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Armalytix Privacy Policy

1. Important Information and who we are

1.1. This document is the Privacy Policy for Armalytix Ltd (“Armalytix”, "we", "us", "our"), which is a company registered In England with company number 11828727 and a registered address at The Record Hall, 16-16A Baldwin's Gardens, London EC1N 7RJ. Armalytix is registered with the Information Commissioner's Office with registration number ZA521224.

1.2. Armalytix is also registered with the UK's Financial Conduct Authority ("FCA") as an Account Information Service Provider ("AISP") and enables users of its service, such as you, to obtain consolidated reports ("Reports") of their financial accounts held at different financial Institutions and to share them with providers of services they are seeking to use.

Purpose of this Privacy Policy

1.3. Armalytix is committed to protecting and respecting your privacy and this Privacy Policy, together with any terms and conditions you enter into with us, sets out the purpose and legal basis on which we collect, process, store and share your personal data (meaning any information which may be used to identify you) in accordance with data protection laws. Please read this Privacy Policy carefully so that you are fully aware of how and why we are using your personal data as well as your rights in relation to your personal data.

1.4. If you have any questions about this Privacy Policy or wish to exercise any of your rights In relation to your personal data please contact us using the details In the Contact Us section.

Third-Party Links

1.5. Our website, and some of the services we provide, 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, we encourage you to read the privacy policy of every website you visit.

2. How we may collect your personal data

2.1. We may collect your personal data in the following ways:

(a) Direct Interactions with you. You may give us your personal data by answering questions, filling in forms, uploading documentation or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: enter into an agreement with use; register to use our services; create an account on our website; use our services to obtain financial information by providing us your account details; and communicate with us (including by email and our live chat service).

(b) Automated technologies and/or Interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy below for further details.

(c) Third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

(i) your name and contact details from Trusted Third-Party Advisors (“TAs”) that have asked us to help you to prepare and share a financial information report (a “Report”) with them to assist them with the services they provide to you. TAs may be professional advisors such lawyers or accountants or any other entity that may legitimately request financial information about you in connection with products or services you may obtain, or are considering obtaining, from them;

(ii) Financial Data from banks and other payment services providers with whom you hold accounts;

(iii) Technical Data from:

(A) analytics providers such as Google based outside the UK;

(B) advertisers; and

(C) search information providers;

(iv) Identity and Contact Data from third parties (such as brokers, aggregators and credit reference agencies) and publicly available sources such as Companies House and the Electoral Register based inside the UK.

3. Information we may collect

3.1. 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).

3.2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

(a) Registration Data. When you register to our services you may provide us with your name and email address.

(b) Contact Data. We collect this data from Third Party Advisors and you and it includes your name, email address, contact telephone number and such other contact information as you or they may provide to us.

(c) Financial Data. When you request us to retrieve information about your accounts we will collect the information that you and the financial Institutions provide to us including bank and payment account details (including sort codes, account numbers and other unique identifiers), transaction history, balance information, details of regular payments (such as Direct Debits and standing orders), details of payment cards and other payment Instruments issued to you. We will also collect answers to questions and documents and images you upload when using our services.

(d) Technical Data. When you visit our website and use our service we will automatically collection technical information including, but not limited to details about the device you used to access our website and use the services, the 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 the website.

(e) Usage Data. When you use our services, including our website, we will collect information about how you use our services.

(f) Marketing and Communications Data. Includes your preferences in receiving marketing from us and our third parties and your communication preferences.

3.3. 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 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.

3.4. 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.

If you fail to provide personal data

3.5. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you and you may not be able to obtain Services from the TA who referred you to us.

4. How we use your information

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

(a) Where we need to perform the contract we are about to enter into or have entered into with you.

(b) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

(c) To comply with legal and regulatory requirements that apply to us.

4.2. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

4.3. We have set out the ways In which we use your personal data and the legal bases we rely on to do so in the table below.

Table showing the purposes for which we will use your personal data:

MARKETING

4.4. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US

4.5. We may use your Registration Data, Contact Data, Financial Data, Technical Data, Usage Data and Marketing and Communications Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

4.6. You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

4.7. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT

4.8. You can ask us or third parties to stop sending you marketing messages at any time by:

(a) following the opt-out links on any marketing message sent to you; or

(b) contacting us at any time.

4.11. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your use of our services.

CHANGE OF PURPOSE

4.12. 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.

4.13. 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.

