Data Privacy & Protection Policy
LAST UPDATED: September 2026
Policy Scope
This Data Privacy & Protection Policy applies to Signifo Ltd applications and platform (collectively, the “Services”), gb.webexpenses.com/we/and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Signifo Ltd.
This Data Privacy & Protection Policy does not apply to any third-party applications or software that integrate with the Services through the Signifo Ltd platform (“Third Party Services”), or any other third-party products, services or businesses. In addition, a separate agreement governs delivery, access and use of the Services (the “Software as a Service Agreement”), including the processing of any messages, files or other content submitted through Services accounts (collectively, “Customer Data”).
The organisation (e.g., your employer or another entity or person) that entered into the Software as a Service Agreement (“Customer”) controls their instance of the Services and any associated Customer Data. If you have any questions about specific settings and privacy practices, please contact the Customer who has provided you with access to the Webexpenses Services.
Information we collect and receive
Signifo Ltd may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:
- Customer Data: Customers or individuals granted access to Webexpenses services (application and mobile) by a Customer (“Authorised User”) routinely submit Customer Data to Signifo Ltd when using the Services.
- Other Information: Signifo Ltd also collects, generates and/or receives Other Information:
- Services Metadata: When an Authorised User interacts with the Services, metadata is generated that provides additional context about the way Authorised Users work. For example, Signifo Ltd logs the features, content and links you interact with, and activity logs for all actions (e.g. assignment, modification, edit, copy, delete) taken by Authorised users when interacting with the Services.
- Log data: As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
- Device information: Software collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all this Other Information often depends on the type of device used and its settings.
- Location information: If opted in by the customer we use an IP Geolocation database to power a Geolocation widget that shows the administrators and account users a visualisation of the claimant’s location at the point of claim creation.
- Cookie Information: Signifo Ltd uses cookies and similar technologies in our Websites and Services that help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services.
- Third-Party Data: Signifo Ltd may receive data about organisations, industries, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners or others that we use to make our information better or more useful.
- Referral Data: Signifo Ltd invites its users to provide details of their contacts under its referral scheme. We may get in touch with those referred to see if they would be interested in our Services. This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed. Additional Information Provided to Signifo Ltd. We receive Other Information when submitted to our websites or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with Signifo Ltd.
- Card Data: Signifo Ltd processes personal data to provide our card services. This includes business contact information (name, address, email address, job title, company/organisation, communications between you and Signifo Ltd), Know Your Customer Data (name, address, date of birth, national identity numbers (e.g. NI number), job title, nationality, email address, phone number) and transaction data (card details and transaction amount, date, time and location). Signifo Ltd collects Know Your Customer Data from customers for the card services. Signifo Ltd collects transaction data through customers’ use of the card services. Signifo Ltd processes Card Data as a controller.
Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as basic user profile level information (e.g. name, email address), is not provided, we may be unable to provide the Services.
How do we use the information?
Customer Data will be used by Signifo Ltd by Customer’s instructions, including any applicable terms in the Software as a Service Agreement and Customer’s use of Services functionality, and as required by applicable law.
Signifo Ltd is a processor of Customer Data and Customer is the controller. Customers may, for example, use the Services to grant and remove access to the application, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.
Signifo Ltd uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, Signifo Ltd uses Other Information:
- To provide, update, maintain and protect our Services, Websites and business. This includes the use of Other Information to support the delivery of the Services under a Software as a Service Agreement, prevent or address service errors, security or technical issues, analyse and monitor usage, trends and other activities or at an Authorised User’s request.
- As required by applicable law, legal process or regulation.
- To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
- To develop and provide additional features and improvements to functionality. Signifo Ltd tries to make the Services as useful as possible for our Customers and their Authorised Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorised User, make Services suggestions based on historical use and predictive models, identify organisational trends and insights, to customise a Services experience or create new features or improvements or develop new products.
- To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Service offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services, and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Signifo Ltd. These are marketing messages so you can control whether you receive them.
- For billing, account management and other administrative matters. Signifo Ltd may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
- To investigate and help prevent security issues and abuse.
Signifo Ltd may process Card Data for the purposes of processing and fulfilment of orders, providing card services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is Signifo Ltd.’s legitimate interests, namely the proper administration of Signifo Ltd.’s services and business.
