Legal & Policies

Hedj privacy notice

Hedj Financial Risk Management Limited · Version 1 · Effective 8 October 2026

About version 1

What changed
First published version
Why
This notice replaces Hedj's earlier draft privacy policy. It now names our partners and our role for each kind of data, the legal basis for each use, where data goes and how long we keep it.
What it means for you
It explains how Hedj handles personal data, including bank data received through Yapily Connect and data used for Ebury's FX and payment services, and how to use your rights.

Contents

  1. 1. Who we are
  2. 2. Whose data this notice covers
  3. 3. Our role for each kind of data
  4. 4. The personal data we collect
  5. 5. Legal bases for using your data
  6. 6. Who we share data with
  7. 7. Where your data is processed
  8. 8. How long we keep data (retention)
  9. 9. AI
  10. 10. Your rights
  11. 11. Security
  12. 12. Complaints
  13. 13. Children
  14. 14. Changes to this notice

This notice explains how Hedj Financial Risk Management Limited ("Hedj", "we", "us", "our") collects, uses, shares and protects personal data when organisations and their people use the Hedj platform at app.hedj.eu and our websites.

1. Who we are

Hedj Financial Risk Management Limited is a company registered in Ireland (registered no. 803831). Registered address: 2 Southwood Park, Blackrock, Co. Dublin, A94 D2C1, Ireland.

For any question about this notice or your personal data, email support@hedj.eu with "Data protection" in the subject line, or write to us at our registered address.

Our lead supervisory authority is the Data Protection Commission in Ireland.

2. Whose data this notice covers

  • People who visit our websites.
  • People who use Hedj for an organisation (our customer), including admins and other users.
  • Directors, owners and other people connected with a customer, where we check who the customer is.
  • People named in a customer's bank transactions, payment details or beneficiary details ("third parties named in transactions"). We usually cannot contact these people directly, so this notice is how we inform them.

3. Our role for each kind of data

Data and purposeHedj's rolePartner's role
Accounts, users, organisations and the treasury data customers enter in HedjControllerNot applicable
Bank data: the bank data service that reads it from the bankYapily Connect provides that service. In the UK, Hedj acts as Yapily Connect Ltd's agent once registered with the FCA; in the EEA, Hedj is not its agentYapily Connect Ltd (UK) or Yapily Connect UAB (EEA) is an independent controller
Bank data once Hedj receives it, to provide Hedj's featuresControllerYapily Ltd processes it for Hedj, as our processor
Business verification and screening for bank connections and Ebury servicesControllerNot applicable
Ebury onboarding information, payment instructions and beneficiary detailsProcessor, acting on Ebury's instructionsEbury is the controller
Ebury client profile criteria and joint marketingJoint controller with EburyJoint controller with Hedj
Hedj's own records of its customers and its relationship with them, including records of FX contractsIndependent controllerEbury is an independent controller of its own records

4. The personal data we collect

CategoryExamplesWhere it comes from
Account and user dataName, email address, job title, role, permissions, authority limits, sign-in recordsYou or your organisation's admin
Organisation dataOrganisation name, country, plan, users and access requestsYou or your organisation's admin
Treasury dataExposures, forecasts, hedges, scenarios, cash, debt, investments and counterpartiesYou or your organisation
Bank dataAccount details, balances, transactions, standing orders and direct debits, and the account holder's nameYour bank, through Yapily Connect, when you connect an account
Third parties named in transactionsNames, references and account details that appear in transaction descriptions, payment details or beneficiary detailsYour bank, Ebury or you
Derived dataPatterns, categories and forecasts built from your data (forecasts are assumptions, not facts)Created by Hedj
Business verification dataCompany register data, directors, owners, ID documents, and ID and selfie imagesYou, public registers
Screening resultsResults of sanctions, politically exposed person and adverse media checksPublic lists and our checks
Ebury dataFX contracts, quotes, currency accounts and balances, beneficiaries, payments and invoicesEbury and you
Terms acceptance recordsWhich version of which terms a person accepted or was shown, when, from which IP address and browser, and the authority statement they gaveYou
Technical dataIP address, device and browser details, logs and diagnosticsAutomatically, when you use Hedj

ID and selfie images are compared manually by a Hedj reviewer. We do not use automated biometric matching.

