Patricia Kibuuka-Musoke T/A Finlune customer privacy notice

Contact details

Email

hello@getfinlune.com

What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients:

• Names and contact details
• Business name, industry, length of time operating and information voluntarily provided about business financial-management challenges

We collect or use the following personal information for information updates or marketing purposes:

• Names and contact details

We collect or use the following personal information for dealing with queries, complaints or claims:

• Correspondence

We collect or use the following personal information to collect expressions of interest, assess suitability and contact prospective early testers:

• Names and contact details

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
• Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
• Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • Finlune has a legitimate interest in identifying and engaging small-business owners who are interested in participating in its early product testing programme. We collect limited personal information, including names, contact details, business information and voluntarily provided descriptions of financial-management challenges. This information is necessary to assess applicants’ suitability, contact them about potential participation and gather insights to improve Finlune’s products and services. Individuals provide this information voluntarily through a form specifically designed for registering interest in the testing programme. They can reasonably expect their information to be used for these purposes. The privacy impact is limited because we collect only information relevant to the programme, do not request sensitive personal or banking information, restrict access to applicant details and do not use the information for unrelated marketing without an appropriate lawful basis. Individuals can contact Finlune to exercise their data protection rights, including requesting deletion of their information where applicable. We consider that these legitimate interests are not overridden by individuals’ rights and freedoms, provided the stated safeguards are maintained.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • Finlune has a legitimate interest in responding to enquiries, concerns and complaints from individuals who contact the business. We use relevant contact details and correspondence to understand and respond to enquiries, resolve issues and maintain appropriate records of communications. Individuals who contact Finlune can reasonably expect their information to be used for these purposes. We limit the information collected and retained to what is necessary, restrict access and allow individuals to exercise their applicable data protection rights. We consider that these interests are not overridden by individuals’ rights and freedoms, provided appropriate safeguards are maintained.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information to collect expressions of interest, assess suitability and contact prospective early testers are:

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • Finlune has a legitimate interest in recruiting suitable small-business owners to participate in its early product testing programme. We collect limited personal and business information to assess suitability, contact prospective testers and organise potential participation. Individuals voluntarily register their interest and can reasonably expect to be contacted about the programme. We minimise the information collected, restrict access to authorised individuals and allow applicants to exercise their applicable data protection rights. Subject to these safeguards, we consider that our legitimate interests are not overridden by individuals’ rights and freedoms.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Where we get personal information from

• Directly from you

How we share and store your information

We use Google Forms and associated Google services to collect and manage early-tester applications.

Google processes information on our behalf to provide these services. We do not sell applicants’ personal information.

Access to application responses is restricted to authorised individuals involved in managing Finlune’s testing programme.

Where personal information is transferred outside the UK, we will ensure that appropriate data protection safeguards apply.

How long we keep information

We retain personal information only for as long as necessary for the purposes for which it was collected.

Early-tester applications: We retain application information for up to six months after the relevant recruitment process closes, unless you become a tester or a longer retention period is justified.

Marketing communications: We retain your contact details while you remain subscribed. We periodically review inactive subscriptions and remove information that is no longer necessary.

Unsubscribed contacts: We may retain a minimal suppression record to ensure that you do not receive further marketing communications.

Enquiries and correspondence: We normally retain correspondence for up to 12 months after an enquiry has been resolved, unless a longer period is necessary to address a legal claim or obligation.

Marketing communications

If you separately opt in, we may email you about Finlune’s development, product updates, financial tips, launch announcements and future offers.

Signing up for the early-tester programme does not automatically subscribe you to marketing emails.

You can withdraw your marketing consent at any time by using the unsubscribe instructions in our emails or contacting hello@getfinlune.com.

You may contact us at hello@getfinlune.com to request deletion of your information, subject to applicable legal requirements.

How to complain

If you have any concerns about our use of your personal information, you can make a data protection complaint to us:

Email: hello@getfinlune.com

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint