CONFIDENTIAL © Yoyo Wallet Limited 2017
The Data Yoyo holds is Personal Data, so Yoyo is the Data Controller. However, the data which we allow our retail partners to access via Yoyo Engage (insights dashboard for clients) does not allow identification of individuals.
It is either aggregated data, or it is anonymised using a unique ID to represent each user - the retailer does not have access to users' names or email addresses.
The retailer does not hold Personal Data, so is not considered a Data Processor under the terms of the Act.