their legitimate business interests and not explicitly prohibited.
Your consent.
Necessary to comply with a legal obligation.
GB Group Plc
  1. Identity
  2. Facial Biometrics
31 days
Verified Technologies
  1. Identity
  2. Registration
  3. Contact
  4. Financial
  5. Transaction
  6. Technical
  7. Marketing and Communications
  8. Biometric (incl facial biometric)
  9. Location
up to 6 years
Your consent
Necessary to comply with a legal obligation.
Performance of a contract.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Third parties will provide the same or equal protection of your personal data as stated in this Policy and in accordance with App Store Review Guidelines:
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We do not transfer your personal data internationally.

8. Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
We have put in place procedures to deal with any suspected personal data breach and will notify you by email and any applicable regulator, in accordance with applicable law, in the event of any data breach in which any of your personal information collected by the App is compromised, unintentionally disclosed or misused.

9. Data retention

How long will you use my personal data for?

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial, Behavioural and Facial Biometrics, and Transaction Data) for six years after they cease being customers.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event that you do not renew subscription to the App then we will treat the account as expired and all of your personal data will be deleted within 30 days. This includes all Biometric and Usage data.

10. Accessing and Modifying Account Information

11. Your legal rights.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are:
If you wish to exercise any of the rights set out above, please contact compliance@sqr-group.com.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.



Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties

Internal Third Parties

Other companies in the SQR Group Limited acting as joint controllers or processors and who are based in the United Kingdom.

External Third Parties

Service providers acting as processors based in the UK including, but not limited to, external development partners.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
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