This 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 Site, 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 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/privacy.
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 Site;
- when you register to use our Site and/or any of our products or services; and/or
- when you interact with any third party content or advertising on our Site.
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).
- Site data: We collect or obtain Personal Data when you visit our Site or use any features or resources available on or through our Site.
- Registration details: We collect or obtain Personal Data when you use, or register to use, any of our Site, products or services.
- Content and advertising information: If you interact with any third party content or advertising on our Site (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 Site:
- 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 Site: device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to our Site; location data, and other technical communications information (some of which may constitute Personal Data e.g. username, event logs, aggregate statistical information).
- 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 fulfil a contract, or take steps linked to a contract including:
- To provide you with our Site, 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 Site 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 Site, 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 Site and our services are used. For example, we analyse data about your use of the Site 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:
Legal & Regulatory Authorities
With legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation.
With accountants, auditors, lawyers and other outside professional advisors to Bud, subject to binding professional and/or contractual obligations of confidentiality.
Third Party Service Providers
With third party service providers who support our business, who will process it on behalf of Bud for the purposes identified above. Such third parties may include providers of hosting services.
Law Enforcement Authorities
With law enforcement agencies or courts, to the extent necessary for the establishment, exercise or defence of legal rights.
Prevention of Crime
With relevant parties for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties.
Business or Share Sales
With any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our shares, business or assets (including in the event of a reorganisation, dissolution or liquidation).
Third Party Providers of Advertising, Plugins and Content
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, data is adequately protected by approved standard contractual clauses, an appropriate Privacy Shield certification 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.
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.
(a) we maintain an ongoing relationship with you (for example, for as long as you are using our products and/or services); or
(b) retention of your Personal Data is necessary in connection with the lawful purposes set out in this Notice, for which we have a valid legal basis.
2. In addition, Bud will retain the Personal Data for the duration of:
(a) any applicable limitation period under law (i.e., any period during which a person could bring a legal claim against us in connection with your Personal Data or to which your Personal Data is relevant), plus an additional two (2) month period following the end of such limitation period; and
(b) if any relevant legal claims are brought, Bud will continue to Process Personal Data for such additional period as is necessary in connection with that claim.
Once the periods at (1) and (2) above have passed, Bud will either (i) permanently delete or destroy the relevant Personal Data; or (ii) anonymise the relevant Personal Data.
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.
Cookies & Similar Technology
When you visit our Site, 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.
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: [email protected]
For contact with the FCA, please follow this link: https://www.fca.org.uk/contact.