PonchoPay Provider Privacy Policy


At Poncho Care Limited, we are committed to respecting your privacy. This Privacy Policy explains how we collect, use and disclose personal information that we receive when you use our PonchoPay platform (whether through our website, www.ponchopay.com, or the PonchoPay app or through one of our provider partners), visit our website, use our services, or communicate with us, both on this website and offline as a customer or potential customer.

It is important that you read this Privacy Policy so that you are fully aware of how and why we are using your data.

When we refer to the“Company”, “we”, “us” or “our” in this Privacy Policy, we are referring to  Poncho Care Limited, which is registered as a data controller with the Information Commissioner’s Office under data protection registration number ZA793696.

When we refer to “Poncho” or "PonchoPay" in this Privacy Policy, we are referring to our website, www.ponchopay.com and the PonchoPay platform which is accessible from our website & our web app https://pay.ponchopay.com/.


If you have any questions about our Privacy Policy or your information, or to exercise any of your rights as described in this Privacy Policy or under data protection laws,you can contact us as follows:
Poncho Care Limited
FAO: Ben Prouty, 167-169, Great Portland Street, 5th Floor, London W1W 5PF
By email:  help@ponchopay.com

Data Protection Principles

We adhere to the following principles when processing your personal information as data controller:

  1. Lawfulness, fairness and transparency: data must be processed lawfully, fairlyand in a transparent manner.
  2. Purpose limitation: data must be collected for specified,explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
  3. Data minimisation: data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  4. Accuracy: data must be accurate and, where necessary, kept up to date.
  5. Storage limitation: data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal information are processed.
  6. Integrity and confidentiality: data must be processed in a manner that ensures appropriate security of the personal information, including protection against unauthorised or unlawful processing and against accidental loss,destruction or damage by using appropriate technical or organisational measures.


Information you give us when using PonchoPay.
When registering or using a PonchoPay account, you may provide us with following details - names of owners/ billing authorities, email addresses, vouchers accepted and login details for automated reconciliation, payment card details for automated billing and connected bank accounts for Tax-Free childcare reconciliation.

We also may also request to send you push notifications regarding your account or certain features of your application(s). If you wish to opt out from receiving these types of notifications, you may unsubscribe from the mailing list.

Payment information
We use a third party payment processor, Adyen, to handle payments for us on PonchoPay. This means that we do not retain your debit or credit card information.  Instead, PonchoPay enables you to provide these details directly to Adyen. Adyen’s privacy policy can be found here.

Billing services
We use a third party billing services provider, Chargebee, to handle billings for us on PonchoPay. Chargebee’s privacy policy can be found here.

Information you give us in your other dealings with us
In addition, you may provide us with information by email, over the phone or when you otherwise contact us.  For example when:
1. you request additional information about our business or ask us to contact you;
2. we provide our services to you and/or enter into transactions with you; or
3. you send any other information about you to us.

We do not generally seek to collect sensitive personal information through PonchoPay or as part of our business transactions. Sensitive personal information is information relating to racial or ethnic origin; political opinions; religious or philosophical beliefs; trade-union membership; health;sex life, sexual orientation; or genetic or biometric information. If we do collect sensitive personal information, we will ask for your explicit consent to our proposed use of that information at the time of collection.

Information we collect from you
We collect, store and use information about your and your customers use of PonchoPay, and about your computer, tablet, mobile or other device through which you access PonchoPay. This includes the following information:· 
1. details of transactions you carry out through PonchoPay;
2. technical information, including the Internet protocol (IP) address, browser type,internet service provider, device identifier, your login information, time zone setting, browser plug-in types and versions, preferred language, activities,operating system and platform, and geographical location; and
3. information about your visits and use of the website, including the full Uniform Resource Locators (URL), clickstream to, through and from our website, pages you viewed and searched for, page response times, length of visits to certain pages,referral source/exit pages, page interaction information (such as scrolling,clicks and mouse-overs), date and time pages are accessed, and website navigation and search terms used.

Aggregated Data
We may also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. For example, we may use Aggregated Data to publish report on trends in the usage of PonchoPay and our applications and services. Aggregated Data could be derived from your personal information but is not considered personal information as this data will not directly or indirectly reveal your identity.

PonchoPay is a platform aimed at parents and young adults. It is not intended for or directed at children under the age of 18 years. When using PonchoPay, parents have the option of providing their children’s names to us. Children’s names are used by us for the purpose of reconciling bookings made by the parents only. Other than this, we do not knowingly collect information relating to children under the age of 18 years.


As data controller, we will only use your personal information if we have a legal basis for doing so. The purpose for which we use and process your information and the legal basis on which we carry out each type of processing is explained in the table below.

Legal Basis for the processing

Purposes for which we will process the information

To enable you to register an account on, access and use PonchoPay and to allow us to supply services to you.

