Contents

Privacy Policy - Bud

This policy describes how Bud Financial Limited also referred to as (“Bud”, “we”, “our” and “us”) will use your personal data when you use products or services provided by us. It also describes your data protection rights, more information about your rights, and how to exercise them, is set out in the “Your Rights” section below.

This website is not intended for children and we do not knowingly collect data relating to children.

Bud acts as data controller when providing the Bud Services described in this Privacy Policy to you.

Bud’s address is 167-169 Great Portland Street, 5th Floor, London, W1W 5PF.

To get in touch with Bud, please email: help@thisisbud.com

1. Categories of personal data we may collect and process about you

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Category	Examples
Personal Identifiers and Contact Details	Given name(s), preferred name, username, email address, company name, job title, phone number, address, such as when you sign up for an account.
Demographic Information	Salutation, title, and language preferences.
Consent Records	Records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
Financial Information	When you link your banking account or other financial accounts to our Services, we may receive your account details, balances, income information, beneficiaries' details, standing orders, direct debits, rent and asset details, transaction details and aggregated financial data.
Prompts and Outputs	The text, audio, images, video, documents, and other materials you submit to the Services (“Prompts”) and the responses generated based on your Prompts (“Outputs”).
Content Data	Records of your interactions with our online content, any interaction you may have had with such content (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part, the pages or other content you view, referrer information (the website you visited before coming to our Services), the dates and times of your visits) and any touchscreen interactions.
Device and Location Information	IP address, device type, device identifiers, operating system version, and web browser type and version.
Career Information	Contact information; information you provide such as your employer and role.
Communications Information	Preferred name; any views and opinions that you choose to send to us and any feedback provided to us via the “Contact Us” functionality, including bug reports. When you sign up for a newsletter, we receive your personal or business email. When we send you emails, we may use embedded pixels or other technologies to track information about your receipt and interaction with our emails, such as whether and when you open them, whether you access any links included in our emails, how long you read our emails, whether you forward our emails and to whom, your Location Information (described below), and your Device Information (described below), to learn how to deliver a better customer experience and improve our Services.

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Information from Cookies and Other Tracking Technologies. We and our third-party partners collect information about your activities on our Services using cookies, pixel tags, SDKs, or other tracking technologies. Our third-party partners, such as analytics, advertising, and security partners, may also use these technologies to collect information about your online activities over time and across different services. For additional details on what information we may automatically collect when you visit our website, please refer to our cookie policy: https://www.thisisbud.com/cookies-notice.

We may also collect personal data about you from publicly available sources for the purposes of completing our anti-money laundering and know-your-client checks that we are required to carry out as a regulated financial services firm.

We do not collect any special categories of personal data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- use our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Notice for further details.
Use of the Bud Services. When you make use of the services provided to you by Bud, we will collect data about you that is generated. This may include transaction details and other financial records, and information about your use of our AI services.
Third parties or publicly available sources. Bud may also receive personal data about you from third parties.

3. Purposes and Legal Bases for Processing

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

To fulfil a contract, or take steps linked to a contract including:

To provide you with products and services including account consolidation, transaction categorisation, spending analysis and other insights, together with ancillary services such as customer support.
To confirm and verify your identity.
To send you service, technical and other administrative emails, messages and other types of communications.

As required by Bud to conduct our business and pursue our legitimate interests, in particular:

To ensure our products and services are working as intended, including tracking outages or troubleshooting issues that you report to us.
For the purpose of ensuring the security of our products and services and processing activities.
For the purposes of detecting, preventing and investigating fraud.
For analytics and measurement to understand how our products and services are used. For example, we analyse data we collect to optimise product design and for the purposes of product improvement.
To conduct surveys and other market research to ensure our services are relevant to your needs.
To train, develop, and improve the artificial intelligence, machine learning, and models that we use to support our Services.
For compliance purposes, including enforcing our Terms and Conditions or other legal rights, or as may be required by applicable laws.

Where you give us consent:

To access your transaction data from your banking or financial services provider(s) for the purposes of account consolidation, transaction categorisation, spending analysis and other insights.
For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable, or otherwise of interest to you.
Where we access information from your device using cookies or similar technologies.
On other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.

