INTRODUCTION

For the purpose of this privacy policy the defined terms set out in our Hoola Mobile App Terms of Use shall apply, and in particular: references to we, us, or our means Hoola Technology Limited, a limited company registered in England and Wales (Registered Number: 12584434), whose registered office is 128 City Road, London, EC1V 2NX, United Kingdom; and references to you or your means any prospective, current, or previous user of the App.

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in this policy and it is important that you read this information.

After installing the App you will be asked to indicate your consent to our processing of your personal data (including your name, contact details, financial and device information, and other types of information as noted in this policy) before you can use the Services. Please note that some Services or parts of the App may not work properly or be accessible to you if you do not provide us with this consent or later withdraw it.

HOW YOU CAN WITHDRAW CONSENT

Once you provide consent you may change your mind and withdraw consent at any time by contacting us at [email protected] but that will not affect the lawfulness of any processing carried out before you withdraw your consent. Please note that some Services or parts of the App may not work properly or be accessible to you if you do not provide us with this consent or later withdraw it.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This privacy policy was most recently updated on the date noted above. This policy may change and if it does, these changes will be posted on this part of the App and, where appropriate, notified to you by a method of our choosing and/or when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

THE DATA WE COLLECT ABOUT YOU

We may collect, use, store, and transfer the following different types of personal data about you:

Location data: Your current location as determined by GPS or other similar technology.
Identity and profile data: Your legal name, username or other identifier, password, title, data of birth, App use history, interests, preferences, feedback, and survey responses.
Contact data: Your mailing address, email address, and telephone number.
Marketing and communications data: Your preferences in receiving marketing from us and our Third Party Partners.
Usage data: Details of your use of the App.
Financial data: Your Accounts with Third Party Financial Institutions, including log on details used to access your Accounts, Account Information, and transaction data from your Accounts. This may include information about transactions which may be identifiable as being of a sensitive nature (e.g., payments to health care providers or trade unions, etc.).
Content data: Information and digital content stored on your Mobile Device which we may need access to in order to allow all features of the App and Services to work properly.
Transaction data: Information about your transaction, including transactions with Third Party Partners.
Data about your Mobile Device: Information about the Mobile Device the App is installed on, including device identification numbers.

We may 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 as this data is anonymised and will not directly or indirectly reveal your identity. 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 do not collect any 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), nor do we collect any information about criminal convictions and offences.

HOW WE COLLECT YOUR PERSONAL DATA

We collect your personal data by various methods, as follows:

Information you give us: This is information (including identity, contact, financial, and marketing and communications data) which you consent to giving us about you by filling in forms on the App, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download or install the App, receive any of the Services, share data via an App's social media functions, and when you report a problem with an App, our Services, or any of Third Party Partners. If you contact us, we will keep a record of that correspondence.
Information about your Mobile Device and location data.: Each time you use the App we will automatically collect personal data including content and usage data, and data about the Mobile Device used to access the App. We collect this data using cookies and other similar technology. We may also use GPS or other similar technology to determine the location of the Mobile Device being used to access the App. Some of our Services may be location-based and may require your personal data for certain features to work. Information we receive from other sources. We may receive personal data about you from public sources and various third parties including your Third Party Financial Institution and our Third Party Partners to which you have provided your personal data and/or consent to share that data.

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;
If we need to perform a contract we are about to enter or have entered with you;
Where it is necessary for our legitimate business interests (or that of a third party) and your interests and fundamental rights do not override those interests;
Where it is necessary in order to protect your interests;
Where we need to comply with a legal or regulatory obligation; or
it is in our legitimate interests.

We have set out our purposes for which we will use your personal data in the table below:

To install the App and register you as a new App user: Your consent:
Performance of a contract with you Necessary for our legitimate interests (in order to enable us to manage and carry out operations as a business)
To deliver and improve the App and Services offered through the App in accordance with our terms of use Our day-to-day management of the App and Services, to ensure that they work properly Subjecting some or all of your data to an automated means of processing, decisioning, or profiling: Your consent:
Performance of a contract with you Necessary for our legitimate interests (in order to enable us to manage and carry out operations as a business)
To manage our relationship with you including our use of your personal data, communicating with you, and notifying you of changes to the App or any Services: Your consent:
Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To communicate with your Third Party Financial Institutions and Third Party Partners: Your consent:
To communicate with your Third Party Financial Institutions and Third Party Partners Your consent Necessary for our legitimate interests (in order to enable us to manage and carry out operations as a business)
To enable you to participate in an the completion of surveys or other similar activities: Your consent:
Performance of a contract with you Necessary for our legitimate interests (to analyse how users use the App and Services and to develop them and grow our business)
To administer and protect our business and this App including troubleshooting, monitoring usage, audits, data analysis, and system testing: Your consent:
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, and for ensuring that our resources are used for the purpose for which they are provided to App users and not for unlawful purposes or purposes which do not meet our standards and policies)
To deliver content to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the App Where content and services we offer through the App need to be tailored for you In order to allow our Third Party Partners to make certain Services or products available to you For marketing purposes, if you have given us permission to contact you for that purpose To allow us to gain an understanding of how you use your Accounts, and to share that information on an individual-level basis with your Third Party Financial Institution, or to share that information anonymously and/or in the aggregate with other Third Party Financial Institutions, Third Party Partners, or any other third party In monitoring trends in product offerings made by Third Party Financial Institutions and Third Party Partners: Your consent:
Necessary for our legitimate interests (to develop our products/Services and grow our business)

In the event that you do not use the App or any Services for a period of time chosen at our sole discretion, we may consider your account to be dormant or expired and your personal data may be deleted in the normal course of our business. If this happens and you wish to use the App or Services again you may be asked to provide your personal data and/or consent again.