It is necessary for us to process your personal information in this way in order to enter into a contract with you and to fulfil our contractual obligations to you.

To carry out  our obligations arising from any contracts entered into with you, and to  perform our services for you.

It is  necessary for us to process your personal information in this way in order to  enter into a contract with you and to fulfil our contractual obligations to  you. 

To send you promotional materials and other materials that may be of interest to you, including information about PonchoPay, us, our services, events or general promotions

It is  necessary for our legitimate interests to develop our services and grow our  business. To ensure we offer an efficient service, we consider this use to be  proportionate and will not be prejudicial or detrimental to you.  You can unsubscribe or opt-out from  receiving these communications at any time by clicking the “unsubscribe” link  in the email.

To provide you with information and materials that you request from us.

It is in our legitimate interests to respond to your queries and provide any information and materials requested in order to generate and develop business.

To manage payments, fees and charges and collect and recover money owed to us; to communicate about billing issues; or to enforce any contracts entered into with you.

It is in our legitimate interests to process your personal information in this way in order to perform or enforce our contract with you.

To send you  information regarding changes to our policies, other terms and other administrative information such as reminders, technical notices, updates and  security alerts.

It is in our legitimate interests to ensure that any changes to our policies, terms and other such technical updates are communicated to you.

To: administer our website including resolving technical issues, troubleshooting, data analysis, testing, research,statistical and survey purposes; and improve our website to ensure that content is presented in the most effective manner for you and your computer, mobile device or other item of hardware through which you access PonchoPay.

For both these categories, it is in our legitimate interests to continually monitor and improve our services and your experience of the website and platform and to ensure network security.

To help create and maintain a trusted and safe environment on the website and platform by, among other things, detection and prevention of fraud and other harmful activity,conducting investigations and risk assessments, verifying any identifications provided by you, and conducting checks against databases and information sources for fraud detection and prevention, risk assessment and harm prevention purposes.

It is in our legitimate interests to carry out such checks to ensure prevention against fraud and other harmful activity and that our website and platform is safe and secure.

Generally, we do not rely on consent as a legal basis for processing your personal information although we may need your consent before sending direct marketing communications to you via email or text message where you are not an existing user.  Where you provide consent, you can withdraw your consent at any time and free of charge, but without affecting the lawfulness of processing based on consent before its withdrawal. You can update your details or change your privacy preferences by contacting us as provided in the Contacting Us section above.


We will not sell, rent, lease or otherwise share your personal information other than as outlined in this Privacy Policy or without obtaining your consent beforehand.
We will share your personal information with any member of our group of companies insofar as reasonably necessary for the purposes set out in this Privacy Policy.
Personal information will also be shared with our third party service providers who assist with the running of PonchoPay and the operation of our business and who process personal data on our behalf, including third party hosting providers and payment processors.





Platform usage data aggregator. To streamline and pre-process capture of usage analytics. To improve the platform and the experience.



Platform usage analytics. To improve the platform and the experience.



To handle platform authentication.  Sensitive data (passwords, login info), are stored in a highly secure  environment and do not touch our servers.



For email automation, of transactional emails such as login and booking.



Platform hosting and data storage.



Platform error logging.



Sales CRM and Marketing



Customer support live chat (web  app)



To run ads, generate publicity and get leads for PonchoPay



Third party payment processor



Customer relationship management. To send emails about new offers and new features in PonchoPay


Google Cloud Platform

Platform hosting and data storage.



To send surveys, get feedback and collect data from users (if required, for e.g. after a booking)

USA, Germany


For maintaining your billing information and to send you invoices for vouchers


Our third party service providers and business partners are subject to security and confidentiality obligations and are only permitted to process your personal information for specified purposes and in accordance with our instructions.

In addition, we may disclose information about you:


Where we collect personal information from you, it may be necessary for us to transfer your personal information outside of the UK or the European Economic Area (“EEA”) to PonchoPay Partners, our service providers and other business partners located outside the UK or the EEA.

Where personal information is transferred to and stored in a country not determined by the UK or the European Commission as providing adequate levels of protection for personal information, we take steps to provide appropriate safeguards to protect your personal information, including entering into standard contractual clauses approved by the UK or the European Commission,obliging recipients to protect your personal information.

If you would like further information on the specific mechanism used by us when transferring your personal information outside of the UK or the EEA,please contact us using the details set out in the Contacting Us section above.


We use appropriate technical and organisational security measures to protect personal information both online and offline from unauthorised use, loss, alteration or destruction. We use physical and procedural security measures to protect information from the point of collection to the point of destruction. Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal information.

Despite these precautions, however, we cannot guarantee the security of information transmitted over the Internet or that unauthorised persons will not obtain access to personal information.


We will only retain your personal information 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 information 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 information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.


You have the right to access information which we hold about you (“data subject access request”).