4.14. 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 data

5.1. We may share your personal data with:

(a) Third Party Advisors that you ask us to share Reports with;

(b) Third parties that help us to provide services to you including without limitation any data processor (as defined in Data Protection Law) we engage for the purposes of providing data storage, Open Banking connectivity and transaction categorisation services;

(c) Third parties that resell our services;

(d) Third parties that we use to help verify your identity for the purposes of fraud protection and credit risk reduction;

(e) Our regulators such as the Financial Conduct Authority or Information Commissioner's Office;

(f) Governmental departments Including HM Revenue & Customers, tax authorities, law enforcement agencies and the courts if under a legal duty to disclose Information;

(g) Analytics and search engine providers that assist us in the improvement and optimisation of our site;

(h) People who provide professional advice to us including without limitation lawyers, accountants, auditors, Insurers and bankers;

(i) Prospective and actual buyers of our business if we decide to sell or merge our business.

5.2. We require all third parties we have agreements in place with 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. Storing and transferring your personal data

6.1. Some of our external third parties are based in the EEA so their processing of your personal data will involve a transfer of data outside the UK.

6.2. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

(a) We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or

(b) Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

6.3. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data Security

7.1. 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.

7.2. 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.

7.3. All information you provide to us is stored on our secure servers. Any banking data transfers will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. You must not share a password with anyone.

7.4. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site: any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try and prevent unauthorised access.

8. How Long Do We Keep Your Personal Data?

8.1. 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.

8.2. 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.

8.3. As an FCA regulated firm we are obliged to retain information, including personal data, about the financial services we have provided to you for up to six years after you stop using our services.

8.4. In some circumstances you can ask us to delete your data: see your Rights Under Data Protection Law below for further information.

8.5. 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 Rights Under Data Protection Law

9.1. We will not, without your consent, provide your information to third parties so that such third parties can market their goods or services direct to you.

9.2. Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

10. Your rights under Data Protection Law

10.1. Under Data Protection Law you have the right to:

(a) Be informed about how we use personal data. This Privacy Policy, together with any agreement you enter into with us, explains who we are and information about how we collect and process your personal data.

(b) 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.

(c) 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.

(d) Request erasure of your 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.

(e) 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.

(f) 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.

(g) Request the transfer of your personal data to you or to a third party (also referred to as data portability). 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.

(h) 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.

NO FEE USUALLY REQUIRED

10.2. 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

10.3. 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

10.4. 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.

11. Contacting Us and Complaints

11.1. Please contact our privacy officer Richard McCall at [email protected] for more information about your rights under Data Protection Law, or if you have a question or complaint about data protection at Armalytix.

11.2. You have the right to make a complaint to the Information Commissioner’s Office (“ICO”) at any in relation to our compliance with Data Protection Law. You can contact the ICO using the details below:

(a) Website: www.ico.org.uk:

(b) Postal Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

(c) Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)

11.3. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

12. Cookies Policy

12.1. As is common practice with professional websites, our websites use cookies and other similar technologies to improve your experience and to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. Cookies are pieces of information that a website transfers to your computer’s hard disk for record-keeping purposes. Cookies can make the internet more useful by storing information about your preferences on a particular site, such as your personal preference pages.  The use of cookies is an industry standard, and most websites use them to provide useful features for their customers. Cookies in and of themselves do not personally identify users, although they do identify a user’s computer. This section describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or 'break' certain elements of the sites’ functionality.

How We Use Cookies

12.2. We use cookies for a variety of reasons detailed below. Unfortunately in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

Disabling Cookies

12.3. You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the site. Therefore it is recommended that you do not disable cookies.

The Cookies We Set

12.4. Account related cookies

(a) If you create an account with us then we will use cookies for the management of the signup process and general administration. These cookies will usually be deleted when you log out however in some cases they may remain afterwards to remember your site preferences when logged out.

12.5. Login related cookies

(a) We use cookies when you are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in. Without these cookies, it is highly unlikely that our Service will function correctly.

12.6. Forms and Live Chat related cookies

(a) When you submit data to us through a form such as those found on contact pages or our live chat form, cookies may be set to remember your user details for future correspondence and to ensure a continuous experience as you move through our site.

12.7. Third Party Cookies

(a) In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.

(b) Our sites use Google Analytics which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page.

(c) If you use our live chat service, our service provider Chatlio uses cookies to provide a consistent experience across all the pages in our sites. For more information on Chatlio cookies, see the information available on their website at https://chatlio.com/legal/privacy-policy/.

13. Changes to our Privacy Policy

13.1. Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy.

Privacy Policy last updated 20 December 2021.

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