Effective Date: 30 May 2025

This Privacy Policy explains how Buckstrybe (“we,” “us,” or “our”) collects, uses, processes, and protects your personal data when you use our website, mobile application (“App”), and services (collectively, “Services”). We are committed to protecting your privacy and handling your data transparently and in accordance with UK data protection laws, including the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

1. Who We Are

Buckstrybe is a UK-based company focused on empowering young adults and immigrants by transforming informal financial transactions into credit profiles and reporting them to credit reference agencies.

Our Contact Details: Email: support@buckstrybe.com Phone: +44 20 7946 0958 Address: 123 Inclusion Lane, London, UK

For any privacy-related queries or to exercise your data protection rights, please contact us at the email address above.

2. The Data We Collect About You

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

• Identity Data: Includes first name, last name, date of birth, and potentially nationality (for immigrants focus).
• Contact Data: Includes billing address, email address, and telephone numbers.
• Financial Data: This is core to our service. It includes information from your linked bank accounts relating to your informal transactions such as rent payments, board money, rotational savings schemes (money cycles), peer-to-peer lending, shared expenses, and potentially subscriptions or utilities. This data is accessed securely via Open Banking.
• Transaction Data: Details about the informal transactions you conduct or have tracked through our Services (e.g., amount, date, participants in P2P lending or money cycles).
• P2P Marketplace Data: If you use our P2P marketplace, we collect data about your phone contacts (with your explicit permission) to help you connect with other Buckstrybe users in your network. Please note, only you can see your synced contacts, and lending terms are set by you.
• Credit Visibility Score Data: Information related to your generated Credit Visibility Score, including the underlying transaction patterns and the score itself.
• Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Services.
• Usage Data: Information about how you use our website and App, products, and services, including navigation paths, service access times, and interaction with features.
• Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties and your communication preferences.
• Community Data: Any information you choose to share when participating in our community features, such as sharing experiences or insights.

3. How Your Personal Data is Collected

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

• 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:
  • Create an account on our App or website.
  • Connect your bank account through Open Banking.
  • Register or track informal transactions (e.g., money cycles).
  • Use our P2P marketplace.
  • Participate in our community features.
  • Request marketing materials to be sent to you.
  • Give us feedback or contact us.
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• Automated Technologies or Interactions: As you interact with our website and App, we will automatically collect Technical Data and Usage Data about your equipment, Browse actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.
• Third Parties or Publicly Available Sources:
  • Open Banking Providers: We receive Financial Data from licensed Open Banking providers when you securely link your bank account.
  • Credit Reference Agencies (CRAs): We will report your Credit Visibility Score and relevant transaction data to CRAs where possible, which may then be used by them to provide credit information services. We may also receive information from CRAs related to your existing credit profiles for verification purposes.
  • Phone Contacts: When you grant permission, we access your phone contacts to identify other Buckstrybe users for the P2P marketplace.

4. 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:

• To provide our Services and fulfil our contract with you: This includes:
  • Creating and managing your Buckstrybe account.
  • Processing, validating, and transforming your informal financial transactions (rent, money cycles, P2P lending) into a Credit Visibility Profile and Score.
  • Operating the P2P marketplace, enabling you to lend or borrow within your network.
  • Monitoring your credit-building progress.
  • Providing customer support and communicating with you about your account.
  • Reporting qualifying payment patterns and your Credit Visibility Score to Credit Reference Agencies (CRAs) where possible, with your consent where required.
• Where we have your explicit consent:
  • To securely connect your bank account via Open Banking and access your financial transaction data.
  • To access your phone contacts for the P2P marketplace.
  • For specific marketing communications if you have opted in.
• 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:
  • Improving our Services, features, and the functionality of our App and website.
  • Developing new products and services, including refining our AI-powered Credit Visibility Score.
  • Conducting data analytics to understand user behaviour and trends.
  • Ensuring the security of our Services and preventing fraud.
  • For internal administration, troubleshooting, and testing.
  • To identify and track users who may benefit from our services (e.g., credit invisibles).
• Where we need to comply with a legal or regulatory obligation:
  • To meet our legal and regulatory requirements, such as anti-money laundering (AML) or know-your-customer (KYC) obligations, if applicable in the future.
  • Responding to requests from law enforcement or regulatory authorities.

Purposes for which we will use your personal data:

Export to Sheets

5. Disclosure of Your Personal Data

We may share your personal data with the parties set out below for the purposes described in section 4:

• Credit Reference Agencies (CRAs): We will share your Identity Data, relevant Financial and Transaction Data, and your Credit Visibility Score with CRAs (e.g., Experian, Equifax, TransUnion) to contribute to your credit profile and facilitate financial inclusion.
• Open Banking Providers: We work with authorised and regulated Open Banking providers to securely connect your bank accounts and access your financial data. They process your data to enable this connection.
• Service Providers: We engage third-party service providers who perform services on our behalf, such as:
  • IT and system administration services (e.g., cloud hosting providers).
  • Data analytics providers.
  • Customer support platforms.
  • Marketing and communication platforms (where you have opted in).
  • Professional advisors (e.g., lawyers, accountants, auditors).
• Other Buckstrybe Users (for P2P Marketplace): When using the P2P marketplace, while you control your contacts, the nature of peer-to-peer lending means certain transaction details (e.g., loan amount, repayment status) may be visible to the specific individuals involved in a transaction with you. Your full identity beyond your app profile may be shared with mutual contacts you choose to engage with for lending/borrowing.
• Law Enforcement and Regulatory Bodies: We may disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g., a court order or government agency).
• Acquirers of our business: In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• Group Companies: We may share data within our group of companies for internal administrative purposes.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

Some of our external third parties may be based outside the UK. While Buckstrybe primarily operates within the UK, the processing of your personal data may involve transferring your data outside the UK.

Whenever we transfer your personal data out of the UK, 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 Information Commissioner’s Office (ICO).
• Where we use certain service providers, we may use specific contracts approved by the ICO which give personal data the same protection it has in the UK (e.g., International Data Transfer Agreements or Addendums).

7. Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. This includes the use of bank-grade security measures and encryption for data transmission and storage.

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 procedures in place 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.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

For example, we will retain your account and transaction data for the duration of your active account with us and for a period thereafter as required by law or for our legitimate business purposes (e.g., tax, audit, or to resolve disputes).

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data (commonly known as a “data subject access request”). 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 to continue 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 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.
• Rights in relation to automated decision-making and profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, unless the decision is necessary for entering into, or performing, a contract between you and us, is authorised by law, or is based on your explicit consent. Our Credit Visibility Score is AI-powered, and while it informs your credit profile, significant decisions based solely on this score will be carefully considered.

If you wish to exercise any of the rights set out above, please contact us at support@buckstrybe.com.

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.

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.

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.

10. Complaints

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

11. Children’s Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal data from children under 18. If we become aware that we have collected personal data from a child under 18 without verification of parental consent, we will take steps to remove that information from our servers.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The latest version will always be posted on our website and App with the “Effective Date” updated. We will notify you of any significant changes by email or through a prominent notice on our Services. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your data.