You may also have the right to receive personal information which you have provided to us in a structured and commonly used format so that it can be transferred to another data controller(“data portability”). The right to data portability only applies where your personal information is processed by us with your consent or for the performance of a contract and when processing is carried out by automated means.We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. Please keep us informed if your personal information changes during your relationship with us.


Direct marketing
You have the right to object at any time to our processing of your personal information for direct marketing purposes.

Where we process your information based on our legitimate interests
You also have the right to object, on grounds relating to your particular situation, at any time to processing of your personal information which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.


You also have the following rights under data protection laws to request that we rectify your personal information which is inaccurate or incomplete.

In certain circumstances, you have the right to request the erasure of your personal information: this enables you to ask us to delete or remove personal information where there is no good reason for us to continuing to process it (“right to be forgotten”); and restrict the processing of your personal information.

Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly,where exceptions under the applicable law apply. For example, we may refuse a request for erasure of personal information where the processing is necessary to comply with a legal obligation or necessary for the establishment, exercise or defence of legal claims. We may refuse to comply with a request for restriction if the request is manifestly unfounded or excessive.


You can exercise any of your rights as described in this Privacy Policy and under data protection laws by contacting us as provided in the Contacting Us section above.

Save as described in this Privacy Policy or provided under data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or (b)refuse to act on the request.

Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.


In order to improve the website, we may use small files commonly known as “cookies”. A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or mobile phone (your “device”) from the website and is stored on your device’s browser or hard drive.

By continuing to browse the website, you are agreeing to our use of cookies.

If you do not want us to use cookies when you use the website, you can set your internet browser not to accept cookies.However, if you block cookies some of the features on the website may not function as a result.

You can find more information about how to do manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device.

We ask for your consent to place cookies on your device, except where these are essential (strictly necessary) for us to provide you with a service that you have requested.

Strictly necessary cookies:
We currently set the following cookies which are strictly ncecessary for provision of our service:

First Party Cookies

Cookies Names(s)




To persist search term entry while navigating the PonchoPay app



To persist selected product filters, such as age, category, while navigating the PonchoPay app



To persist selected product filter parameters,such as specific selected categories or age ranges, while navigating the PonchoPay app

Third Party Cookies

Cookie Name(s)





To detect if user is logged in/authorised or not

Auth0Privacy Policy


Refer Adyen Cookie policy

To enable payment for products and services.

Adyen Privacy Policy



These cookies remember to ask visitors not to accept cookies again, prevent tracking code from sending information to hubspot,prevent banner from displaying in strict mode, record categories visitor has consented to, help with a/b testing, not require logins for future visits,determine and save whether chat widget is open for future, prevent chat widget from appearing after it is dismissed, identifies user when they are logged in,ensures content membership logins cannot be forged, save language choice,detect malicious visitors and minimize blocking of legitimate users(Cloudflare)and help with rate limiting policies of CDN provider

Hubspot Privacy Policy

Non-essential cookies from third parties
We currently use the following (non-essential)third party cookies:

Third Party Cookies

Cookie Name(s)



Google Analytics


Marketing website (www.ponchopay.com) only.These cookies provide us with a visitor count and an understanding of how visitors move around and use the website. We can then use this information to improve navigability and the website generally.

Google Privacy Policy



These cookies help us track visitors, their identities, keep track of sessions and to check if users have restarted their browsers.

Hubspot Privacy Policy



These cookies  enable us to recognise device data, such as your computer or mobile  device operating system type and version number, manufacturer and model,  browser type, screen resolution, IP address, unique identifiers, and general  location information such as city or town.They also  enable us to monitor usage data, such as the website you visited  before browsing to the Site, pages or screens you viewed, how long you spent  on a page or screen, navigation paths between pages or screens, information  about your activity on a page or screen, access times, and duration of  access. 

Segment Privacy Policy



These cookies help us track visitors, their identities, keep track of sessions and to check if users have restarted their browsers.

Intercom Privacy Policy



Targeting cookies which allow us to place advertising content onto Facebook that is relevant to you based on your browsing patterns on our website. This information is never connected to your profile and it is always anonymous.

Facebook Privacy Policy



These cookies  enable us to embed product videos via YouTube. They are used by youtube to  track which videos are watched, to keep progress and enable recommendations.  Youtube uses this data to improve it’s service.

Google Privacy Policy

If you have any questions or concerns regarding our Privacy Policy or practices, please contact us as provided in the Contacting Us section above. You also have the right to complain to the UK Information Commissioner’s Office (https://ico.org.uk/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

We reserve the right to change this Privacy Policy from time to time. Any changes will be posted on the website with an updated revision date. If we make any material changes to this Privacy Policy, we may notify you by email or by means of a prominent notice on the website prior to the change becoming effective.

Date: 17-10-2023

167-169 Great Portland Street,
5th Floor,
Poncho ®