Privacy notice | Corduroy

1. Introduction

This privacy notice is issued by PensionPay Limited, trading as Corduroy (“Corduroy”, “we”, “us”, “our”). PensionPay Limited is a company registered in England and Wales (company number 15682711) with its registered office at Chancery House, 53–64 Chancery Lane, London WC2A 1QS, and is the data controller for the personal data described in this notice.

We take the protection of your personal data very seriously and strictly adhere to the rules laid out by data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We are committed to keeping your information private and protected.

‘Your information’ means any information about you that you provide to us, is provided to us by your pension scheme, or we produce in relation to our services provided to you (the “Services”).

This Privacy Notice gives you information on how we collect and process your personal data. This notice should be read together with the Corduroy Cookies Notice.

PensionPay Limited is registered with the Information Commissioner’s Office (registration number ZB855419).

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the contact information in section 16 of this privacy notice.

2. Corduroy’s Privacy Principles

Corduroy is committed to safeguarding the privacy and security of your information.

We will only collect and use your information where we have lawful legitimate business reasons to do so.
We will not ask for more information than we need for the purposes for which we are collecting it.
We will update our records when you inform us that your details have changed.
We have implemented and adhere to information retention policies relating to your information.
We will ensure that your information is securely disposed of at the end of the appropriate retention period.
We observe the rights granted to you under applicable privacy and data protection laws.
We will ensure that queries relating to privacy issues are promptly and courteously dealt with.
Our staff are trained on their privacy obligations.
We will ensure there are appropriate measures in place to protect your information regardless of where it’s held and ensure that safeguards are in place before transferring your information to other countries.

3. Why we collect your personal information

We collect your personal data for one of the following purposes:

To manage communications between you and us
To confirm your identity and conduct necessary checks to comply with our legal and regulatory obligations
To perform the contract we have entered with you to provide Corduroy services
To provide you with information you have requested or which we may feel may be of interest to you
To ensure the safe operation of our product (including to protect you from fraud) and to monitor the performance of our product
For marketing and advertising purposes

4. Lawful basis of processing information

We only collect and use personal information about you when the law allows us to. Most commonly, we use it where:

The data subject (you) has given consent to the processing activity taking place
If the processing is necessary for the performance of a contract
If the processing is necessary for the purpose of the legitimate interest pursued by us or our partners

5. What information we collect and where from

We collect personal information from you if you request product information, contact us through this website, call us or use any of our services. In order to invite you to use our services, your pension scheme will also provide us with certain personal information. The categories of personal information that we may collect, store and use about you include:

Name, residential address, telephone number, email.
Date of birth
Mobile telephone number

Website visitors and enquiries. If you contact us through the form on this website, we collect the details you give us: your name, work email address, organisation, role and the content of your message. We use them to reply to you and to keep a record of our conversation, relying on our legitimate interest in responding to business enquiries. This website also uses cookies; see section 12 and our Cookies Notice.

We do not collect any 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 or information about your health).

6. How long we keep information for

We pride ourselves on ensuring that your personal data is only retained for the period that we need it for, or in accordance with laws, regulations and professional obligations that we are subject to. All personal information collected has a defined retention period, which is in-line with our retention policy. If you would like to find out how long your information is being retained, please see “additional information”, section 16 of this policy.

7. Security of personal information

We take the responsibility for protecting your privacy very seriously and we will ensure your data is secured in accordance with our obligations under the Data Protection laws. We have in place technical and organisational measures to ensure personal information is secured and to prevent your personal data from being accessed in an unauthorised way, altered or disclosed. We have in place a robust access control policy which limits access to your personal data to those employees, contractors and other third parties who only have a business need to know. The processing of your personal data will only take place subject to our instruction.

8. Children’s information

We do not knowingly collect information on children under 16. If we have collected personal information on a child, please contact us immediately using the details in section 16, so we can remove this information without any undue delay.

9. Your individual rights

In this section, we have summarised the rights that you have under the UK General Data Protection Regulation (UK GDPR). Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under the UK GDPR are:

Right to Object
Right of Access
Right to be informed
Right to Rectification
Right to Erasure
Right to Restrict processing
Right to Data Portability

The right to object: You can exercise this right if

Processing relies on legitimate interest
Processing is for scientific or historical research
Processing includes automated decision making and profiling
Processing is for direct marketing purposes

The right of access: You or any third party acting on your behalf with your authority may request a copy of the personal data we hold about you without charge.

