1.1 This Privacy Policy explains the total range of purposes and legal bases upon which Moneyhub Financial Technology Ltd (company number 06909772) (“Moneyhub”) collects, processes, stores and shares data that can identify you (the “End User”). We reserve the right to publish different or bespoke versions of this global privacy policy, to suit particular products, sites or apps.

1.2 Moneyhub has its registered office at C/O Roxburgh Milkins Limited Merchants House North, Wapping Road, Bristol, United Kingdom, BS1 4RW, United Kingdom., with our principal place of business at Runway East Temple Meads, 101 Victoria Street, Bristol, BS1 6PU, United Kingdom. We are registered with both the Information Commissioner (No. Z2507137) and the FCA’s Financial Services Register (reference no: 809360).

1.3 You can contact Moneyhub at any time for more information about this policy so please get in touch with us at support@moneyhub.com

1.4 This Privacy Policy primarily applies to our account-information services, our payment initiation services, and to your use of our platform and software applications hosted or made available by us, wherever and however you access them (“the Service”). To a lesser extent this Privacy Policy applies to any visitor to our websites (where the level of interaction with your data and the amount of data processing will be much less).

1.5 Together with our various user terms (“Terms of Use”), this Privacy Policy forms our agreement with you. Capitalised terms not defined in this Privacy Policy shall have the meaning given to them in our applicable Terms of Use or in the General Data Protection Regulation (EU) 2016/679 (the “EU GDPR”) or the retained version of the EU GDPR as it applies in the UK from 1 January 2021 (the “UK GDPR”).

3.1 We may need to share information about you with certain service providers who help us to deliver the Service to you, such as agents registered with the FCA or third party technology companies who may provide elements of the Service functionality and other companies in our corporate group). We refer to the latter service providers as (“Third Party Service Providers”). We only disclose personal data to Third Party Service Providers for the purposes explained in this Privacy Policy.

3.2 You may access the Service directly through us or through enterprise clients of Moneyhub whose platforms are powered by Moneyhub or through other partners who operate within the Moneyhub ecosystem (for example, your financial adviser, your employer or a provider of your financial products) (“Third Party Members”). In order to engage with such Third Party Members, you may be required to enter into contracts with them and accept additional privacy policies which are specific to those Third Party Members. We may also share anonymous aggregated data with Third Party Members so they can understand trends and preferences across groups of users in a non-personalised way such as how spending habits are evolving or which new technologies or payment-types are being used more than others. These insights in turn allows Third Party Members to refine or pivot their own service-offers to their clients or create new partnerships with other organisations to provide better, more relevant functionality, products and services which users may want to use.

5.1 Moneyhub does not engage in restricted transfers of personal data (i.e. those which do not benefit from the “appropriate safeguards” under UK GDPR or EU GDPR). We do however engage in some international transfers of data (outside the EEA and UK) where the appropriate safeguards are in place, such as the deemed application of standard contractual clauses approved by the European Commission. We shall continue to use these and will also use UK related standard contractual clauses as and when appropriate and applicable.

5.2 For more information on the privacy practices of our key international partners, please see the relevant additional material at the foot of this Privacy Policy.

6.1 Where we hold your personal data and are responsible for it, it will be stored for the life of your contract with us and in accordance with the Moneyhub data retention policy and UK GDPR.

6.2 Your contract with us would typically expire when you delete your account with us or ask us to delete your Moneyhub account for you. Our databases are backed up but such backups are never held for more than 90 days at a time. It is crucial that we hold your personal data in this way because without it, we would not be able to fulfil our contract with you and show you copies of your account information or payment transaction information, when you request/select these.

7.1 Once we have received your information, we will use procedures and security features to try to prevent unauthorised and unlawful access and processing, as well as accidental loss, destruction or damage. We use encryption technology to protect personal data that you submit to us online in order to reduce the risk of your data being intercepted by unauthorised persons during transmission.

7.2 We deploy a range of “technical and organisational” measures including physical, electronic, and procedural safeguards to protect information we process and maintain.

7.3 Please be aware that the transmission of information via the internet or mobile networks is not completely secure; we cannot guarantee the security of your data transmitted to or from us and any transmission is at your own risk. Moneyhub 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. It will be clear to you when you click on a link that will take you to a Third Party Member we strongly encourage you to read their privacy policies in detail. We do not control these third-party websites and are not responsible for their content or their privacy statements.

