- Who are we?
- What data do we store
- How do we use your data
- Who do we share your data with
- How long we keep your data
- Your rights
- Where we store your data
- How to make a complaint
- Changes to this policy
Who are we?
We are Fairscore Ltd (“we”, “our”, “us”) and operate under the name of Updraft.
We’re committed to protecting and respecting your privacy. If you have any questions about your personal information, you can
- chat with us through the Updraft app or our website
- email us at email@example.com
- write to us at Rocketspace “Fairscore Ltd”, Regents House 40-42 Islington high street, London N1 8EQ
We’re registered with the Information Commissioner’s Office under number ZA428986.
What data do we store
- Data about you - these are things like your name, email, address or any additional details you provide to us when you use our website or our mobile app.
- Data on your transactions and usage e.g. transaction data from your linked bank accounts, loans with us and any payments you make on those loans (refer to the Account Information Services section for additional details)
- Device data - e.g. phone settings, mobile network, IP address, operating system you use etc.
- Data you give us permission to access on your phone e.g. your location data, photos and data from your camera.
- Data from social networks or any online account that you share with us.
Account Information Services
We use a tool provided by TrueLayer Limited (www.truelayer.com) (“TrueLayer”) that allows you to send information on your payment accounts to us and other service providers.
In order to use our services, you will be asked to enter your payment account details with TrueLayer and agree to their Terms of Service. The Terms of Service set out the terms on which you agree to TrueLayer accessing information on your payment accounts for the purposes of transmitting that information to us.
TrueLayer is authorised by the UK Financial Conduct Authority under the Payment Services Regulations 2017 to provide account information services and payment initiation services (Firm Reference Number: 793171 )
How do we use your data
We use the data we collect to:
- Help us manage your account.
- Track, analyse and improve the services we give you and other customers.
- To exercise our legitimate interests. This when we use data for a reason which is in your and/or our interest, and which doesn’t involve overriding your privacy rights.
a) Market products and services generally in app but also through emails
b) Search your record at credit reference agencies when you sign up (this is a ‘soft search’ and shouldn’t impact your credit score).
c) Check your credit history if you apply for a credit product like an updraft loan (this is a ‘hard search’, it might impact your credit score and chances of getting credit elsewhere).
- To meet our legal obligations.
a) Meet our Know your customers (Know your customers) and AML obligations
b) Make responsible lending decisions while offering you Updraft line of credit or a term loan. We make our decisions automatically using technology. We’ll tell you in the app once we’ve made this decision. You can opt out or ask for a manual review by email or chat through the mobile app. We are authorised and Regulated by the Financial Conduct Authority. Reference no. 828910
Who do we share your data with
We may share your personal information with:
- Anyone who works for us when they need it to do their job.
- Any organisation which supports any of our services you use, when they need it to offer those services. That includes:
- Credit reference agencies (for information on how they use data please read the Credit Reference Agency Information Notice).
- Know Your Customer (KYC) and cyber security service providers.
- Analytical Providers (e.g. Google analytics and Heap analytics)
- Customer ‘interface’ providers (like the ones who manage our in-app chat service)
- Cloud platform provider (Google Cloud Platform, Amazon Web services)
- Companies that do advertising for us in accordance with your permissions.
- Anyone who you give us explicit permission to share it with.
We’ll also share it to comply with the law; to enforce our Terms and Conditions or other agreements; or to protect the rights, property or safety of us, our customers or others.
How long we keep your data
We keep your data as long as you’re using Updraft, and for 6 years after that to comply with the law. In some circumstances, like cases of anti-money laundering or fraud, we may keep data longer if we need to and/or the law says we have to.
You have a right to:
- Access the personal data we hold about you, or to get a copy of it.
- Make us correct inaccurate data.
- Ask us to delete, ‘block’ or suppress your data, though for legal reasons we might not always be able to do it.
- Object to us using your data for direct marketing and in certain circumstances ‘legitimate interests’, research and statistical reasons.
- Withdraw any consent you’ve previously given us.
To do so, please contact us through the app or by emailing firstname.lastname@example.org
Where we store your data
We might transfer and store the data we collect from you somewhere outside the European Economic Area (‘EEA’). People who work for us or our suppliers outside the EEA might also process your data. We may share data with organisations and countries that:
- The European Commission say have adequate data protection.
- We’ve agreed standard data protection clauses with.
How to make a complaint
If you have a complaint, please contact us through the app or by emailing email@example.com and we’ll do our best to fix the problem. You can also complain to the data protection regulator, the Information Commissioner’s Office, whose address is: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 0303 123 1113. You can find out how to report a concern on their website at: https://ico.org.uk/reportaconcern
For complaints related to the provision of account information services, please contact TrueLayer directly by emailing firstname.lastname@example.org.
Should you wish to raise a complaint in relation to the service with your Bank please refer to their complaints policy.
Changes to this policy
We’ll post any changes we make to our privacy notice on this page and, if they’re significant changes we’ll let you know by email.