1. Who we are
Pegno UK Ltd (Company No. 17169218), registered at 167-169 Great Portland Street, London W1W 5PF ("Pegno", "we", "us", "our") is the data controller for personal data processed through the Pegno platform.
FCA registration pending as a Small Payment Institution (FRN: 1056758) under the Payment Services Regulations 2017.
Contact: privacy@pegno.app
2. Data we collect
- Account data: Name, email address, phone number, user ID
- Identity verification data: Government-issued ID, selfie/biometric data (for KYC compliance)
- Financial data: Bank account details, transaction history, payment information
- Deal data: Job descriptions, milestone details, messages between parties
- Device data: IP address, device type, operating system, app version
- Communications: Support messages, dispute submissions, in-app messages
3. How we use your data
- To provide and operate the Pegno escrow platform
- To verify your identity and comply with AML/CTF obligations
- To process payments and manage escrow transactions
- To resolve disputes and handle complaints
- To comply with our regulatory obligations under the Payment Services Regulations 2017
- To send transactional emails and account notifications
- To improve and develop the platform
4. Legal basis for processing
We process your personal data on the following legal bases under the UK GDPR:
- Contract: Processing necessary to provide the Pegno service you have signed up for
- Legal obligation: Processing required to comply with the Payment Services Regulations 2017, Money Laundering Regulations 2017, and other applicable law
- Legitimate interests: Fraud prevention, security, and platform improvement
- Consent: Marketing communications (where applicable)
5. Data sharing
We share your data only where necessary:
- Payment partners: Banking and payment rail providers for fund processing and safeguarding
- KYC providers: Identity verification service providers
- Cloud infrastructure: Supabase (database and authentication), AWS (email delivery)
- Regulators: FCA, HMRC, and law enforcement where legally required
We do not sell your personal data to third parties.
6. Data retention
We retain your data for as long as your account is active and for a minimum of 5 years after account closure, in accordance with our AML/CTF obligations under the Money Laundering Regulations 2017.
7. Your rights
Under the UK GDPR, you have the right to:
- Access your personal data
- Correct inaccurate data
- Request deletion of your data (subject to legal retention obligations)
- Object to processing
- Data portability
- Withdraw consent (where processing is based on consent)
To exercise any of these rights, email privacy@pegno.app.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.
8. Account deletion
You can delete your account from within the Pegno app via Account Settings → Danger Zone → Delete Account. Accounts with active deals cannot be deleted until those deals are resolved. Upon deletion, your personal data will be anonymised or deleted in accordance with our retention policy.
9. Contact us
For privacy-related enquiries: privacy@pegno.app
Pegno UK Ltd, 167-169 Great Portland Street, London W1W 5PF