EXTERNAL DOCUMENT

CUSTOMER PRIVACY NOTICE

Version 2.0

May 2021

© Kroo Ltd 2021

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EXTERNAL DOCUMENT

First Issued: 12th March 2021

Last updated: 18 May 2021

Introduction

Kroo Ltd ("we", "us", and "ours" or “Kroo”) respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. If you have any questions or concerns about our use of your personal information please contact us using the contact details provided at the end of this Privacy Notice.

What does Kroo do?

Kroo is a company incorporated in England and Wales. It is planning to launch as a UK bank in 2021, and currently acts as an E-Money agent for Modulr FS Ltd. Kroo offers a pre-paid debit card to its customers, and a banking app that enables customers to set up social groups of friends, flat mates, colleagues, family etc and split bills and settle directly with each other.

Information that you provide voluntarily

We ask you to provide certain information voluntarily. The types of information we ask you to provide, and the reasons why we ask you to provide it, include:

Types of personal information

Why we collect it

 

 

Name and contact details such as address,

For the purpose of processing applications

telephone number and email

for banking products and services, including

 

ID and fraud checks. Also used to provide

 

those products and services to you (for

 

private customers) or your employer (for

 

business customers) and to communicate

 

with you in connection with those products

 

and services.

 

 

Personal data you may provide in

Where we are communicating with you,

communications

whether via the banking app or otherwise,

 

you may provide personal data, for example

 

in connection with an enquiry or complaint.

 

 

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Types of personal information

Why we collect it

 

 

Age

To verify we are legally permitted to provide

 

banking products and services to you.

 

 

Information such as copies of passports,

For identification purposes and to prevent

driving licenses, or other

fraud in connection with accounts and to

government-issued IDs, passport numbers,

comply with anti-money laundering

signatures, tax identification numbers and

requirements and tax reporting

utility bills.

requirements.

 

 

If we ask you to provide any other personal information not described above, then the personal information we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect your personal information.

Information that we collect automatically

If you use a mobile phone or other similar electronic device to access our products and services, we may also collect certain information automatically from your device. This will include your IP address.

Information that we obtain from third party sources

From time to time, we may receive personal information about you from third party sources (including credit reference agencies, World Checking services, CIFAS (a credit industry fraud prevention community)), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

The types of information we collect from third parties includes:

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Types of personal information

Why we collect it

 

 

Criminal records and proceedings checks,

To comply with anti-money laundering and

immigration status checks and World

other account opening and maintenance

Checking searches

requirements

 

 

Account and loans information

To provide our products and services to

 

you, for internal analytics and credit

 

portfolio management and for the purpose

 

of detection and prevention of fraud

 

 

Information to check creditworthiness such

To carry out checks to assess

as financial history, income and outgoings,

creditworthiness for credit facilities you

credit history and court judgements

have applied for, for internal analytics and

 

credit portfolio management

 

 

Information about claims and proceedings

To identify, exercise and defend contractual

(or potential claims and proceedings) by or

and other legal rights

against you

 

 

 

In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

Who does Kroo share my personal information with?

We may disclose your personal information to the following categories of recipients:

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to our third party services providers and partners who provide data processing services to us, or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information;

to one or more credit reference agencies, to inform them that you have a current account and to tell them about any credit you have with Kroo and your repayment record. Equifax, Experian and TransUnion (previously CallCredit), the ICO and major financial services trade associations, we have developed a common statement, Credit Reference Agency Information Notice (CRAIN), defining the standards that all three Credit Reference Agencies will apply across all products and services in relation to processing consumer data. This can be found: https://www.transunion.co.uk/legal/privacy-centre#pc-credit-reference .

to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation including anti-bribery and corruption regulations and anti-money laundering laws, (ii) to exercise, establish or defend our legal rights, (iii) for fraud prevention purposes and (iv) to protect your vital interests or those of any other person;

to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;

to any other person with your consent to the disclosure.

Legal basis for processing personal information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or from third parties (such as to comply with anti-money laundering or immigration laws and fraud prevention) or may otherwise need the personal information to protect your vital interests or those of another person.

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If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided at the end of this Privacy Notice.

How does Kroo keep my personal information secure?

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include:

physical access control systems

a physical security presence

logical access controls (such as passwords)

perimeter security systems (such as firewalls)

vulnerability management

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, our servers are hosted by AWS in Ireland. Our third party service providers and partners operate around the world. This means that when we collect your personal information we or our data processors may process it outside the UK or the European Economic Area (EEA).

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between us and our data processors, which require such processors to protect

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personal information they process outside the EEA in accordance with European Union data protection law.

Our Standard Contractual Clauses can be provided on request.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Automated decision-making

Automated decisions are decisions concerning you which are made automatically on the basis of a computer determination (using software algorithms), without human review. We do not use automated decision-making except:

Face recognition technology which matches an image that you provide us of your face with the photograph on ID documents that you provide us with when you apply to open an account with us. If there is no match the application will be declined.

When you apply to open an account we run your details through fraud databases provided by external agencies. If there is a match your application will be declined.

When you apply to borrow from us we will obtain information from credit reference agencies and use that, in combination with other information you have given us or which we hold because you are already a customer, to provide a credit score which will determine whether we can lend to you. If you are declined credit you have the right to ask for this decision to be reviewed.

Your data protection rights

You have the following data protection rights:

If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided at the end of this Privacy Notice.

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In addition, if you are a resident of the United Kingdom or the European Union, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details at the end of this Privacy Notice.

You have the right to opt-out of marketing communications we send you at any time by contacting us using the contact details at the end of this Privacy Notice.

Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact the UK’s Information Commissioner’s Office (ICO) www.ico.org.uk

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the date displayed at the top of this Privacy Notice.

How to contact us

If you have any questions or concerns about our use of your personal information, please contact our Data Protection Officer using the following details: dataprotection@Kroo.com.

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