Finvence Technologies Limited (“Finvence”) (collectively referred to as "we", "us" or 'our' in this privacy policy) respects your privacy and is committed to protecting your personal data. This privacy policy applies to your use of our website and software and tells you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Finvence collects and processes any personal data we collect from you (either directly or via third parties), or that you provide to us through your use of our Platform or this website.

We may receive your personal data via the following routes: (i) Direct interactions. You may give us your Identity, Contact and Financial Data by registering as a User on our Platform; (ii) Automated technologies or interactions. As you interact with our Platform and website, we will automatically collect Technical, Profile and Usage Data about your equipment, browsing actions and patterns; and (iii) Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources such as insolvency practitioners, open-banking applications and public registers. Further details on the ways in which we may receive your personal data is set out in section 3 below.

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

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Finvence is the data controller and responsible for your personal data processed via this website. We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

• DPO: Kenneth Doherty
• Email: technical@finvence.com
• Address: Pearse Road, Ardara, Co. Donegal, Ireland, F94 XVN6

You have the right to make a complaint at any time to the Data Protection Commission (DPC), the Irish supervisory authority for data protection issues ( www.dataprotection.ie ). We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.

Third-party links

This website and our Software products and services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website and/or services we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Through our services we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, middle name, maiden name, last name, former names, username or similar identifier, marital status, title, date of birth, nationality, employment status, occupation, residential status, dependents, dependents age, marital status, photos/images and gender.
• Contact Data includes billing address, delivery address, physical address(es), postcode, email address and telephone numbers.
• Financial Data includes bank account details, wage/salary data, National Insurance number, tax status, tax code, welfare and benefits details, pension data, assets, savings and investment data, loan and creditor debts, credit history and financial solvency status.
• Transaction Data includes details about payments to and from your bank accounts which our software may have access to.
• Technical Data includes the type of device you use (for example a mobile device and unique device identifier such as the IMEI number), the MAC address of your device’s wireless network, 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, and other technology on the devices you use to access our software or website.
• Profile Data includes your username, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes details of your use of our software, services or website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Vulnerability Data includes vulnerability flags, registration numbers and priority service indicators which may represents your personal circumstances at a given point in time.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or product feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

3. How is your personal data collected

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

• Direct interactions: You may give us your Identity, Contact or Financial Data by using our services or software products, or by corresponding with us by post, phone, email, website contact form or otherwise.
• Automated interactions: If you use our services or software products we may collect Technical, Profile and Usage Data about your equipment, browsing actions and patterns. We collect this personal data via usage, audit and feedback logs and other similar technologies. If you supply us with bank statements or similar financial documents or digitally connect your bank accounts through our software, you should be aware that we may also collect Transaction Data.
• Third party or publicly available sources: We may receive personal data about your from various third parties and public sources such as: (i) Identity, Contact, Financial and Transaction Data from: providers of technical, payment and delivery services and data brokers or aggregators, insolvency practitioners, creditor agencies, financial advisors inside the United Kingdom or EEA. (ii) Identity, Contact and Vulnerability Data from publicly available sources, including but not limited to Companies House, the Electoral Register, the Insolvency Service, the Gazette and the Vulnerability Registration Service, - based inside the United Kingdom or EEA. (iii) Technical Data from advertising networks such as Microsoft based inside the EEA and the United Kingdom.

Cookies

We do not use browser cookies on our website.

4. How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

• Where you have consented before the processing.
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interested and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
Registration of an account on our software.	(a) Identity (b) Contact (c) Technical (d) Profile	Your consent.
Uploading content to your account for use of the software in the performance of the Service.	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Technical (f) Vulnerability	(a) Your consent. (b) Performance of a contract with you. (c) Necessary for our legitimate interest.
To share analytics and processing results with you and Third Parties e.g insolvency practitioners and regulators.	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Vulnerability	(a) Your consent. (b) Performance of a contract with you.
To manage our relationship with you including notifying you of changes to the services.	(a) Identity (b) Contact (c) Financial (d) Profile (e) Marketing and Communications	(a) Your consent. (b) Performance of a contract with you. (c) Necessary for our legitimate interest. (d) Necessary to comply with legal obligations.
Storing and using data to improve our data models and algorithms.	(a) Financial (b) Transaction (c) Technical (d) Vulnerability	Necessary for our legitimate interests (to train and improve the accuracy of our data models and analytics and to improve our Service).
To administer and protect our business and our software including troubleshooting, data analysis and system testing.	(a) Identity (b) Contact (c) Technical (d) Usage	Necessary for our legitimate interests (for running our business, provision of administration, IT services and network security).
To monitor trends so we can improve services.	(a) Identity (b) Contact (c) Technical (d) Profile (e) Usage (f) Marketing and Communications	(a) Your consent.                                                                     (b) Necessary for our legitimate interests (to develop our Services, define types of customers for our products and Services, to develop our business and to inform our marketing strategy).

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosure of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. Internal transfers

The only transfers of your personal data that take place are within the UK and EEA.

7. 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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

1. Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of the personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.
4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) 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.
5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) If you want us to establish the data's accuracy. (ii) Where our use of the data is unlawful but you do not want us to erase it. (iii) 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. (iv) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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.
7. Withdraw consent at any time where we are relying on consent to process your personal data. 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.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Consent means that you have given us permission (your consent) to process your personal data for one or more specific purposes.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties: Other companies in the Finvence Group acting as joint controllers or processors and who are based in the United Kingdom or EEA.

External Third Parties:

• Service providers acting as processors or independent controllers based in the United Kingdom or EEA who provide cloud services, open banking services, insolvency registers, postcode lookup services, and vulnerability registers.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, financial advisors, mortgage brokers, loan brokers, loan origination companies, insolvency practitioners, debt advisors and insurers based in the United Kingdom or the EEA who provide consultancy, banking, legal, mortgage, loan, insolvency, insurance and accounting services.
• Regulators and other authorities acting as processors or joint controllers based in the United Kingdom or EEA.

DEFINTIONS

Software means a digital technology platform which offers Services that uses machine learning technology to automate document, data, reporting and administrative processes for customers. The Software can be accessed by insolvency practitioner firms, debt advisor firms, personal financial planning firms, mortgage brokers, loan brokers and loan origination companies, or consumers as authorised users on behalf of each of the firm types via online web-portals or mobile app.

Services means our specific software product(s), including any related documentation, and excluding any third-party products.

User means you and/or the named users authorised by you to use the Services in accordance with the terms of service and usage policy of that Service and Software