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Privacy Policy

Summary

This policy explains how we collect, use and process personal data and other related information. We are committed to being transparent about how we use (and won’t use) data.

Who we are

Nude, Tembo, Tembo Lifetime ISA and Tembo LISA are trading names of Nude Finance Limited and we’re registered with the Information Commissioner’s Officer (reference: ZA594655). Our registered office is at 18 Crucifix Lane, London, SE1 3JW: and you can write to us there, email us at hey@getnude.com. We’re also authorised and regulated by the Financial Conduct Authority.

The information we hold about you

The data and information we may hold about you includes:

Information you give to us
  • When you apply for an account, we’ll ask for things such as your email address, legal name, date of birth, National Insurance number, residential address and ID documents in order to verify your identity and securely open your account. You may also be asked to provide photographs of documents and a selfie to help us prevent money laundering, which we appreciate.
  • When you set up a direct debit mandate we require your bank details.
  • If you get in contact with us, either directly or through applying for things like surveys and competitions, we’ll collect your contact details, name and the information included in your message.
Information we collect about you

When you use our website or mobile app, if you have an account with us, or if you get in touch with us, we might automatically collect the following:

  • Technical information, including the IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and device platform;
  • Usage data, such as page response times, download errors, length of visits to certain pages and page interaction information; and
Information we receive from other sources
  • When we connect to your bank account through Open Banking, we’ll view your balance and transactions to help you better understand your finances and suggest personalised ideas that could help you reach your savings goal faster.
  • We also collect and use information about you that is provided by third parties. Refer to our Cookie Policy for more information about how we use cookies.

How we use your information

We use your information:

  • To perform identity, fraud and anti-money laundering checks;
  • To operate as a business that provides financial products and services;
  • To carry out our obligations to you under any contracts entered into between you and us;
  • To comply with our legal obligations, including disclosing information to regulatory agencies where necessary;
  • To keep you up to date with changes to your account, our contract together and make other important notifications;
  • To keep you and us secure;
  • To give you information about our products and services;
  • To enable you to participate in surveys and competitions; and
  • To measure and understand (in some cases using analytics) our products and services in order to improve them, our app and our business generally.

We collect and process your information only where we have a lawful basis to do so. This includes the following:

  • Where it is necessary for entering into or performing a contract with you;
  • Where we have a legitimate interest to do so, provided your rights do not override those interests;
  • Where you have consented to its uses;
  • Where we believe it is in your vital interests to share your personal details; and
  • Where required to comply with our legal obligations.

Credit reference and fraud prevention agencies

  • For a range of reasons, we use services of credit reference and fraud prevention agencies. For example when you apply for an account with us and whilst you use our services. These systems use automated decision making, and you can contact us in relation to such a decision if you want us to look at it again.

Sharing your information

We may share your personal information with:

  • Anyone who works for us if they need it to do their job;
  • Any organisation which supports us in operating our business, if they need it to perform a contract with us or for the uses set out above in the ‘How we use your information’ section. This includes, but is not limited to:
    • Quai Administration Services Limited, who help us manage our books and records;
    • Winterflood Securities Limited, who provide dealing and custody services for investments;
    • Gocardless Ltd, who help us process payments. You can access their privacy policy here;
    • Onfido Ltd, who help us verify identities. (This may also involve your information being shared with credit reference and fraud prevention agencies, see above);
    • Moneyhub Financial Technology Limited, who help us access customer bank accounts via Open Banking;
    • Microsoft Ireland Operations Limited, our cloud storage provider of choice;
    • Zendesk, Inc., who host our communication tools;
    • Mailjet inc., to send you email communications;
    • KickoffLabs LLC., to run our referrals programmes; and
    • Typeform SL, to run surveys.
  • Any analytics or search engine providers that support us in the improvement and optimisation of products and services; and
  • Any of our group entities or subsidiaries.

We’ll also share your data if it is necessary to comply with the law, to enforce agreements between us or to protect the rights, property or safety of us, our customers or relevant third parties.

Keeping your information safe

We keep your data safe by locking it up with enterprise-level encryption.

Internally, we only give access to the people who absolutely need to have access to your data, no one else. It’s held strictly on a need-to-know basis. Some data is anonymised (meaning it can’t be clearly linked back to you).

As a regulated financial institution, we have obligations to retain some data for a specified period, even after you’ve closed your account. We’ll keep this data safe and secure and only allow access to it for specific and limited purposes. As a general rule, we will aim to delete or anonymise data which we no longer need for regulatory purposes or to offer you an account.

In order to keep your data in the app secure, you need to keep your login credentials confidential. That means you can’t share them with anyone else or store it where anyone else could find it.

Storing your data

We try to keep your data within the UK and European Economic Area (EEA) wherever possible. However, from time to time it may be transferred outside of the UK and EEA, where allowed under data protection laws. This would only happen if the people who work for us or third parties we work with outside of the EEA need to process the data. It’s also sometimes necessary for third parties we utilise to offer you our products and services to have their servers located in the United States, for example.

We cannot accept responsibility or liability for the content held on third party sites. Please refer to the third party’s terms of use and privacy and cookie policies before using and/or providing any information to or via their sites or apps, as they may process your personal data for their own purposes.

Third-party software / service providers

We may use UXCam, which is an analytics solution. UXCam may record: Screens visited, Interaction patterns (such as screen actions, gestures: taps, scrolls), and Device details (Type, Version, Model, Operating System). We are using the information collected by UXCam to improve our app.

UXCam does not collect personally identifiable information and does not track your browsing habits across apps. For more information see Privacy Policy for Information Collected by the UXCam Service.

Your rights

You have the right to:

  • Access your personal data and request a copy of it;
  • Ask us to amend information for accuracy;
  • Request that we delete your personal data (please note that for legal reasons we might not be able to do this with certain pieces of information which we are obliged to retain, and in some cases it may be impossible to permanently delete and where this is not possible we will put that information beyond reasonable use);
  • Ask us to stop our use of some or all of your personal data;and
  • Withdraw any consent you’ve previously given us. To request taking any of these actions, email us at hey@getnude.com.

Updating this policy

We may update this policy from time to time. When we change this document you’ll be able to find the latest version here. We’ll also contact you about changes if we think you need to know about them.