We will ask to verify your identity or request evidence from the third party that they are acting on your behalf before releasing any personal data we hold about you.

The right to be informed: We are required, to provide clear and transparent information to you about how we process your personal data. This privacy notice addresses this right.

The right of rectification: If you believe the personal data we hold about you is incorrect or incomplete you have the right to correct this and you may exercise this right along with the right to restrict processing until these corrections are made.

The right to erasure: If there is no legal basis or legitimate reason for processing your personal data, you may request that we erase it.

The right to restrict processing: You may ask us to restrict the processing of your personal data. This means we will still hold it but not process it. This is a conditional right which may only be exercised when:

Processing is unlawful
We no longer need the personal data, but it is required for a legal process
You have exercised your right to object to processing and require processing to be halted while a decision on the request to object is made.
If you are exercising your right to rectification

The right to data portability: You can request that your personal data is transferred to another controller or processor in a machine-readable format if:

Processing is based on consent
Processing is by automated means (i.e. not paper based)
Processing is necessary for the fulfilment of a contractual obligation

If you have any question about these rights, please see “additional information”, section 16 of this policy.

10. Consent

Where you have given consent for processing, or explicit consent in relation to the processing of special category data, you have the right to withdraw this consent at any time, but this will not affect the lawfulness of processing based on consent before its withdrawal.

11. Failure to provide personal information

Where we need to collect personal data by law or in order to process your instructions or perform a contract we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.

12. Cookies

Our website uses cookies. Please see our Cookies Policy for full details of the cookies used.

13. Transfers to third parties

Corduroy may disclose your personal data, listed in section 5, to some third parties to help us deliver our services/products. All third parties are contractually bound to protect the personal data we provide to them. We may use several or all of the following categories of recipients:

Business partners, suppliers, contractors for the performance of any contract we enter into with them or you including data storage
Companies within our group where necessary for administrative purposes and to provide services to you
Third parties for the purposes of carrying out anti-money laundering and fraud checks. As part of this process, your data may be shared with bureaus which may leave a soft credit check on your record.
Third parties for the purposes of providing in-house and outsourced customer support
Third parties for the purposes of providing email marketing and registration invitations
Payment service providers
Professional advisors e.g. lawyers, auditors
Law or governmental authorities, as may be necessary in order to comply with statutory requirements and official requests – identity data, contact data, transaction data, marketing and communication data

14. Transfers outside of the UK

In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside the United Kingdom (UK).

We may share personal information to third parties outside of the United Kingdom (UK). Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the Data Protection laws.

Where personal data is transferred outside of the UK to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer. These could include:

Standard Contractual Clauses
International Data Transfer Agreement
Binding Corporate Rules
An exception as defined in Article 49 of the UK GDPR

For more information about transfers and safeguarding measures, please contact us using the information in section 16.

15. Right to complain

We take any complaints about our collection and use of personal information very seriously.

If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.

To make a complaint, please contact us via email: privacy@withcorduroy.com

Alternatively, you can contact us by post: Corduroy, PensionPay Limited, Chancery House, 53–64 Chancery Lane, London WC2A 1QS, United Kingdom.

Alternatively, you can make a complaint to the Information Commissioner’s Office:

By post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Website: ico.org.uk/global/contact-us/contact-us-public

By phone: 0303 123 1113

16. Additional information

Your trust is important to us. That is why we are always available to talk with you at any time and answer any questions concerning how your data is processed. If you have any questions that could not be answered by this privacy notice, or if you wish to receive more in-depth information about any topic within it, please contact us by email at privacy@withcorduroy.com or by post at Corduroy, PensionPay Limited, Chancery House, 53–64 Chancery Lane, London WC2A 1QS.

17. Policy review and amendments

We keep this notice under regular review. This notice was last updated in October 2026.

We reserve the right to update this privacy notice at any time. We may also notify you in other ways from time to time about the processing of your personal information.

Privacy notice. What we hold, why, and your rights.