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# Privacy Policy

StrideUp is the trading name of StrideUp Homes Limited (registered company number 10848518). We at StrideUp are the ‘data controller’ and we’re responsible for deciding how we use your personal data and information. StrideUp is registered with the ICO, and our registration number is ZA337545.

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Your personal data is data which by itself or with other data available to us can be used to identify you. It applies to all our products and services, and any instances where we collect your personal data.

Where there are two or more people named, this privacy policy applies to each person separately. If you are applying on behalf of a Limited Company, this policy applies to the personal data of the company’s directors, beneficial owners, shareholders, and authorised representatives.

Please read the following carefully and if you have any questions, please contact us using the contact details provided below.

### 1. Types of personal data we collect from you and its use

Whether or not you become a customer with us, we will use your personal data for the reasons set out below and if you become a customer we will use it to manage the product or service you’ve applied for. We will collect most of the information directly through the application process, but some may be collected indirectly as mentioned below.

The personal data we may use may include:

- Full name and personal details including contact information (address history including current address, email address and home and mobile telephone numbers);
- Date of birth and/or age (for product eligibility purposes);
- Financial details (different forms of income and details of accounts with other providers);
- Information from Credit reference and fraud prevention agencies, electoral roll, court records of debt judgements and bankruptcies and other publicly available sources as well as information on any financial associates that you may have;
- Family, lifestyle and social circumstances relevant to the product and services;
- Education and employment details and status (where appropriate);
- Personal data about other named applicants or giftors. You must have their authority to provide their personal data and share this privacy policy with them beforehand together with details of what you’ve agreed on their behalf;
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number. We use this information to analyse trends, to administer our site, to track user’s movement around our site and to gather demographic information about our customer base as a whole.

### 2. Providing your personal data

We will monitor and record all forms of communications in your dealings with us subject to applicable laws. We do this for:

- Regulatory and business compliance
- Crime prevention and detection
- Protection of the security measures around communication systems and procedures
- Checking for obscene and profane content
- Quality control and staff training
- Statement verification

We may also monitor activities on your account, including your current and future conduct,
where necessary for the above reasons

### 3. Monitoring of communications and activities

Access to our site and services is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide without notice. We will not be liable if for any reason our site or services are unavailable at any time or for any period.

From time to time, we may restrict access to some parts, or all of our sites or services, to users who have registered with us.

### 4. The legal basis and purposes using your personal data

- Contract: We will process your personal data as needed to perform our contract with you for the relevant product and service. This is in order to take steps at your request before entering into it, decide whether to enter into it, manage and perform that contract, update our records and contact you about your account and recovering debt.
- Legitimate interests: We will process your personal data as needed for our own legitimate business interests or those of other persons and organisations. For example, to ensure that content from our site is presented in the most effective manner for you, search at credit reference agencies if you’re above 18, monitoring all forms of communications in our dealings with you and activities in your account, market research and analysis and send marketing communications.
- Legal Obligations: We will process your personal data as needed to comply with legal obligations. This could be for compliance with legal and regulatory requirements and related disclosures, when you exercise your rights under data protection law and make requests, establishment and defence of legal rights, activities in relation to prevention, detention and investigation of crime, to verify ID and perform credit, fraud and anti-money laundering checks and monitoring all forms of communications in our dealings with you and activities in your account.
- Consent: We will process your personal data based on your consent when you request us to disclose your personal data to other people or organisations such as not-for-profit organisations assisting with debt on your behalf or otherwise agree to disclosures. This could also be when we process any special categories of personal data about you at your request and to send you marketing communications where we have asked for our consent to do so. Please note, you’re free to change your mind anytime and withdraw your consent.

### 5. Sharing your personal data

Subject to applicable data protection law, we will share your personal data with third parties only in the ways that are described in this privacy policy. We do not sell your personal data to third parties.

#### Sources of Personal Data (Where we collect it from):

We will collect personal information directly from you, as well as from the following sources:

- Your use of our services: Information generated about you when you use our products and services.
- Connected individuals: Family members, associates, beneficiaries, or joint applicants.
- Intermediaries: Brokers or other intermediaries (such as Independent Financial Advisers) who work with us to provide products or services to you.
- Business partners: Financial services institutions, insurers, or others who help provide your products and services or operate our business.
- Agencies and other lenders: Credit Reference Agencies (CRAs), Fraud Prevention Agencies (FPAs), debt recovery and/or tracing agents, and other lenders.
- Government and law enforcement: HMRC, the Department for Work and Pensions (DWP), police, law enforcement agencies, and other organisations assisting in the prevention and detection of crime.
- Publicly available sources: Directories, social media, the internet, and news articles.

#### Sharing Your Personal Data (Who we share it with):

We may share your personal data with the following parties:

- Our group companies: Any member of our group of companies, which means our subsidiaries and associated companies where we have shareholdings.
- Service providers: Business partners, suppliers, subcontractors, and other companies providing services to us for the performance of any contract we enter into with them or you.
- Joint applicants: Other parties connected to your account. Where there are joint applicants, we may share data with the other parties to enable them to consent to the accuracy of the data submitted on their behalf.
- Agencies: Credit Reference Agencies, Fraud Prevention Agencies, and debt collection agencies, both at the time of you entering into an agreement with us and periodically thereafter.
- Advisors: Our legal and other professional advisors.
- Analytics providers: Market analytics and search engine providers that assist us in the improvement and optimisation of our products and services.
- Legal and regulatory bodies: If we are under a duty to disclose or share your personal data to comply with any legal and regulatory obligation; to enforce or apply our agreements; or to protect the rights, property, or safety of StrideUp, our customers, or others.
- Business transfers: Prospective buyers or sellers in the event that we sell or buy any business or assets. If StrideUp, or substantially all of its assets, are acquired by a third party, the personal data held about our customers will be one of the transferred assets.
- Protection and emergencies: In an emergency to protect your vital interests, or to protect the security and integrity of our business operations.