Signifo Ltd may process Card Data for the purposes of managing its relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, and/or telephone, providing support services and complaint handling. The legal basis for this processing is Signifo Ltd.’s legitimate interests, namely communications with its service users, individual customers and customer personnel, the maintenance of its relationships, enabling the use of its services, and the proper administration of its services and business.
Signifo Ltd may process Card Data for the purposes of researching and analysing the use of its services, as well as researching and analysing other interactions with its business. The legal basis for this processing is Signifo Ltd.’s legitimate interests, namely monitoring, supporting, improving and securing its services and business generally.
Signifo Ltd. may process Card Data for the purposes of analysing, tracking, and comparing transaction and other data to develop and provide insights for Signifo Ltd and/or others as well as for developing, marketing, maintaining and/or improving Signifo Ltd.’s products and services.
Record keeping – Signifo Ltd may process your personal data for the purposes of creating and maintaining Signifo Ltd.’s databases, back-up copies of our databases and its business records generally. The legal basis for this processing is Signifo Ltd.’s legitimate interests, namely ensuring that Signifo Ltd has access to all the information it needs to properly and efficiently run its business in accordance with this policy.
Security – Signifo Ltd may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is Signifo Ltd.’s legitimate interests, namely the protection of its services and business, and the protection of others.
Insurance and risk management – Signifo Ltd may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is Signifo Ltd.’s legitimate interests, namely the proper protection of its business against risks.
Legal claims – Signifo Ltd may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is Signifo Ltd.’s legitimate interests, namely the protection and assertion of its legal rights, your legal rights and the legal rights of others.
Legal compliance and vital interests – Signifo Ltd may also process your personal data where such processing is necessary for compliance with a legal obligation to which it is subject or to protect your vital interests or the vital interests of another natural person.
If information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, Signifo Ltd may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Data Privacy & Protection Policy as “Personal Data.”
Data retention
Signifo Ltd will retain Customer Data by a Customer’s instructions, including any applicable terms in the Software as a Service Agreement and Customer’s use of Services functionality, and as required by applicable law.
Signifo Ltd may retain Other Information about you for as long as necessary for the purposes described in this Data & Protection Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period needed for Signifo Ltd to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
Signifo Ltd will retain Card Data for the duration of the relevant customer’s contract with Signifo Ltd and for 9 months / 270 days post contract termination, following the date of termination of the relevant customers’ contract.
How do we share and disclose information?
This section describes how Signifo Ltd may share and disclose Information. Customers determine their policies and practices for the sharing and disclosure of Information, and Signifo Ltd does not control how they or any other third parties choose to share or disclose Information.
- Customer’s Instructions: Signifo Ltd will solely share and disclose Customer Data by a Customer’s instructions, including any applicable terms in the Software as a Service Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process.
- Customer Access: Owners, administrators, Authorised Users and other Customer representatives and personnel may be able to access, modify or restrict access to Other Information. This may include, for example, an Authorised User’s email address which could be made visible to other Authorised Users within the Customer or restricted to specific roles (e.g. manager or company admin) or security profiles.
- Third-Party Service Providers and Partners: We may engage third-party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services. Additional information about the sub-processor(s) we use to support the delivery of our Services is set forth within the section “sub-processor(s)”.
- During a Change to Signifo Ltd.’s Business: If Signifo Ltd engages in a merger, acquisition, bankruptcy, dissolution, reorganisation, sale of some or all of Signifo Ltd.’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
- Aggregated or De-identified Data: We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, or as part of new product offerings or features provided to Customers which provide anonymised benchmark metrics for comparative performance between Customers.
- To Comply with Laws: If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is by or required by any applicable law, regulation or legal process. This may include the Notifiable Data Breaches (NDB) scheme contained within the Australian Privacy Act, notifiable privacy breach provisions within the New Zealand Privacy Act, and data breach notification provisions contained within the United Kingdom and/or European Economic Area General Data Protection Regulation (GDPR). For example, where Personal or Sensitive Information is lost or subject to unauthorised access or disclosure and will likely result in serious harm to an individual/risk to the rights and freedoms of natural persons, Signifo Ltd will take appropriate response action by applicable law.