THIRD PARTY PRIVACY POLICIES

In the course of using the App some of your personal information may be shared with Third Party Partners or Third Party Financial Institutions. We do not control these Third Party Partners and Third Party Financial Institutions, and your use of any part of the Service or App in relation to those Third Party Partners and Third Party Financial Institutions may be subject to separate terms, conditions, and privacy policies. Personal information which you provide directly to Third Party Partners and Third Party Financial Institutions is not covered by our privacy policy.

Third Party Partners and Third Party Financial Institutions may process your personal data outside of the country of the origin of that data.

DISCLOSURES OF YOUR PERSONAL DATA

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with third parties for the purposes noted above in Section 6 of this privacy policy.

We may share your personal data with:

Third Party Financial Institutions.
Third Party Partners.
Third party businesses which we may seek to merge with or acquire.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If this happens the new owners may use your personal data in the same way as set out in this privacy policy.

DATA TRANSFERS AND SECURITY

We may process your personal information both within and outside of the UK and the European Economic Area (EEA). When we transfer your personal information outside of the EEA, we will take reasonable steps to ensure that such information will be adequately protected, by implementing at least one of the following safeguards:

Only transferring your personal data to countries which have been deemed to provide an adequate level of protection for personal data by the European Commission; and/or Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; and/or Where we use service providers based in the US, we may transfer personal data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. If you want further information on the specific mechanism used by us when transferring your personal data out of the EEA please contact us using the details provided in Section 12, below. Your personal data will be encrypted when in our possession and during transmission to any third parties. We use strict procedures and security features to try to prevent your personal data from being accidentally lost, used, or access in an unauthorised way. If any parts of the App or Services include social networking or chat features, and you elect to use those features, you must ensure that you do not submit any personal data which you do not want to be seen, collected, or used by other App users. We have put in place procedures to deal with suspected data breaches and should such a breach occur we will notify you and any applicable regulator when we are legally required to do so.

The App may store your personal data on your Mobile Device, and access it when required. If we share anonymised transaction data with third parties we will take additional steps to protect your privacy by imposing contractual restrictions on them and requiring them to do the same for any parties they disclose it to.

DATA RETENTION

We will retain your personal information for no longer than we believe it is necessary to do so for the purposes of which that personal information is being used, subject to any other legal obligations with which we must comply.

The length of time we hold on to your personal information may vary according to what that information is and the reason we are using it. For further information about how long we may retain certain pieces of your personal information please contact us using the details provided in Section 12, below.

We may have to retain some of your personal information (such as contact, identity, financial, and transaction data) for legal or tax purposes for at least six (6) years, or for any other period required by law.

Your personal data may be deleted, overwritten, or otherwise made to be inaccessible without notice to you after a certain period of time in accordance with our standard data management and retention procedures.

In the circumstances where your personal data has been anonymised so that it can no longer be associated with you, we may use this information indefinitely without further notice to you.

YOUR RIGHTS

You have certain rights with respect to your personal information. The rights will only apply in certain circumstances and are subject to certain exemptions. Please see the table below for a summary of your rights.

Right of access to your personal data: You have the right to receive a copy of your personal data that we hold about you and information about how we use it, subject to certain exemptions.
Right to rectify your personal data: You have the right to ask us to correct your personal data that we hold where it is incorrect or incomplete.
Right to erasure of your personal data: You have the right to ask that your personal data be deleted in certain circumstances. For example: where your personal data is no longer necessary in relation to the purposes for which it was collected or otherwise used; if you withdraw your consent and there is no other legal ground for which we rely on for the continued use of your personal data; if you object to the use of your personal data (as set out below); if we have used your personal data unlawfully; or if your personal data needs to be erased to comply with a legal obligation.
Right to restrict the use of your personal data: You have the right to suspend our use of your personal data in certain circumstances. For example: where you think your personal data is inaccurate but only for so long as is required for us to verify the accuracy of your personal data; the use of your personal data is unlawful and you oppose the erasure of your personal data and request that it is suspended instead; we no longer need your personal data, but your personal data is required by you for the establishment, exercise or defence of legal claims; or you have objected to the use of your personal data and we are verifying whether our grounds for the use of your personal data override your objection.
Right to data portability: You have the right to obtain your personal data in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible. The right only applies: to personal data you provide to us; where we rely on the following legal bases: consent; or for the performance of a contract; and when the use of your personal data is carried out by automated (i.e., electronic) means.
Right to object to the use of your personal data: You have the right to object to the use of your personal data in certain circumstances and subject to certain exemptions. For example: where you have grounds relating to your particular situation and we use your personal data for our legitimate interests (or those of a third party); and if you object to the use of your personal data for direct marketing purposes.
Right to withdraw consent: You have the right to withdraw your consent at any time where we rely on consent to use your personal data.
Right to complain to the relevant data protection authority: If you think that we have processed your personal data in a manner that is not in accordance with data protection law, you can make a complaint to the data protection regulator. In the UK this is the Data Commissioner's Office (ICO) and they can be contacted on +44 (0)3031231113 or please see www.ico.org.uk.

FOR MORE INFORMATION

We have appointed a Data Privacy Manager. If you have questions about this privacy policy please contact us at [email protected] or by writing to:

Hoola Technology Limited

128 City Road

London

EC1V 2NX

United Kingdom

Attention: Mark Tabrett, Data Privacy Manager

Privacy Policy