7.4 In the event there is an occasion in future where there is an unauthorised use or breach with respect to personal data, Moneyhub shall comply with GDPR expectations and timelines (including a 72 hour investigation and reporting window) in order to mitigate the risk to any individuals affected.

Moneyhub uses (i) Strictly necessary (essential) (ii) Functional (iii) Analytical (measuring performance) and (iv) Tracking/advertising types of cookies.

Cookies may be delivered by us directly to you (first-party cookies) or delivered by one of our partners (such as Intercom for users of AISP or PISP services). Cookies can be either session cookies or persistent cookies. Session cookies enable sites to recognise and link the actions of a user during a browsing session and expire at the end of each session. Persistent cookies help us recognise you and these are stored on your system or device until they expire, although you can delete them before the expiry date.

8.1 Moneyhub uses cookies for the following reasons:

For our products/platform:

• To help us improve End Users’ experience
• To fulfil API calls and integration requests to connect to various accounts
• To help with data protection and spot fraudulent activity

For our websites:

• To remember preferences and settings
• To identify errors on the site and assess performance
• To help us understand traffic data relating to our site, e.g. time and date of visit

8.2 What other similar technologies does Moneyhub use?

Moneyhub uses certain tools for basic font usage and to understand email-opening statistics by recipients of our emails). These help us to gauge the effectiveness of certain communications, promotions and marketing campaigns.

8.3 How you can take control of cookies and similar technologies

You have rights to manage and turn off/on certain cookies as you wish from your browser settings but you may not be able to use our applications or features of our sites if cookies are disabled.

8.4 In light of recent changes to cookies practices in 2021 (with respect to the disablement of third party cookies on some browsers) we include below an updated list of the more popular browser types with hyperlinks showing how to adapt their cookie settings accordingly:

• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Opera
• Apple Safari

8.5 Where & how Moneyhub uses cookies

We use cookies in several places, and some examples from third parties are included below:

For our Product (platform):

• Adjust
• Braze
• Heap
• Intercom
• Zendesk

For our websites:

• Squarespace
• Google Ads
• Google Analytics
• Vimeo
• Cloudflare
• Pardot

For more information on the main cookies currently used, their purpose and their duration please get in touch with us at support@moneyhub.com

10.1 Right of Access

You have the right to access information held about you and you can ask us for a copy of the information at any time. Where we have good reason, and if the law permits, we can refuse your request for a copy of your personal data, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.

10.2 Right of Correction or Completion

If personal data we control and hold about you is not accurate or needs updating you have a right of rectification (we can easily correct some of your personal data like an email address upon your instruction, but we cannot unilaterally amend your credit card transaction data if supplied to us in error by a third party) .

10.3 Right of Erasure

In certain circumstances, you have the right to request that personal data we hold about you is erased for example if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.

10.4 Right to Object to or Restrict Processing

In certain circumstances, you have the right to object to our processing of your personal data by contacting us. You have the right to object to use of your personal data for direct marketing purposes. You have a legal right to object at any time to: (i) use of your personal data for direct marketing purposes; and (ii) processing of your personal data which is based on our legitimate interests, unless there are compelling legitimate grounds for our continued processing.

NOTE: If you do object, it is highly unlikely we will be able to provide our Service to you given the nature of our products and solutions.

10.5 Right of Data Portability

To save you time, you should know that the vast majority of the personal data and transaction data you would want to port across to other systems, devices or software solutions are readily downloadable from our platform and the Moneyhub App. (It is highly unlikely if you are a website visitor we will have any personal data you would wish to port).

Where your request to move or migrate is more complex than you simply downloading the data that you need from the platform, you can ask us to transmit your data in a structured, commonly used and machine-readable format. Of course, we cannot guarantee technical compatibility with a third party organisation’s systems if that is your desired destination and we cannot accede to requests that involve personal data belonging to other persons.

10.6 Marketing

You have the right to ask us not to process your personal data for marketing purposes. We will only process your personal data for such purposes where you agree to such processing (e.g., by checking certain boxes on the forms or registration pages we use to collect your information).

