Privacy Policy

Privacy Notice

This Privacy Notice ("Notice") describes how Bud Financial Limited also referred to as (“Bud”, “we”, and “us”) will make use of your personal data, and is addressed to individuals with whom we interact, including our customers, visitors to our website, other users of our products or services and visitors to our premises (together, “you”). 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.

This Privacy Notice does not cover personal data that:

i)we collect through the Bud App. For more information on how Bud processes personal data through the Bud App, please see our Bud App Privacy Notice which is available here - https://thisisbud.com/mobile/legal/privacy-policy. 

(ii) is processed by Bud on behalf of third parties that provide services to you (each a “Bud Client”), where part of that service relies on Bud’s technology (for example, in relation to Bud’s account information services or payment initiation services). For more information on how Bud processes personal data on behalf of a Bud Client, please refer to the privacy notice provided to you by that Bud Client. 

Collection of Personal Data

We collect or obtain personal data:

• when those data are provided to us (e.g. where you contact us);
• in the course of our relationship with you (e.g. if you make a purchase);
• when you make personal data public (e.g. if you make a public post about us on social media);
• when you visit our website;
• when you register to use our website and/or any of our products or services; and/or
• when you interact with any third party content or advertising on our website.

We may also receive personal data about you from third parties (e.g. law enforcement authorities).

We collect or obtain personal data about you from the following sources:

• Data provided to us: We obtain personal data when those data are provided to us (e.g., where you contact us via email, telephone or by any other means, or when you provide us with your business card).
• Relationship data: We collect or obtain personal data in the ordinary course of our relationship with you (e.g., we provide a service to you or to your employer).
• Data you make public: We collect or obtain personal data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
• Website data: We collect or obtain personal data when you visit our website or use any features or resources available on or through our website.
• Registration details: We collect or obtain personal data when you use, or register to use, any of our website, products or services.
• Content and advertising information: If you interact with any third party content or advertising on our website (including third party plugins and cookies), we receive personal data from the relevant third party provider of that content or advertising.
• Third party information: We collect or obtain personal data from third parties who provide it to us (e.g., credit reference agencies, law enforcement authorities; etc.)
  
  

Categories of Personal Data We Process

We may process some or all of the following categories of personal data about you when you use our website:

• Personal details: given name(s), preferred name.
• Demographic information: date of birth / age, nationality, salutation, title, and language preferences.
• Contact details: address, telephone number and email address.
• Consent records: 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).
• Service details: records of services.
• Supplier payment details: invoice records; payment records; billing address; payment method, bank account number or credit card number, cardholder or account holder name, card or account security details, card ‘valid from’ date, card expiry date, BACS details; SWIFT details, IBAN details, payment amount, payment date, and records of cheques.
• Data automatically collected from our website: device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to our website; location data, and other technical communications information (some of which may constitute personal data e.g. username, event logs, aggregated statistical information). We may use cookies and other tracking technologies to capture this data. 
• Employer details: where you interact with us in your capacity as an employee of a third party, the name, address, telephone number and email address of your employer, to the extent relevant.
• Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on webpages displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.
• Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

Purposes of Processing & 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 fulfill a contract, or take steps linked to a contract including:

• To provide you with our website, products and services, including ancillary services such as customer support.
• To confirm and verify your identity.
• To bill for our services.
• To send you service, technical and other administrative emails relating to our services and other types of communications.

As required by Bud to conduct our business and pursue our legitimate interests, in particular:

• To ensure our website and services are 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 including our website, and services.
• For the purpose of ensuring the physical security of our premises, including records of visits to our premises, CCTV recordings and electronic security (including login details and access control information).
• For the purposes of maintaining health and safety assessments and record keeping, providing a safe and secure environment at our premises and compliance with related legal obligations.
• For the purposes of managing and operating the financial affairs of our business (including sales, finance, corporate order and vendor management).
• For the management and operation of our communications, IT and security systems including audits and monitoring of such systems.
• For the purposes of detecting, preventing and investigating fraud.
• For the purposes of detecting and investigating breaches of policy and criminal offences, in accordance with applicable law.
• For analytics and measurement to understand how the website and our services are used. For example, we analyse data about your use of the website 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 we access information from your device using cookies or equivalent technologies.
• On other occasions where we ask you for consent, we will use the personal data for the purpose which we explain at that time.

For purposes which are required by law:

• In response to requests by government, regulatory or law enforcement authorities conducting an investigation.

Disclosure of Personal Data to Third Parties

Bud may share your personal data in the following ways:

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, or, in the case of a non-EEA country, not subject to adequacy determined in another valid method under applicable data protection law, data is adequately protected by approved standard contractual clauses, 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.

Data Retention

We take every reasonable step to ensure that your personal data are only processed for the minimum period necessary for the purposes set out in this Notice.

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 personal data to meet a contractual or other legal requirement, or where we are using the personal 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.  In the UK, this is the Information Commissioner’s Office.

Cookies & Similar Technology

We process personal data by using Cookies and similar technologies. For more information, please see our Cookie Policy.

When you visit our webite, 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.

Direct Marketing

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.

Details of Controller

For the purposes of this Notice, the relevant Controller is: Bud Financial Limited - Ground Floor, 25b Vyner Street, London, England, E2 9DG.

Bud is registered with the Information Commissioner’s Office under registration number ZA198709. Bud's Data Protection Officer is contactable at the following address: Bud Data Protection Officer, Bud Financial Limited, Ground Floor, 25b Vyner Street, London, England, E2 9DG.

Bud is a private limited company registered in England & Wales (registration number 09651629), having its registered office at Ground Floor, 25b Vyner Street, London, England, E2 9DG and is regulated by the FCA under registration numbers 765768 and 793327.

For contact with Bud, please email: help@thisisbud.com.

For contact with the FCA, please follow this link: https://www.fca.org.uk/contact.