Firenze Ltd (“Firenze”) is committed to protecting and respecting your privacy. This privacy policy describes how, as you use and access Firenze, we collect, use, process, store and disclose your information. It explains what kind of personal data we collect and sets out your rights in relation to how we look after your personal data.

 

For the purposes of General Data Protection Legislation (GDPR) the data controller is Firenze Ltd, registered at Stableford Hall, Stableford Avenue, Manchester, M30 8APR.

This policy is available on Firenzeme.com where you can review it to stay updated with recent changes.

 

Policy highlights

We process data collected from you, your connected accounts, and third parties, to make Firenze work for you, and comply with our regulatory requirements. Most importantly we use:

• Your personal details – names, address, date of birth, to comply with our obligations to know our customer.

• Your portfolio data - detail of your investments, their performance and their value

• Your transaction data – (but not your account login details or security details) to make Firenze work, and enable us to give you insights into your credit card data and how best to repay your cards.

• Payment data – necessary to process payments on your behalf as requested by you.

• Data about your use of Firenze – to help us make Firenze work better for you.

 

We also share your data with other companies to fulfil our services to you, or to comply with regulation:

 

• Credit Reference agencies

• Direct Debit provider – Modulr manages any Direct Debits

• Other selected service providers - under GDPR rules.

 

GDPR gives you the right to see, erase, or challenge the data we hold about you, among other rights. Our support team can help with this.

 

Read the full privacy policy for further details on how we use your information.

 

Data collection

Information we collect about you

You may give us information about yourself by accessing our website Firenzeme.com, by using the app or by contacting us by phone, email or otherwise. We may store this information along with any consent that you give.

 

Information you give us when you sign up in our app

This is information necessary to provide you with Firenze’s services and to comply with regulatory obligations to know your customer (KYC):

• First and last name

• Email

• Address

• Date of birth

• Nationality

• Telephone number

 

Some additional information may be collected to enable us to make an assessment of our willingness to provide credit and your ability to repay. For example, occupation, salary, and expenditure.

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Information we automatically collect when you use Firenze

When you use the Firenze app or visit our website, we automatically collect information. This includes personal information about the parts of the Firenze service you use, and how you use them. The following information is necessary to fulfil our services to you, to fulfil our regulatory obligations, and given our legitimate interest in being able to provide Firenze services to you:

• Information about your payments – needed to process payments and carry out fraud prevention measures, including credit and debit card numbers, security code numbers and other such relevant billing details.

• Information about your device – your use of the site or the service (including your IP address, geographical location, browser or platform type and version), internet service provider, operating system.

• Information about your use of the product – to be able to offer you the Firenze features and benefits.

 

Information we receive from third parties

We receive the following personal information about you from our third party service providers who help us in providing some or all of our service:

 

• Your wealth manager - details of your investment portfolio and its performance

• Our KYC provider – the outcome of your know-your-customer check, to perform our money-laundering obligations.

• Your accountant – information to enable Firenze to validate, classify and process your credit application

• Public and commercial sources – to perform our KYC obligations and regulatory obligations we might collect information from public sources such as sanction lists or credit reference agencies. 

 

How we use the information we collect from you 

To provide and improve the Firenze product

We process the information we collect given our legitimate interests in improving the Firenze service, and to fulfil our services to:

• Give you access to, and enable your interaction with, Firenze’s products and features

• Offer you customer service

• Offer products and services that we feel may be of interest to you

• Keep you informed by sending you support messages, push notifications, security alerts, updates and account notifications

• Manage our website and app services and for internal analysis, such as troubleshooting, data analytics, testing, research, statistical analysis and surveys

 

To prevent fraud, and to meet regulatory obligations

We process the information we collect given our legitimate interest to protect us from fraud, and to comply with regulatory obligations to:

• Detect fraud, including transaction monitoring

• Verify your identity and check it against sanction lists

• Keep our platform secure

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Who we share your data with

Service providers

To provide our services to you, we use trusted service providers. These providers will each handle your data according to their own privacy policies. The most important service providers we use are:

• Direct Debit provider – Modulr helps us to deliver our services by providing you with access to their direct debit service.

• Regulatory bodies - To comply with our regulatory obligations to report activity suspected to be money laundering we might share your information with government entities responsible for this. We may be required by the Financial Conduct Authority or the Financial Ombudsman Service to share personal data with them.

• Aggregated data - We may share aggregated and non-personally identifiable information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes. Aggregated information is information about our users that we combine so that it no longer identifies or references a user. It is not considered personal data under GDPR as it can’t be used to directly or indirectly identify you.

• Our funders – we will share aggregated performance data of the Firenze lending portfolio, in support of our debt funding obligation.

 

Credit reference agencies

In order to process your credit application, we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.

We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates.

 

The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at:

• Call Credit – www.callcredit.co.uk/crain

• Equifax – www.equifax.co.uk/crain

• Experian – www.experian.co.uk/crain

 

How long we keep your data

We generally keep your information for as long as we need to perform the service we have with you, or to comply with our regulatory obligations. If you no longer want us to use your information you can send a request to privacy@Firenzeme.com

 

Please note that if you ask us to erase your personal data, we will keep relevant personal information for at least 5 years to comply with our regulatory obligations.

 

Your rights under GDPR

Individuals shall have the following rights regarding personal data that we process:

 

The right of access - You have the right to get a copy of the data we hold about you. This is free of charge. To do this please email privacy@Firenze.com or talk to one of our support team

The right of rectification - You have the right to ask us to correct or update any information we hold which may be inaccurate, and which you can't change yourself through the Firenze app or website.

The right of erasure - You have the right to ask us to erase personal information we hold on you and close your Firenze account. If you do this, we might maintain the personal information we hold on you which is necessary to comply with our regulatory obligations or to reduce fraud.

The right to withdraw consent or restrict processing - If you wish to withdraw consent or restrict processing, you can do this by contacting us. If you withdraw your consent to share your financial transaction data, we will be unable to provide the Firenze service to you. Some information you have provided to us will be retained after you withdraw your consent to comply with legal and regulatory obligations.

The right to complain - You have the right to lodge a complaint with the Information Commissioner's Office for any processing carried out by Firenze. You can contact them through ico.org.uk or by phoning 0303 123 1113. Firenze’s ICO reference number is ZB612919

 

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on our website. Where appropriate, we will notify you by email or by in-app push notifications.

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Contact us

If you have any questions, comments and requests regarding this privacy policy we would like to hear from you. Please address these to privacy@firenzeme.com

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