This Notice describes how Bud Financial Limited also referred to as (“Bud”, “we”, and “us”) will make use of your Personal Data when you use the Bud App (the “App”). It also describes your data protection rights, including a right to object to some of the processing which Bud carries out. More information about your rights, and how to exercise them, is set out in the “Your Legal Rights” section below.
Categories of Personal Data We Process
We Process the following categories of Personal Data about you when you use our App:
Given name(s), preferred name.
Date of birth / age; salutation, title; and language preferences.
Address; email address.
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).
Data Automatically Collected from the App
Device type, operating system, browser type, browser settings, IP address, language settings, App usage statistics, App settings, dates and times of connecting to the App, location data, and other technical communications information (some of which may constitute Personal Data), including event logs and aggregate statistical information.
Account details, balances, beneficiaries' details, standing orders, direct debits, rent and property details, transaction details and aggregate financial data.
Records of your interactions with our online content, records of content displayed or App screens displayed to you, 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
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 App or 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 Land Registry and Credit Reference Agencies; (ii) for the purposes of KYC and identity verification, Bud may obtain information from third parties such as Northrow; and (iii) as part of the “marketplace journey”, Bud may obtain information from investment providers.
Purposes of Processing and Legal Bases for Processing
The purposes for which we Process Personal Data, and the legal bases on which we perform such Processing, are as follows:
To fulfil a contract, or take steps linked to a contract including:
- To provide you with the App, and the associated services including account consolidation, transaction categorisation, spending analysis and personalised recommendations, 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 relating to the App.
As required by Bud to conduct our business and pursue our legitimate interests, in particular:
- To ensure our App is working as intended, such as tracking outages or troubleshooting issues that you report to us.
- For the purpose of ensuring the physical and electronic security of our business and our property.
- For the purposes of detecting, preventing and investigating fraud.
- For analytics and measurement to understand how the App is used. For example, we analyse data about your use of the App to do things like optimise product design and for product improvement.
- To conduct surveys and other market research to ensure our services are relevant to your needs.
Where you give us consent:
- Where required by law to send you direct marketing.
- Where we access information from your device using cookies or equivalent technologies in-App.
- 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:
- 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 conducting an investigation.
Disclosure of Personal Data to Third Parties
Bud may share your Personal Data in the following ways:
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.
Marketplace Service Providers
To provide the marketplace services your Personal Data may be shared with utility companies, investment providers, government agencies such as Land Registry, credit referencing agencies (such as Equifax), and financial services comparison websites such as GoCompare.
With accountants, auditors, lawyers and other outside professional advisors to Bud, subject to professional and/or binding contractual obligations of confidentiality.
Third Party Service Providers
With third party service providers who support Bud’s business, who will process it on behalf of Bud for the purposes identified above.
Law Enforcement Authorities
With law enforcement agencies or courts, to the extent necessary for the establishment, exercise or defence of legal rights.
Prevention of Crime
With relevant parties for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties.
Business or Share Sale
With any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our shares, business or assets (including in the event of a reorganisation, dissolution or liquidation).
International Transfer of Personal Data
Where information is transferred outside the European Economic Area (the “EEA”), Switzerland or the United Kingdom and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review by contacting Bud at the contact details below.
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.
1. We will retain Personal Data in a form that permits identification only for as long as:
(a) We maintain an ongoing relationship with you (for example, as long as you are a user of the App); or
(b) Retention of your Personal Data is necessary in connection with the lawful purposes set out in this Notice, for which we have a valid legal basis
2. In addition, Bud will retain the data for the duration of:
(a) Any applicable limitation period under law (i.e., any period during which a person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant) plus an additional two month period following the end of such limitation period; and
(b) If any relevant legal claims are brought, Bud will continue to Process Personal Data for such additional period as is necessary in connection with that claim.
Once the periods at (1) and (2) above have passed, Bud will either permanently delete or destroy the relevant Personal Data; or anonymize the relevant Personal Data.
Your Legal Rights
You have the right to ask us for a copy of your Personal Data; to correct, delete or restrict (and/or stop any active) processing of your Personal Data; and to obtain the Personal Data you provide to us for a contract or with your consent in a structured, machine readable format, and/or to ask us to share (and/or port) this data to another controller.
In addition, you can object to the processing of your Personal Data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing). These rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights - including obtaining copies of our legitimate interests balancing tests - 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.
We Process Personal Data to contact you with information regarding services that may be of interest to you. You may unsubscribe for free at any time.
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for Processing your Personal Data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
Sharing with Credit Referencing Agencies
By using the Bud App, information regarding your rental payments and track record as a tenant, may be shared with Equifax Ltd. Equifax will add this information to the credit reference data it holds about you and use it as a controller, in accordance with its fair processing notice available at https://www.equifax.co.uk/About-us/Privacy_policy.html.
Cookies and Similar Technology
We Process Personal Data by using Cookies and similar technologies.
When you visit the App we may access your device, thereby engaging the cookie rules, subject always to obtaining your consent, where required, in accordance with applicable law. We use these technologies to record information about your device, your browser and, in some cases, your preferences and browsing habits.
Details of Controllers
For the purposes of this Notice, the relevant Controller is: Bud Financial Limited - 1st Floor WeWork, The Bower, 207 Old Street, London, EC1V 9NR.
Bud is registered with the Information Commissioner’s Office under registration number ZA198709.
Our Data Protection Officer is contactable at the following address: Bud Data Protection Officer, Bud Financial Limited, 1st Floor WEWORK, The Bower, 207 Old Street, London, EC1V 9NR.