[Magdalena]

Hi Everyone!

I just wanted to let you know about Suits me terms and conditions (agreement), as there are several points worth questioning:

Terms and conditions document:

1. Point D –
   Providing all know your customer and anti-money laundering data to Suits
   me – GDPR constrains if credit union will not form a
   partnership. As if partnership will be formed Data Sharing Agreement will
   form part of it.
2. Point E, 2
   – We cannot offer any alternative to our members – which should be considered by credit unions prior to making a decision
   in my opinion.
3. Point F, 4
   – Nondisclosure agreement clause– terms and
   conditions cannot have nondisclosure clauses within them, which proved
   that document is an agreement.
4. Point G, 1 – They can still request onboarding and
   AML documents, even from existing Engage members and they can also refuse
   an account for any reason – so they can request an ID from any vulnerable,
   homeless member or close their account, which is why we want those cards
   in the first place, so not helpful at all.
5. Point H, 1
   – Agreement ? And 30 days to terminate it? – Document is
   presented in the form of terms and conditions not the agreement, which it
   actually is.
6. Point N , 1
   and 3 Proof that it is an agreement and to get out of it we need to
   respond within 30 days.

I do not like the form this agreement (not terms and conditions) and data sharing agreement are presented. Credit unions might not realise that they need to respond to it within 30 days.

I have also several constraints about data sharing agreement, however this could be the problem of credit unions forming partnership with Suits me (happy to help if anyone is struggling).

If your credit union is not willing to form a partnership or share data with Suits me, you need to respond to them in writing within 30 days of receiving terms and conditions email. If your credit union is not willing to form a partnership with Suits me existing members of Engage may still use its services and will be contacted by Suits me individually for due diligence.

Thank you,

Magdalena Niemczyk – Senior Compliance Manager – Pennine Community Credit Union

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[mbrazendale]

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[Magdalena]

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[David]

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