- To enforce our rights, prevent fraud, and for safety: To protect and defend the rights, property or safety of Signifo Ltd or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
- With Consent: Signifo Ltd may share Other Information with third parties when we have consent to do so.
Signifo Ltd may share Card Data with the issuer of its card services (Adyen N.V.): for the purposes of allowing the issuer to carry out Know Your Customer screening; for the issuer to determine whether or not specific Signifo Ltd customers may participate in the card services; for the issuer to monitor/review card services customers and transactions; for the issuer to issue cards; for the issuer to administer card services customers’ accounts; for the issuer (along with Signifo Ltd) to administer the funding of card services customers’ accounts; and for the issuer to ensure that card services customers’ payments are processed lawfully.
Security
Signifo Ltd takes the security of data very seriously. We take all reasonable steps to ensure that all Customer Data and Other Information is secure and protected from misuse, loss and unauthorised access and modification. To learn more about current practices and policies regarding the security and confidentiality of the Services, please refer to your Software as a Service Agreement, contact your Signifo Ltd Account Manager or contact us at data.protection@webexpenses.com.
Changes to this policy
Signifo Ltd may change this Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this policy on the Signifo Ltd website and encourage you to review our Data Privacy & Protection Policy to stay informed. If we make changes that materially alter your privacy rights, Signifo Ltd will provide additional notice, such as via email or through the Services.
If you disagree with the changes to this Data Privacy & Protection Policy, Customers may speak with their Signifo Ltd. Account Manager or contact us at data.protection@webexpenses.com.
Data protection officer
To communicate with our Data Protection Officer, please email data.protection@webexpenses.com.
Your rights
Individuals located in certain countries, including the European Economic Area, have certain statutory rights about their data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Authorised User account.
Customers determine their own policies to control the level of access Authorised Users have to directly update or correct information contained within Webexpenses services (application and mobile). In circumstances where Authorised Users do not have permission to make updates or corrections directly, they may contact the Customer to request the update, correction or removal of Personal Data under their control. Signifo Ltd personnel have limited ability to access Customer Data. If you wish to make your request directly to Signifo Ltd, please provide the name of the Signifo Ltd Customer who submitted your data on our solution. We will refer your request to that Customer and will support them as needed in responding to your request within a reasonable timeframe.
To the extent that Signifo Ltd.’s processing of your Personal Data is subject to the General Data Protection Regulation, Signifo Ltd relies on its legitimate interests, described above, to process your data.
Signifo Ltd may also process Other Information that constitutes your Data for direct marketing purposes, and you have a right to object to Signifo Ltd.’s use of your Personal Data for this purpose at any time.
Where Signifo Ltd is the data controller, your principal rights under data protection law are:
- the right to access – you can ask for copies of your personal data;
- the right to rectification – you can ask Signifo Ltd to rectify inaccurate personal data and to complete incomplete personal data;
- the right to erasure – you can ask Signifo Ltd to erase your personal data;
- the right to restrict processing – you can ask Signifo Ltd to restrict the processing of your personal data;
- the right to object to processing – you can object to the processing of your personal data;
- the right to data portability – you can ask Signifo Ltd transfers your personal data to another organisation or to you;
- the right to complain to a supervisory authority – you can complain about Signifo Ltd.’s processing of your personal data; and
- the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by accessing:
You may exercise any of your rights in relation to your personal data by contacting data.protection@webexpenses.com.
Sub-processor(s)
Signifo Ltd uses certain sub-processor(s) to assist in providing its Services. It works with service providers that have or may have access to or process Signifo Ltd.’s customer data.
Before engaging any sub-processor(s), Signifo Ltd performs strict due diligence to ensure our customer data remains secure and protected, including ensuring our sub-processor(s) satisfy equivalent contractual obligations as those required from Signifo Ltd as a Processor. Where Signifo Ltd.’s sub-processor(s) are located outside of the UK, Signifo Ltd ensures that your personal data is protected, either by ensuring that sub-processor(s) are located in countries where the competent data protection authorities have made an adequacy determination with respect to the data protection laws of the relevant country or by ensuring that the transfer of your personal data to the relevant sub-processor(s) is protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities.
The list of sub-processor(s) used by Signifo Ltd is published on our public website at https://www.webexpenses.com/subprocessors/.