Privacy Policy

1. Purpose of this Privacy Policy

vabble Ltd. (“vabble”) is the owner of vabble’s mobile device appcation (the “Appcation”) and the site www.vabble.io (the “Site”, and together with the Appcation, the “Platform”). vabble undertakes to maintain the confidentiaty and security of personal information provided by you, to which effect we have created these Privacy policy (“Privacy policy”) to tell you how we protect, collect, use, disclose and store the information collected through the Platform, and tell you about your privacy rights and how the law protects you.

This Privacy policy constitutes an integral part of the Terms and Conditions of the Platform. If you are a User of the Platform, you acknowledge that by registering as a User in the Platform you consent so that your Personal Data can be used in accordance with this Privacy policy.

The Platform is not intended for children and we do not knowingly collect data relating to children.

The data owners may contact us with questions related to data collection and processing at:

+ Name: vabble Ltd.

+ Address: 5 New Street Square, London, UK EC4A 3TW

+ Email: [_______________]

BY DOWNLOADING, ACCESSING, OR USING THE PLATFORM, AND/OR BY REGISTERING WITH US OR PROVIDING INFORMATION TO US IN CONNECTION WITH THE PLATFORM, YOU ACCEPT THE PRACTICES AND POCIES OUTNED IN THIS PRIVACY policy, AND YOU HEREBY CONSENT THAT WE WILL COLLECT, USE, AND SHARE YOUR INFORMATION AS SET FORTH IN THIS PRIVACY policy. IF YOU ARE REGISTERING AN ACCOUNT OR USING THE PLATFORM ON BEHALF OF AN INDIVIDUAL OR ENTITY OTHER THAN YOURSELF, YOU REPRESENT THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL OR ENTITY TO ACCEPT THIS PRIVACY policy ON SUCH INDIVIDUAL'S OR ENTITY'S BEHALF.

2. Data we collect about you

Personal data, or personal information, means any information about an individual or entity from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Data you give to us

This covers data given by you as well as data provided by people nked with you or your business, or people working on your behalf. This could include an employee, officer or company director.

• When you create an account on our Platform
• When you talk to us on the phone, including recorded calls and notes we make
• When you use our websites, mobile device apps or web chat services
• In emails and letters
• In insurance claims or other documents
• In financial reviews and interviews
• Data we collect when you use our services
• Payment and transaction data

This includes the amount, frequency, type, location, origin and recipients.

Profile and usage data

This includes the security details you create and use to connect to our services. It also includes your settings and marketing choices. We also gather data from the devices you use (such as computers and mobile phones) to connect to our internet and mobile services. We also use cookies and similar tracking technologies to collect data while you are using our websites or mobile apps and when you receive, open or respond to emails we send you. You can find out more about this in our Cookies policy.

Data from outside organizations

We may also obtain data from outside organizations such as insurers, fraud and AML (anti money laundering) prevention agencies, financial advisors, agents, etc. These can be types of firms we use to help us run our Platform.

Financial Data

We may collect specific Financial Data (this includes bank account information) from registered Users of the Platform which is necessary to perform our services.

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.

We do not collect any data related to race or ethnicity, regious or philosophical beefs, sex fe, sexual orientation, potical opinions, trade union membership, information about your health, and genetic and biometric data.

3. Failure to Provide Personal Data

We may need to collect personal information by law, or to enter into or fulfil a contract we have with you. 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, it may delay or prevent us from fulfilng our contract with you or prevent us from entering into a contract with you (for example, to provide you with our services).

In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

4. How we use your Personal Data

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:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• 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.
• Where we need to comply with a legal obgation.
• Tailoring products, services, offers and marketing
• Detecting fraud. If we think there is a risk of fraud, we may stop activity we may refuse to continue doing business with you.
• Approving a given transaction
• Your onboarding into the Platform

5. For how Long will you Use my Personal Data?

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 beeve there is a prospect of tigation in respect to our relationship with you.

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 appcable legal, regulatory, tax, accounting or other requirements.

6. Credit Reference Agencies (CRAs)

This section explains how we work with outside companies to decide whether to do business with you. It explains what we do and why we do it.

