Contents

Privacy Notice – Bud Financial Inc

This notice describes how Bud Financial Inc also referred to as (“Bud”, “we”, “our” and “us”) will collect, use, and disclose your information, when you use products or services provided by us. It also describes any data protection rights you may have under applicable law; more information about data protection rights, and how to exercise them if they apply to you, is set out in the “Your Rights” section below.

For the purposes of this notice, the term “information” includes “Personal Data,” which means any information relating to an identified or identifiable individual, such as an individual's name, address, telephone number, or e-mail address.

Categories of Information we may collect and process

We may collect a variety of information from or about you or your devices from various sources, including from third parties such as banking providers.

Category	Examples
Personal Identifiers and contact details	Given name(s), preferred name, username, email address, home address.
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	Account details, balances, beneficiaries' details, standing orders, direct debits, rent and property details, transaction details and aggregated financial data.
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) and any touchscreen interactions.
Technical and Usage Data	Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
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.
Marketing & Communications Data	Your preferences in receiving marketing from us and our third parties and your communication preferences.

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For additional details on what information we may automatically collect when you visit our website, please refer to our cookie policy

Purposes for Processing your Information

We will process your information for the following purposes:

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.
Confirming and verifying your identity.
To send you service, technical and other administrative emails, messages and other types of communications. To ensure our products and services are working as intended, including tracking outages or troubleshooting issues that you report to us.
To ensure the security of our products and services and processing activities.
To detect, prevent and investigate 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 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.

Additionally, to fulfil our legal or regulatory obligations we may also process your information:

For 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.

Disclosure of Information to Third Parties

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose information that we collect or you provide as described in this privacy notice:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties (such as advertising and analytics partners) we use to support Bud’s data processing activities.
To a buyer or other successor in the event of a potential or actual merger, divestiture, restructuring, reorganization, 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.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our Terms and Conditions and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Bud, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

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. We will retain 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 are required to hold onto your Personal Data (e.g. to comply with legal and/or regulatory obligations).

Your Personal Data will only be processed as required by law or in accordance with this notice.

Please see “Your Rights” below for options that may be available to you in respect of your Personal Data. You can also contact Bud about our data retention practices by emailing help@thisisbud.com.

Third Parties

Our services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this notice does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

Security

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

Children’s Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our products or services is directed to children. If you learn that a child has provided us with personal information in violation of this notice, then you may alert us at help@thisisbud.com.

Your Rights

Under the applicable data protection laws in your jurisdiction, you may have certain rights over the Personal Data we hold on you. To the extent that you have these rights under applicable law, Bud agrees to respect the following rights in connection with your Personal Data, subject to exceptions provided by law:

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 by emailing help@thisisbud.com, 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. 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	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.

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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 may have the right to complain to a data protection authority where you live, work or where you believe a breach may have occurred.

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 provide those to you on request.

Supplemental Privacy Notice for Colorado Residents:

If you are a Colorado Consumer and would like to exercise your rights pursuant to the Colorado Privacy Act (CPA), including the “Right to Access”, “Right to Correct inaccuracies”, “Right to Delete”, “Right to Data Portability”, “Right to Opt-Out of Targeted Advertising”, and any implementing regulations adopted thereunder, please contact us at help@thisisbud.com.

Supplemental Privacy Notice for Connecticut Residents:

If you are a Connecticut Consumer and would like to exercise your rights pursuant to the Connecticut Data Privacy Act (CTDPA), including the “Right to Know”, “Right to Access”, “Right to Correct inaccuracies”, “Right to Delete”, “Right to Data Portability”, “Right to Opt-Out of Targeted Advertising”, and any implementing regulations adopted thereunder, please contact us at help@thisisbud.com.

Supplemental Privacy Notice for Nevada Residents:

Nevada SB220 provides the right to Nevada consumers to request that their personal information not be sold. This notice is a reminder that we do not sell your personal information to any third parties.‍

Supplemental Privacy Notice for Utah Residents:

If you are a Utah Consumer and would like to exercise your rights pursuant to the Utah Consumer Privacy Act (UCPA), including the “Right to Access”, “Right to Delete”, “Right to Data Portability”, “Right to Opt-Out of Targeted Advertising”, and any implementing regulations adopted thereunder, please contact us at help@thisisbud.com. We respect your rights as outlined in the UCPA and will not discriminate against you if you exercise those rights.