We do not ask for special category data, such as health or religious information. It may appear incidentally in bank transaction descriptions. We do not use it for any purpose of its own.

Identifiers that appear in the free text of bank transactions are redacted where we can detect them.

5. Legal bases for using your data

PurposeWhose dataLegal basis
Providing Hedj to a sole trader or partnershipThe sole trader or partnersContract
Providing Hedj to a companyIts staff and other usersLegitimate interests: delivering the service the company has contracted for
Connecting bank accounts and using bank data to show cash, forecast, reconcile and categoriseSole traders and partnersContract
The same, for companiesCompany staff and account holdersLegitimate interests: delivering the service the company asked for
Holding and using data about third parties named in transactions or beneficiary detailsThird parties named in transactionsLegitimate interests: giving customers complete and accurate records of their own transactions and payments
Sharing data with Yapily Connect and Ebury so they can provide the services a customer choosesUsers, account holders, directors and ownersContract (sole traders and partners); legitimate interests (everyone else)
Business verification and screeningUsers, directors and ownersLegitimate interests: preventing fraud and financial crime and meeting our partners' requirements; legal obligation where a law binds Hedj, such as sanctions law
Processing Ebury onboarding, payment and beneficiary dataEveryone in that dataWe act on Ebury's instructions; Ebury decides the legal basis as controller
AI-enhanced categorisation, when an admin switches it onThird parties named in transactionsLegitimate interests: categorising transactions accurately, with personal details stripped first
Security, fraud prevention, support and improving the serviceAll usersLegitimate interests
Keeping records of terms accepted and defending legal claimsUsers who accept termsLegitimate interests; legal obligation where a law requires the record
Tax and accounting recordsCustomers and their contactsLegal obligation
Telling customers about Hedj's productsCustomer contactsLegitimate interests (you can opt out at any time)

We rely on legal obligation only where a law binds Hedj itself.

We do not rely on consent as the legal basis for sharing your data with Yapily Connect or Ebury. When you press Confirm to connect a bank, you give the explicit consent that payment services law requires for the bank data service. That is a step under payment services law. It is not consent under data protection law.

Where e-privacy law requires your permission before we set non-essential cookies or send certain marketing emails, we ask for it first. Our Cookie Policy explains our cookies.

Where we rely on legitimate interests, we have weighed those interests against your rights, and you can object (see section 10).

6. Who we share data with

We do not sell personal data. We share it only as follows.

  • Yapily Connect Ltd and Yapily Connect UAB provide the bank data service as independent controllers. Your data will be shared with Yapily and may be used in connection with Yapily's value-added services. See Yapily's Privacy Notice and Yapily Connect's End User Terms.
  • Yapily Ltd provides the technology that connects Hedj to banks, as our processor.
  • Ebury (Ebury Partners UK Limited and Ebury Partners Belgium NV/SA) provides FX and payment services. Ebury's privacy notice is at privacy.ebury.com.
  • Amazon Web Services (AWS) hosts the platform, sends our emails and runs AI models for us, as our processor.
  • Professional advisers, auditors, regulators, law enforcement and courts, where the law requires it or to protect our rights.

Before any other company processes personal data for us, such as an identity verification provider, we will add it to this notice.

7. Where your data is processed

Hedj hosts its platform with AWS in the EU, in the Stockholm (eu-north-1) region. AI models run in AWS Bedrock in the EU.

Yapily Ltd and Yapily Connect Ltd are in the United Kingdom, and Ebury Partners UK Limited is in the United Kingdom. Transfers from the EEA to the UK rely on the European Commission's adequacy decision for the UK. Transfers from the UK to the EEA rely on the UK's adequacy regulations.