For purposes which are required by law or to fulfil our regulatory obligations, including:

For “know your client” checks and screening against government, law enforcement agency sanctions lists and other legal restrictions.
In response to requests by legal or regulatory authorities, government or law enforcement authorities.

4. Disclosure of personal data to Third Parties

We may share your personal data with the following categories of Third Parties. If we do, they will use your data in the ways described below:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties (such as our AI service providers and our advertising and analytics partners) we use to support Bud’s data processing activities. We use analytics services such as Google Analytics to collect and process certain analytics data. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/.
To third parties through a third-party application integration to our Services.
To a buyer or other successor in the event of a potential or actual merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of Bud’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by Bud about our website users is among the assets transferred.
To comply with any court order, law, or legal process, including to respond to any government or regulatory request. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.
To enforce or apply our Terms and Conditions and other agreements, including for billing and collection purposes.
For any other purpose disclosed by us when you provide the information.
With your consent.

5. International Transfer of personal data

If we transfer personal data outside of the UK or the European Economic Area (the “EEA”), to a service provider located in a country that is not subject to an adequacy decision by the UK ICO or the EU Commission, we will ensure that the transfer of personal data is adequately protected through the use of the approved UK or EU Standard Contractual Clauses, as applicable.

To understand more about the protections we have in place over the transfer of personal data, you may contact us using the details in Section 11 below.

6. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

7. Data Retention

We take every reasonable step to ensure that your personal data is only processed for the minimum period necessary for the purposes set out in this policy. We will retain personal data in an identifiable form for as long as we maintain an ongoing relationship with you (i.e. you are a user of our services) or if we are required to keep your personal data for another lawful basis (e.g. a basic record of any consent you may have provided us with). Once these applicable periods have passed Bud will permanently delete or fully anonymise your personal data.

8. Your Rights

You have a number of rights under data protection laws in relation to your personal data, including:

Access	You can request that we provide you with a copy of the personal data that we hold about you and to check that we are processing it lawfully.
Correction	If you believe the personal data we hold on you is inaccurate, you can request that we update or correct it, although we may need to verify the accuracy of the new data you provide to us.
Revocation	If we rely on your consent to process your personal data, you may withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Objection or Opt-out	You may request us to stop processing your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Erasure	If we no longer need your personal data and have no other legal basis for processing, you can request that we delete it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
Restriction	This enables you to ask us to suspend the processing of your personal data in the following scenarios: If you want us to establish the data's accuracy. Where our use of the data is unlawful, but you do not want us to erase it. Where you need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims. You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Portability	You may ask us to provide you or a third party with a copy of the personal data you provided to us in a portable format, to use with other organisations. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.

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To exercise any of these rights, please email: help@thisisbud.com. Please note that these rights are subject to certain exemptions, which Bud will apply on a case-by-case basis.

If you have unresolved concerns, you have the right to complain to a data protection authority where you live, work or where you believe a breach may have occurred. In the UK, this is the Information Commissioner’s Office (www.ico.org.uk)

9. Direct Marketing

If you provide your consent, we may process your personal data in order to contact you with information regarding services that may be of interest to you. You may withdraw your consent and unsubscribe for free at any time, using the contact details below or by following the instructions in any email marketing you may have received from us. If you opt out, we may still send you other types of emails, such as support, service, and other emails about our ongoing business relationship.

For other marketing services that we provide, such as downloadable reports or fact sheets, we will rely upon our legitimate interests to provide you with those, as you have expressly requested them.

10. Changes to this policy and your duty to inform us of changes

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

11. Information relating to Bud - Contact us

Bud’s address is 167-169 Great Portland Street, 5th Floor, London, W1W 5PF.

Bud is registered with the Information Commissioner’s Office under registration number ZA198709.

Bud is a private limited company registered in England & Wales (registration number 09651629) and is regulated by the FCA under registration number 793327.

To get in touch with Bud, please email: help@thisisbud.com

For details on what information we may collect when you visit our website, please refer to our Cookies Notice