Privacy

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 support@updraft.com
• write to us at “Fairscore Ltd”, 5 Merchant Square, W2 1AY

We’re registered with the Information Commissioner’s Office under number ZA428986.

• 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)
• Data related to credit information which we receive from credit reference agencies (refer to Credit 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.
• Data from social networks or any online account that you share with us.
• Cookie information. Read our Cookie Policy for more info on what cookies are and how we use them.

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 subject to UK and EU data protection laws and is required to treat your data in accordance with those laws, as well as the Terms of Service and TrueLayer’s Privacy Policy.‌ 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: 901096)

When you register with us, you’re authorising us to ask credit reference agencies, such as TransUnion, for your credit data and authorising them to provide this to us, so we can show it to you securely. This includes information like your credit score, credit report and data related to them, such as credit providers, county court judgements and reasons for changes to your score or report. When we ask TransUnion for this data, it’s called a “limited subject access request” and is made under article 15 of the General Data Protection Regulation. TransUnion may also provide us with credit data when there are changes to your credit score or credit report.

“TransUnion” is TransUnion International UK Limited, a credit reference agency authorised and regulated by the Financial Conduct Authority (reference number 737740). Transunion is registered in England and Wales (company number 3961870). Registered office: One Park Lane, Leeds, West Yorkshire, LS3 1EP.

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.
• Market products and services generally in app but also through emails
• Search your record at credit reference agencies when you sign up and check eligibility for Updraft Credit (this is a ‘soft search’ and shouldn’t impact your credit score).
• 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).
• Analyse data to estimate impacts of changes to your credit history, or provide you with nudges and alerts.
• Meet our legal obligations.
• Meet our KYC (Know Your Customers) and AML(Anti Money Laundering) obligations.
• Make responsible lending decisions while offering you an Updraft term loan. In a majority of cases, 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.
• Prevent fraud by sharing your personal information with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found here.

We are authorised and Regulated by the Financial Conduct Authority. Reference no. 828910 and 810923

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.
• Fraud prevention agencies.

Information For Non UK Residents Only.

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.

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.

Data related to your credit report is deleted six months after you unsubscribe from the service within your account and information relating to your use of the services after 6 years. If we close your account because you’ve not used it in a long time, we may delete this information straight away.

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 dataofficer@updraft.com

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.

If you have a complaint, please contact us through the app or by emailing complaints@updraft.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/make-a-complaint/

For complaints related to the provision of account information services, please contact TrueLayer directly by emailing agents@truelayer.zendesk.com.

Should you wish to raise a complaint in relation to the service with your Bank please refer to their complaints policy.

We regularly review and, where necessary, update this policy. If we make any significant changes such as using your personal information in a new way, we’ll update the policy and let you know by email.