Supplemental Privacy Notice for Virginia Residents:

If you are a Virginia Consumer and would like to exercise your rights pursuant to the Virginia Consumer Data Protection Act (VCDPA), including the “Right to Access”, “Right to Correct”, “Right to Delete”, “Right to Data Portability”, “Right to Opt-Out of Targeted Advertising”, and any implementing regulations adopted thereunder, please contact us at help@thisisbud.com. If you would like to appeal our decision relating to your request, you have the right to submit an appeal and can do so by contacting us at help@thisisbud.com. We respect your rights as outlined in the VCDPA and will not discriminate against you if you exercise those rights.

Supplemental Privacy Notice for California Residents:

The California Consumer Protection Act (CCPA) and, the California Privacy Rights Act of 2020 ("CPRA"), effective January 1, 2023, and any implementing regulations adopted thereunder creates consumer rights for California residents relating to the access to, deletion of, and sharing of personal information that is collected by businesses. Terms (including defined capitalized terms) used in this California Privacy Notice have the same meanings given in the CCPA and CPRA and the associated regulations, unless otherwise defined herein. Those rights include:

Right to Know. California Consumers have the right to know what information we have collected about you (the categories and the specific pieces of information). Upon request, we must disclose and deliver the required information to you free of charge within 45 days of receiving your verifiable request. This time period may be extended once by an additional 45 days when reasonably necessary. This disclosure will cover the 12-month period preceding our receipt of your request. We are not required to provide your personal information more than twice in a 12-month period.
To exercise your rights in this area, please contact us at help@thisisbud.com.

Right to Delete. California Consumers have the right to request that we delete information we have collected from you. Upon request, we must delete any personal information about you which we have collected from you. We are not required to delete your personal information, however, if:

We need the information to complete the transaction or contract for which we collected the information from you.
We detect a security issue and need the information to protect against malicious, deceptive, fraudulent, or illegal activity and prosecute those responsible.
Deletion of the information creates an issue with regard to the exercise of free speech.
The information impacts engagement in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to privacy laws. To exercise your rights in this area, please contact us at help@thisisbud.com.

Right to Correct. If at any time you wish to review, update, change or delete any information you have provided to us please contact us at help@thisisbud.com.

Right to Opt-Out of Sale. As a reminder, we do not sell your personal information to any other parties. We are required to inform you, however, that in the unlikely event any changes occur in this regard, we will make every attempt to accommodate any consumer requests that are exercised in this area. To exercise your rights in this area, please contact us at help@thisisbud.com.

Right to Opt-Out of Sharing. California Consumers have the right to opt-out of the sharing of your Personal Information or Sensitive Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising), whether or not for monetary or other valuable consideration. To exercise your rights in this area, please contact us at help@thisisbud.com.

Right to Limit the Use and Disclosure of Sensitive Personal Information. You have a right to limit the use or disclosure of your Sensitive Personal Information to purposes set forth in the statute, including that use which is necessary and anticipated to perform the Services or provide the goods reasonably expected by an average consumer who requests those goods or Services (“Right to Limit The Use and Disclosure of Sensitive Personal Information”). To exercise your rights in this area, please contact us at help@thisisbud.com.

Right to Data Portability. California Consumers have the right to request that businesses transfer personal information to another entity, to the extent it is technically feasible. To exercise your rights in this area, please contact us at help@thisisbud.com.

Verification of Requests. In every instance, and for your protection, we must verify any of these requests to ensure that the individual making the request is authorized to make the request, in order to reduce the potential of fraud and to ensure the security of your personal information. We may require that you provide the e-mail address that we have on file for you and verify that you can access that account; as well as ask for your address, phone number, or other data we have on file in order to verify your identity. We will not require you to verify your identity, beyond asking for the information necessary to complete your request. Additionally, if someone else is submitting the request on your behalf, we reserve the right to validate their authority to act on your behalf in order to reduce the potential of fraud and to ensure the security of your personal data.

Discrimination for exercising your rights. We respect your rights as outlined in the CCPA. We will not discriminate against you if you exercise your rights in any of the above categories by denying services to that individual, by charging different prices, or by providing a different level of services for exercising their rights.

Information relating to Bud

Bud’s address is 108 Lakeland Avenue, Dover, Delaware, 19901.

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