Prograd Privacy Policy

Controller

Prograd Limited is the controller and responsible for your personal data (collectively referred to as "Prograd", "Company", "we", "us" or "our" in this Privacy Policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights as a data subject, please contact our data privacy manager using the details set out below.

Contact details

If you have any questions about this Privacy Policy or our privacy practices, please contact our data privacy manager in the following ways:

• Full name of legal entity: Prograd Limited
• Email address: ethan@prograd.app
• Postal address (trading address):
  WeWork 2 Minster Court London EC3R 7BB (attention of Prograd Limited)

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk) or any other competent data protection authority in the relevant jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or the other relevant authority so please contact us in the first instance.

Changes to this Privacy Policy

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

The Services 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 Services, we encourage you to read the privacy policy of every website you visit.

What information do we collect about you?

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).

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

• Identity Data includes first name, last name or similar identifier, title, and date of birth.
• Contact Data includes billing address, residential address, email address and telephone numbers.
• Additional Personal Data includes supplementary information we may ask you when registering an account with us or depending on the Services you access such as your product preferences, whether you are a student, your education history, your employment status, your occupation, your salary, your monthly rent or mortgage, your age, and your marital status.
• Financial Data includes information about your bank account and any other connected accounts.
• Transaction Data includes details about transactions and balances from connected accounts.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, operating system and platform.
• Profile Data includes your username and password, community username, purchases or orders made by you through partner websites, your interests, preferences, feedback and survey responses.
• Partner Services Data includes information that we share with our partners relating to a product you have applied for or purchased through their website via our Services, including for the purposes of running soft credit checks when you apply for a credit card or a loan.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share anonymised and aggregated data such as statistical or demographic data for any purpose, including to third-parties (and we may be paid for this). Aggregated and anonymised 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. No aggregated data that is combined with your personal data will be shared with third parties without your consent. Please see To Whom We Disclose Information below.

We do not collect any special categories of personal data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic or biometric data, nor do we collect any information about criminal convictions and offences. However to the extent that you use Prograd's Open Banking feature, we may process special categories of personal data when processing your Transaction Data, i.e. banking transactions. For instance, if you have made a payment to a political party or trade union this may reveal your political beliefs. Any special categories of data that you make available to us will be processed in accordance with the law and strictly as part of our provision of Services to you, and your consent to connect to Open Banking can be withdrawn at any time.

How your personal data is collected

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • create an account on our website;
  • request marketing materials to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website [whether you register an account with us or not], we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy Cookie Policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties from time to time including:
  • Technical Data from the following parties:
    • analytics providers such as Google;
    • advertising networks such as Quint Group; and
    • search information providers.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services and credit reference agencies such as Monevo; and
  • Contact Data from publicly available sources.

Our Services and 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 obligation; or
• where you have given us consent to process your data, for example 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.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We would like to send you regular information about our product and service updates. You have a right at any time to stop us from contacting you for marketing purposes.

You will receive marketing communications from us if you have requested information from us, signed up to receive updates from us, or accessed our Services and you have not opted out of receiving that marketing. We may also use your information to provide you with details about products and services from our partners such as Quint Group (Monevo) and Sendgrid. We may send you marketing messages by post, email, telephone, text, secure messages, or through social media. You can change your mind on how you receive marketing messages or choose to stop receiving them at any time.

We will get your express opt-in consent in the event we share your personal data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, accessing our website settings or by contacting us at any time by emailing ethan@prograd.app.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase, product experience or other transactions. We will also continue to use your contact details to provide you with important information, such as changes to our terms and conditions or if we need to tell you something to comply with our regulatory or legal obligations.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy Cookie Policy.

Change of Purpose

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.

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.

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.

To Whom We Disclose Information

Except as described in this Privacy Policy, we will not intentionally disclose your personal data to third parties without your consent or any other appropriate lawful basis. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

• HM Revenue & Customs, Regulatory Bodies, and other authorities (e.g. Financial Conduct Authority). We may be required from time to time to disclose information to third-party regulatory bodies and other authorities to ensure compliance with any reporting or regulatory obligations.
• Fraud prevention and Law Enforcement Agencies. We may be required from time to time to disclose information to law enforcement bodies to ensure compliance with any law enforcement requirements.
• Credit Consumer Compliance Limited (our Principal): We may be required to from time to time to disclose information to our Principal solely for the purpose of complying with legal obligations, such as our data protection obligations or for the purposes of regulatory compliance.
• Credit Reference Agencies. If you apply for credit products through one of our partners, then we may be required from time to time to perform necessary identity and credit checks for our legitimate interests.
• CircleCo, Inc. We use CricleCo, Inc. to host our community page. If you sign up to use the ProPeople Community, your personal data (Contact and Identity Data) may be shared with them for the purpose of delivering the community service to you.
• Other Community Users: Any content you choose to post or display on the ProPeople Community will be shared with other users of the platform. If another user makes a complaint to us by claiming that the content you have posted infringes their rights in any way, including their privacy rights, then we may disclose your information with that user to ensure compliance with our legal obligations.
• Service Providers. We work with third party service providers who provide email hosting, core corporate applications, web hosting, maintenance, and other services for us. These third parties may have access to, or process personal data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality and provide equivalent protections to such information. This list may be amended from time to time.
  Service providers include:
  • Amazon Web Services, Inc.
  • TrueLayer
  • Freshpaint
  • Mixpanel
  • Stitch (stitchdata.com)
  • dbt (getdbt.com)
  • Metabase
  • Google Cloud
• Change of Control or Restructure. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We may also disclose and use anonymised, aggregated data about users of our Services for the purpose of reporting to third parties for industry analysis (and we might be paid for this), and for our marketing and promotion purposes. This will be in the form of reports or statistics, none of which will enable our users to be personally identified and shall remain anonymised and aggregated.

We will never share, sell or rent any of your personal data to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal data in a particular way, but later change your mind, you should contact us and we will stop doing so.

Transfers outside the UK and/or EEA

The information you provide may be transferred to countries outside the United Kingdom ("UK") or European Economic Area ("EEA") that do not have similar protections in place regarding your data and restrictions on its use as set out in this policy. However, we will take steps to ensure adequate protections are in place to ensure the security of your information. By submitting your information, you consent to these transfers for the purposes specified above.

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

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK's Information Commissioner's Office or the European Commission.
• Where we use certain service providers, we may use specific contracts approved for use in the UK or EEA (including the EU Standard Contractual Clauses ("SCCs"), the UK International Data Transfer Agreement ("IDTA&qout;) and/or the UK Addendum to the SCCs as amended from time to time) which give personal data the same protection it has in the UK or EEA.

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

Law Enforcement, Legal Process and Compliance

We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

Change of Ownership

Information about data subject, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the personal data commits to a privacy policy that has terms substantially consistent with this Privacy Policy.‍

Data Retention

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.

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.

In some circumstances you can ask us to delete your data: see your rights below for further information.

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.

Our Data Security

Prograd is ISO72001 certified. In accordance with our certification, data security is important to us and 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.

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.

Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data as set out below. If you wish to exercise any of the rights set out below, please contact us.

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request&qout;). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• 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.
• 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.
• 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.
• 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:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful, but you do not want us to erase it.
  • 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.
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. 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.
• 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

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

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

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.