If you have previously agreed to us using your personal data for marketing purposes, you may change your mind at any time by contacting us at marketing@moneyhub.com. You will also be given the opportunity to unsubscribe when you receive marketing messages.

10.7 Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.

To the extent that we are processing your personal data based on your consent, you have the right to withdraw your consent at any time. You can do this by contacting us.

We aim to keep your personal data up-to-date, so please advise us of any changes and feel free to exercise any of the above rights by contacting us at Support.

11.1 Should you be dissatisfied with the service we provide, you have the right to file a formal complaint to the Information Commissioner's Office at www.ico.org.uk, or to the relevant data protection supervisory authority in your country of residence. The ICO can be contacted at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. They can be contacted by telephone on 0303 123 1113 or 01625 545 745.

11.2 Contact details for Moneyhub’s EU Representative in the EU as required by Article 27 of the EU GDPR shall be made available upon request in writing.

12.1 You may be located in the European Union. This Privacy Policy applies to our provision of services within the EU, as well as our provision of services within the UK. For all personal data held by us in connection with End Users located in the European Union since 1 January 2021, (and for historical personal data sets processed by us up until 31 December 2020) we continue to apply and adhere to the GDPR. We also comply with the UK GDPR as it applies in the UK from 1 January 2021 as amended from time to time.

12.2 We may need to share information about you with certain service providers who help us to deliver the Service to you, such as with fino run GMBH, our European outsourced partner who provides AISP and PISP service delivery to our End Users located in the EU. For the time being and until we are formally authorised in Slovenia, fino will have a role in processing and storing your personal data in accordance with its privacy policy, found here:

13.1 Where possible we will use Open Banking to allow you to see your accounts and payment transactions in Moneyhub. Where a particular bank, financial institution or account is not enabled for Open Banking we may use another method via the non-exclusive use of certain aggregation partners. One such partner is Yodlee Inc who allow you to retrieve your financial/account data using their services. We work with Yodlee Inc as a Third Party Service Provider who are supervised by the US Banking Regulators (a body similar to the UK’s Financial Conduct Authority).

13.2 Yodlee Inc handle any personal data (which can exist as part of aggregated data or wider client data) in accordance with this privacy policy and its own privacy practices which we are required to point out to you, as part of our terms and conditions with Yodlee. We provide you with important information about Yodlee’s client privacy arrangements through a dedicated link, which is available here.

14.1 Another subset of personal data shared with Third Party Service Providers relates to identity data emanating from our Know-Your-Client and anti-money laundering obligations. On rare occasions we will need to check user identity and other personal details with a fraud prevention and credit reference agency. An example of when we will need to do this includes when using our payments capability for high value, high volume or unusual transactions or if you opt into our Rent Recognition Service to submit your rent data to a credit reference agency. If you give false or inaccurate information and we identify fraud, this will be recorded and may be shared by those agencies with other organisations. This is important:

a. to trace debtors, recover debt, prevent fraud, and to manage your accounts or insurance policies; and,

b. to prevent fraud and money laundering, for example, for payments services or where a bank or other third party, such as an Enterprise client requests these checks as part of their service.

14.2 Links to each agency’s relevant Credit Reference Agency Information Notice:

Transunion: www.transunion.co.uk/legal/privacy-centre

Equifax: www.equifax.co.uk/crain

Experian: www.experian.co.uk/crain

15.1 We provide a Rent Recognition feature (delivered in conjunction with Experian) which helps individuals by giving them intended credit-score benefits flowing from their regular property rental payments. End-User data can only be used to positively impact your credit score when rent is paid on time.

15.2 When you sign up to use the Experian Rental Exchange service (known as Rent Recognition on the Moneyhub app/service), you are expressly consenting to our use and process any personal data provided to deliver this particular service. The kind of personal data includes financial account categorisations for the rental information and tenancy details, and other identifiers such as your name, address, date of birth.

15.3 We will continue to exchange information about you with Experian while you have a relationship with us. Please note that we understand that Experian will record any outstanding debt. Experian will hold your rental data for the time limits explained in their CRAIN notice as explained above.

15.4 Further information about the Rent Recognition service is available here: https://www.experian.co.uk/assets/rental-exchange/rental-exchange-privacy-notice.pdf & here https://www.experian.co.uk/assets/rental-exchange/rental-exchange-data-protection.pdf