### 6. How we store, process and secure your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom (“UK”) or the European Economic Area (“EEA”). It may also be processed by staff operating outside the UK or EEA who work for us or for one of our suppliers. 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 appropriate legal safeguards are in place. All information you provide to us is stored on our secure servers.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once we receive it. Unfortunately, the transmission of information via the internet or methods of electronic storage is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee its absolute security. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. In the event of a material personal data breach, we will only notify you if we believe that your rights and freedoms may be at high risk, as required by law.

### 7. Data retention policy

We will keep your personal data for as long as you have a relationship with us. After it ends we will keep it where it may be needed for our legitimate purposes e.g. to help us respond to queries or complaints, or for other reasons such as fighting fraud and financial crime, and responding to requests from regulators.

### 8. Your rights

You have a number of rights relating to your information e.g. to see what we hold, to ask us to share it with another party, ask us to update incorrect or incomplete details, to object to or restrict processing of it, to make a complaint etc. More specifically, your rights are as follows:

- The right to be informed about our processing of your personal data.
- The right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed.
- The right to object to processing of your personal data.
- The right to restrict processing of your personal data.
- The right to have your personal data erased (the “right to be forgotten”).
- The right to request access to your personal data and information about how we process it.
- The right to move, copy or transfer your personal data (the “data portability”).

You can correct, change or delete your information in your member account setting page or by writing to us at hello@strideup.co.

You can stop receiving our newsletters or marketing emails by following the unsubscribe instructions included in these emails or accessing the email preferences in your account settings page. Alternatively, or to access any of the other above rights, you can email us at hello@strideup.co or by contacting us by telephone or postal mail at the contact information listed below.

You also have the right to complain to the Information Commissioners Office (www.ico.org.uk), the UK independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals.

If you believe we have not handled your personal data appropriately, you have the right to complain to us. Details of how to do this, and what to expect, are set out in our Complaints & Feedback page. You also have the right to complain directly to the Information Commissioner’s Office (https://ico.org.uk/make-a-complaint/), the UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals.

### 9. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

### 10. Credit reference checks

In order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies. This entails passing your personal data to the credit reference agencies and they will give us credit and ID information about you. When we carry out a search at the credit reference agencies, they will place a footprint on your credit file. A credit search may either be:

- a quotation search where a soft footprint is left, and this has no impact on your credit score and furthermore, lenders are unable to see this; or
- a hard footprint where you have agreed/requested us to proceed with your application. This footprint will be viewable by other lenders and may affect your ability to get credit elsewhere.

We will also continue to share your personal information with credit reference agencies whilst you have a relationship with us. The credit reference agencies may in turn share your personal information with other organisations. Details about your application (whether or not it is successful) will be recorded and we will give details of your account and how you manage it to credit reference agencies. If you do not repay any debt in full or on time, they will record the outstanding debt and supply this information to others performing similar checks, to trace your whereabouts and to recover debts that you owe. Records remain on file for 6 years after they are closed, whether settled by you or defaulted. A financial association link between joint applicants will be created at the credit reference agencies. This will link your financial records and be taken into account in future applications by either or both of you until either of you apply for a notice of disassociation with the credit reference agencies.
The identities of the credit reference, and the ways in which they use and share personal information is explained via the Credit reference Agency Information Notice (CRAIN) document which can be accessed via any of the following links:

- experian.co.uk/crain
- equifax.co.uk/crain
- transunion.co.uk/crain ‍

### 11. Biometric Data and AI Processing

We use specialised third-party providers to help verify your identity and prevent fraud:

- Biometric Identity Verification: We use third-party platforms to verify your identity using biometric data (such as facial images). Explicit consent for this processing is captured directly at the time of the check.

AI Document Checks: We use Artificial Intelligence (AI) to assist in verifying documents and detecting fraud. This data is processed securely in real-time, and the AI provider does not retain your data once the check is complete.

While these technologies generate flags or recommendations to assist our team in assessing risk, we do not make decisions solely by automated means. A human team member is always involved in making final decisions regarding your account or services.

We apply strict security measures to protect your data throughout this process, ensuring it is only used for its intended purpose.

### 12. Use of cookies

We use cookies (small data files placed on your computer) to tailor our offerings, provide you with a better service, and ensure the website operates correctly. We use the following cookies:

- Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
- Analytical/performance cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

View a more detailed breakdown of our cookie usage here.

### Contact

Questions, comments, and requests regarding this privacy policy are welcome and should be addressed to our Data Protection Team at dataprotection@strideup.co or by telephone on 0203 376 8726 (for data protection enquiries only). You may also write to the team at: Data Protection Team, StrideUp, Third Floor, 20 Old Bailey, London, United Kingdom, EC4M 7AN.

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