We carry out credit and identity checks when you apply for a product or services for you or your business. We may use Credit Reference Agencies to help us with this.

If you use our services, from time to time we may also search information that the CRAs have, to help us manage those accounts.

We will share your personal information with CRAs and they will give us information about you. The data we exchange can include:

• Name, address and date of birth
• Financial situation and history
• Fraud prevention information
• Pubc information sources

We’ll use this data to:

• Assess whether you or your business is in a good solvency status
• Make sure what you’ve told us is true and correct
• Help detect and prevent fraud
• Manage your relationship with us
• Trace and recover payments

We will go on sharing your personal information with CRAs for as long as you are a User. The CRAs may give this information to other organizations that want to check your financial status.

When we ask CRAs about you or your business, they will note it on your credit file. This is called a credit search. Other lenders may see this and we may see credit searches from other lenders.

You can find out more about the CRAs on their websites, in the Credit Reference Agency Information Notice. This includes details about:

• Who they are
• Their role as fraud prevention agencies
• The data they hold and how they use it
• How they share personal information
• How long they can keep data
• Your data protection rights.

Here are nks to the information notice for each of the three main Credit Reference Agencies:

TransUnion

Equifax

Experian

7. Transfers Outside the UK and EEA

We will only send your data outside of the UK and the European Economic Area (‘EEA’) to:

• Follow your instructions
• Comply with a legal duty. For example, we share information about US citizens with the US tax authority.
• Work with our suppers who help us to run vabble’s business and services.

If we do transfer your personal information outside the UK and EEA to our suppers, we will make sure that it is protected to the same extent as in the UK and EEA. We’ll use one of these safeguards:

• Transfer it to a non-UK or EEA country with privacy laws that give the same protection as the UK and EEA. Learn more on the European Commission Justice website.
• Put in place a contract with the recipient that means they must protect it to the same standards as the UK and EEA. Read more about this here on the European Commission Justice website.

8. Security of Your Personal Information

We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.

All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes sted above), who have access to, and are associated with the processing of personal information, are obged to respect the confidentiaty of the personal information of all users of the Site.

We seek to use reasonable physical, technical and administrative measures to protect Personal Data under our control. Unfortunately, no data transmission over the Internet or data storage system is 100% secure, and therefore we cannot guarantee against all potential security breaches.

You are responsible for taking all reasonable steps to ensure that no unauthorized person shall have access to the Platform, passwords or accounts. It is your sole responsibity to (1) control the dissemination and use of sign-in name, username, screen name and passwords; (2) authorize, monitor, and control access to and use of your vabble account and password; (3) promptly inform vabble if you beeve your account or password has been compromised or if there is any other reason you need to deactivate a password,

If you have reason to beeve that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at [_________________].

9. How to Access Your Information and Your Other Rights

You have the following rights in relation to the personal information we hold about you:

• Your right of access.

  If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

• Your right to rectification.

  If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to erasure.

  You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where appcable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly

• Your right to restrict processing.

  You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we ft any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to data portabity.

  You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.

• Your right to object.

  You can ask us to stop processing your personal information, and we will do so, if we’re:1. relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelng legal grounds for the processing; 2. processing your personal information for direct marketing; or 3. processing your personal information for research unless such processing is necessary for the performance of a task carried out in the pubc interest.

• Your rights in relation to automated decision-making and profing.

  You have the right not to be subject to a decision when it’s based on automatic processing, including profing, and it produces a legal effect or similarly significantly affects you unless such profing is necessary for entering into, or the performance of, a contract between you and us.

• Your right to withdraw consent.

  If we rely on your consent (or expcit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

• Your right to lodge a complaint with the supervisory authority.

  If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calng their helpne on 0303 123 1113.

10. Changes to this Privacy policy

We may make changes to this Privacy policy from time to time.

To ensure that you are always aware of how we use your personal information we will update this privacy policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in appcable law or regulatory requirements. We may notify you by e-mail of any significant changes. However, we encourage you to review this Privacy policy periodically to be informed of how we use your personal information.