This policy (“Privacy Policy) describes our collection, use, disclosure, retention, and protection of your personal information. Where you provide us with your personal information in any of the ways described in section 2 below, you agree that we may collect, store and use it: (a) in order to perform our contractual obligations to you; (b) based on our legitimate interests for processing (i.e. for internal administrative purposes, data analytics and bench-marking (see section 3 below for more information), direct marketing, maintaining automated back-up systems or for the detection or prevention of crime); or (c) based on your consent, which you may withdraw at any time, as described in this policy.

1. This Privacy Policy applies to all products, applications and services offered by Fibre Finance Corporate Ltd (a company incorporated in England with company registration number 14489901 whose registered office address is 20 Peterborough Road, Harrow, England, HA1 2BQ) and its affiliates, but excludes any products, applications, or services that have separate Privacy Policies which do not incorporate this Privacy Policy.

2. To the extent permissible under applicable law, we collect information about you and any other party whose details you provide to us when you:

register to use our websites, applications, or services; this may include your name (including business name), address, email address and telephone number. We may also ask you to provide additional information about your business and your preferences; place an order using our websites, applications or services; this may include your name (including business name), address, contact (including telephone number and email address) and payment details; complete online forms (including call back requests), take part in surveys, post on our message boards, post any blogs, enter any competitions or prize draws, download information such as white papers or other publications or participate in any other interactive areas that appear on our website or within our application or service; interact with us using social media; provide your contact details to us when registering to use or accessing any websites, applications or services we make available or when you update those details; and contact us offline, for example by telephone, fax, SMS, email or post. We will also collect your information where you only partially complete and/or abandon any information inputted into our website and/or other online forms and may use this information to contact you to remind you to complete any outstanding information and/or for marketing purposes.

We also collect information from your devices (including mobile devices) and applications you or your users use to access and use any of our websites, applications or services (for example, we may collect the device identification number and type, location information and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history and your web log information) and we will ask for your permission before we do so. We may do this using cookies or similar technologies (as described in section 11 below).

We may enhance personal information we collect from you with information we obtain from third parties that are entitled to share that information; for example, information from credit agencies, search information providers or public sources (e.g., for customer due diligence purposes), but in each case as permitted by applicable laws.

3. Providing us with information about others If you provide us with personal information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protection laws in relation to such disclosure. In so far as required by applicable data protection laws, you must ensure that you have provided the required notices and have obtained the individual’s explicit consent to provide us with the information and that you explain to them how we collect, use, disclose and retain their personal information or direct them to read our Privacy Policy.

4. How we use your information to the extent permissible under applicable law, we use your information to:

provide any information and services that you have requested or any applications or services that you have ordered; compare information for accuracy and to verify it with third parties; provide, maintain, protect and improve any applications, products, services and information that you have requested from us; manage and administer your use of applications, products and services you have asked us to provide; manage our relationship with you (for example, customer services and support activities); monitor, measure, improve and protect our content, website, applications and services and provide an enhanced, personal, user experience for you; undertake internal testing of our website, applications, systems and services to test and improve their security, provision and performance, in which case, we would pseudonymise any information used for such purposes, and ensure is it only displayed at aggregated levels which will not be linked back to you or any living individual; provide you with any information that we are required to send you to comply with our regulatory or legal obligations; detect, prevent, investigate or re-mediate, crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes); To the extent permitted by applicable law, we retain information about you after the closure of your account, if your application is declined or if you decide not to proceed. This information will be held and used for as long as permitted for legal, regulatory, fraud prevention and legitimate business purposes.

Our website, applications (including mobile applications) and services may contain technology that enables us to:

check specific information from your device or systems directly relevant to your use of the websites, applications or services against our records to make sure the websites, applications or services are being used in accordance with our end-user agreements and to troubleshoot any problems; obtain information relating to any technical errors or other issues with our website, applications and services; collect information about how you and users use the functions of the features of our website, applications and services; and gather statistical information about the operating system and environment from which you access our applications or services. You can manage your privacy settings within your browser or our applications and services (where applicable). In addition to the purposes described in this section 4, we may also use information we gather to deliver targeted
advertising, marketing (including in-product messaging) or information to you which may be useful, based on your use of the website, applications or services or any other information we have about you (depending on the websites, applications or services, you may able to configure these features to suit your preferences). Sections 6 and 7 of this Privacy Policy provides further details on how we will do this. We may monitor and record our communications with you, including e-mails and phone conversations. Information which we collect may then be used for training purposes, quality assurance, to record details about our website, applications, and services you order from us or ask us about, and in order to meet our legal and regulatory obligations generally.

5. We may use information generated and stored during your use of our services for our legitimate business interests to enable us to give you the best service and/or solutions and the best experience. These purposes include to:

deliver advertising, marketing (including in-product messaging) or information to you which may be useful to you, based on your use of services; carry out research and development to improve our services, products and applications; develop and provide new and existing functionality and services (including statistical analysis, bench-marking and forecasting services); and provide you with location-based services (for example location relevant content) where we collect geo-location data to provide a relevant experience. Whenever we use your information for our legitimate interests, we will ensure that your information is processed on a pseudonymous basis and displayed at aggregated levels, which will not be linked back to you or to any living individual. You have the right to object to processing based on our legitimate interests, and if you wish to do so, please contact us at info@fibrecorporate.com to discuss this further. If you object, this may affect our ability to provide certain services and/or solutions for your benefit.

6. We may share your information with:

A company we work with, for the purposes set out in this Privacy Policy, (e.g. global information and customer relationship management; software and service compatibility and improvements; and to provide you with any information, applications, products or services that you have requested); our service providers and agents (including their sub-contractors) or third parties which process information on our behalf (e.g. internet service and platform providers, payment processing providers and those organisations we engage to help us send communications to you) so that they may help us to provide you with the applications, products, services and information you have requested or which we believe is of interest to you; partners, including system implementers, re- sellers, value-added re-sellers, independent software vendors and developers that may help us to