Contents

Mobile privacy policy

This Notice 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.

1. Categories of Personal Data we may collect and process

We may collect and process the following categories of Personal Data about you when you use our products and services:

Personal Identifiers and contact details	Given name(s), preferred name, username, email address. For certain services Bud may also require your address, location and/or phone number.
Demographic Information	Date of birth / age; 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).
IP Address, Location and Browser Information	Some information is automatically collected when you interact with Bud Web Applications through your Browser. This can vary from device to device but generally includes information about your device such as your operating system, version and device; your browser and browser version; your IP (Internet Protocol) address; and the website you visited before ours.
Financial Information	Account details, balances, beneficiaries' details, standing orders, direct debits, rent and property details, transaction details and aggregated financial data.
Web Application & Online Content Interaction Data	Records of your interactions with our online content and any interaction you may have had with such content (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions. We may collect information on your interactions with Bud’s online content and web applications including event logs, aggregate statistical information, duration of your visit, changes to user state, interaction with web elements (such as touchscreen interactions, mouse clicks, mouse hovers or any forms you complete in whole or in part) and metadata about your site usage and visit. We may use cookies and other tracking technologies to capture this data.
Views & Opinions	Preferred name, any views and opinions that you choose to send to us or publicly post about us on social media platforms and any feedback provided to us via the “Contact Us” functionality, including bug reports.

Bud may also receive Personal Data about you from third parties, for example: (i) as part of our rent recognition service Bud may obtain information from third parties such as HM Land Registry and Credit Reference Agencies; (ii) as part of our credit score service, Bud may obtain information from third parties such as Credit Reference Agencies; iii) for the purposes of KYC and identity verification, Bud may obtain information from third parties such as Northrow Limited; and (iv) as part of the “marketplace journey”, Bud may obtain information from investment providers.

2. Purposes and Legal Bases for Processing

The purposes for which we process Personal Data, and the legal bases that we rely upon, are as follows:

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

To provide you with the products and services including account consolidation, transaction categorisation, spending analysis and other insights, together with ancillary services such as customer support.
Confirming and verifying 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.

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.
Where required by law to send you direct marketing.
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 fulfill 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.

3. 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:

Service Providers

With service providers who support Bud’s data processing activities as detailed under Section 2 of this notice.

Marketplace Partners

To provide our marketplace services to you your Personal Data may be shared with our Marketplace Partners which include:

Utility companies
Investment providers
Government agencies such as the Land Registry
Credit referencing agencies (such as TransUnion, Equifax and Experian)**, and financial services comparison websites such as GoCompare.

Legal & Regulatory Authorities

With legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation.

**Sharing with Credit Referencing Agencies

If you use Bud’s Rent Recognition service, information relating to your tenancy (including your rental payment history) may be shared with credit reference agencies, TransUnion International UK Limited, Equifax Ltd and Experian Ltd (the “CRAs”). The CRAs may disclose information related to your tenancy to their other customers for the purposes of verifying identity, assessing the risk of giving credit, preventing fraud, tracing debtors or as otherwise detailed in their CRAIN notices below. Bud will share information related to your tenancy with the CRAs, based upon your consent. Once shared the CRAs may continue to process information related to your tenancy, even if you revoke your Open Banking consent or stop using Bud’s Rent Recognition service. If you would like to understand how TransUnion, Equifax and Experian use and share data (including the legitimate interests they pursue) please click the following links: www.transunion.co.uk/crain , www.equifax.co.uk/crain and https://www.experian.co.uk/legal/crain/

4. International Transfer of Personal Data

If we transfer Personal Data outside of the UK or the European Economic Area (the “EEA”), to a Third Party 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 8 below.

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 notice and/or the reasons set out below.

We will retain your personal data in an identifiable form for as long as we maintain an ongoing relationship with you (e.g. you are a user of our services), or we require 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.

6. Your Rights

Under the applicable data protection laws you may have certain rights over the Personal Data we hold on you, including:

Access	You can request that we provide you with a copy of the Personal Data that we hold about you
Correction	If you believe the Personal Data we hold on you is inaccurate, you can request that we update or correct it.
Revocation	If we rely on your consent to process your Personal Data, you may withdraw that consent at any time
Objection or Opt-out	You may request us to stop processing your Personal Data, we will either agree to it or explain why we are not able to. Stopping processing your Personal Data may impact the services we can provide to you.
Erasure	If we no longer need your Personal Data and have no other legal basis for processing, you can request that we delete it
Restriction	In certain circumstances, you can ask that we restrict the processing of your Personal Data, such as where you believe the Personal Data we hold is inaccurate
Portability	You may ask us to provide you with a copy of the Personal Data you provided to us in a portable format, to use with other organizations

To exercise any of these rights you can get in touch with us using the details set out below.

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.

7. 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 following the instructions in any email marketing you may have received from us.

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.

8. Details of Controller

For the purposes of this Notice, the relevant Controller is: Bud Financial Limited, 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 numbers 765768 and 793327.

For contact with Bud, please email: help@thisisbud.com