Some of Yapily's sub-processors are in the United States. Those transfers are covered by the European Commission's Standard Contractual Clauses, with the UK addendum where UK law applies. Yapily's Privacy Notice gives more detail.

8. How long we keep data (retention)

CategoryHow long we keep it
Account, user and organisation dataWhile the organisation's account is open, then 6 years
Treasury dataWhile the organisation's account is open, then deleted or anonymised as set out in the Master Terms
Bank data, including data about third parties named in transactionsWhile the organisation is a customer, then 6 years. It is kept after a bank authorisation lapses or is withdrawn, unless an admin uses the Delete bank data action or asks us to delete it
Ebury records5 years, or longer only where Ebury or the law requires. Where we act as Ebury's processor, we keep, return or delete data on Ebury's instructions
Business verification evidence and screening results5 years after the customer relationship ends, or longer only where Ebury or the law requires
Terms acceptance records, including the IP address and browser details recorded with each acceptance and authority statementWhile the organisation exists in Hedj, then 6 years. They are kept when the person who accepted leaves the organisation or closes their account, and they cannot be changed or deleted while they are kept
Technical logsUp to 12 months
Marketing preferencesUntil you opt out, and then a record of the opt-out

When a retention period ends, we delete the data or anonymise it so that it no longer identifies anyone.

9. AI

9.1 Transaction categorisation is rules-only by default for every organisation.

9.2 AI-enhanced categorisation is available on paid plans, if an admin of the organisation switches it on. Before any transaction text reaches the AI model, we strip personal details such as names, references and account identifiers. Only that stripped text is sent. The model runs in AWS Bedrock in the EU.

9.3 Any other AI-assisted features in Hedj also run in AWS Bedrock in the EU. Your data is not used to train the providers' models.

9.4 We do not make decisions with legal or similarly significant effects about anyone based solely on automated processing. Screening alerts are reviewed by a person.

10. Your rights

You have the right to:

  • access the personal data we hold about you;
  • have inaccurate data corrected;
  • have your data erased, except records we must keep to establish, exercise or defend legal claims, such as terms acceptance records, for the period in section 8;
  • restrict how we use your data;
  • object to our use of your data where we rely on legitimate interests, and to direct marketing at any time;
  • receive data you gave us in a portable format;
  • withdraw any permission you gave under e-privacy law; and
  • complain to a supervisory authority (section 12).

For bank data you can also:

  • withdraw bank access at any time, by disconnecting the bank in Hedj or directly with your bank;
  • let an authorisation lapse by not reconfirming it when it expires after 90 or 180 days, depending on the bank; and
  • ask an admin of your organisation to remove bank data with the Delete bank data action.

You can exercise your rights over the processing Yapily Connect or Ebury does as controllers directly with them. Where we act as Ebury's processor, we pass your request to Ebury within 5 business days and help it respond.

To exercise a right, email support@hedj.eu. We respond within one month, which can be extended for complex requests.

11. Security

We use encryption in transit, access controls, least-privilege access, network isolation, logging and monitoring. Access to customer data within Hedj is limited to people who need it to provide and support the service.

12. Complaints

If you are unhappy with how we handle your data, please contact us first at support@hedj.eu. You can also complain to a supervisory authority:

  • Ireland (our lead authority): the Data Protection Commission, www.dataprotection.ie;
  • United Kingdom: the Information Commissioner's Office, www.ico.org.uk.

13. Children

Hedj is a service for businesses and is not intended for children. We do not knowingly collect children's data.

14. Changes to this notice

We may update this notice. A new version takes effect when we publish it. We will tell you about it in Hedj and, for significant changes, by email, with a short summary of what changed, why, and what it means for you. Each version stays published, so you can see the text that applied at any time.

Hedj Financial Risk Management Limited is registered in Ireland, company number 803831. Registered office: 2 Southwood Park, Blackrock, Co. Dublin, A94 D2C1, Ireland.