We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to all legislation in force from time to time in the United Kingdom applicable to data protection and privacy including, but not limited to, the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR), as it forms part of the law of England and Wales, Scotland, and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018; the Data Protection Act 2018 (and regulations made thereunder); and the Privacy and Electronic Communications Regulations 2003 as amended.

This policy (together with our end-user licence agreement and terms of use) applies to your use of:

• “Auderli” whether provided via our web app at https://app.auderli.com or via our native app (Our App) once accessed via our website or once you have downloaded a copy of Our App onto your mobile telephone or handheld device (Device).
•  Any of the services accessible through Our App (Services). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Our App is not intended for children, and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

It would be helpful to start by explaining some key terms used in this policy:

Term: We, us, our
Description: We are Auderli Limited, a company registered in England and Wales. Our company registration number is 11818553 and our registered office is Stanford Gate, South Road, Brighton, BN1 6SB, United Kingdom. Our brand name is "Auderli".

Term: Personal data
‍Description: Any information relating to an identified or identifiable individual as defined in UK GDPR.

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

• first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender (Identity Data)
• billing address, email address and telephone numbers (Contact Data)
• details about the assets you hold such as real property, personal property, intangible property, bank accounts, cryptocurrency, pensions, insurance policies and your liabilities such as mortgages, bank loans, car loans or credit card debt (Estate Data)
• details about payments to and from you; details of the Services you have purchased; payment information such as your credit or debit card number and other card information, other account and authentication information, and billing, delivery and contact details (Transaction Data)
• the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, internet protocol (IP) address, your login data and the time and date the Services were used, browser type and version, time zone setting and location, browser plug-in types and versions; operating system and error data (Device Data)
• information stored on your Device including login information (Content Data)
• your username/login ID and password; purchases or orders made by you; your interests; preferences; feedback and survey responses (Profile Data)
• information about how you use the Services including how you interact with the Services; we receive and analyse content, communications and information that you provide when you use the Services (Usage Data)
• your preferences in receiving marketing from us and our third parties and your communication preferences (Marketing & Communications Data)

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Our App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact, Estate and Marketing & Communications Data) you consent to giving us about you by filling in forms on Our App or by corresponding with us (for example, by email or SMS). It includes information you provide when you register to use Our App, subscribe to any of the Services, use any of the Services, make a purchase, enter a competition, promotion or survey and when you report a problem with Our App or the Services. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you use Our App we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below:
• Device Data from the following parties:
- - analytics providers such as Google based outside the UK;
- - advertising networks such as Google based outside the UK; and
- - search information providers such as Google based outside the UK.
• Contact and Transaction Data from providers of technical, payment and delivery services.

We use cookies and/or other tracking technologies to distinguish you from other users of Our App to remember your preferences. This helps us to provide you with a good experience when you use Our App and also allows us to improve Our App. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where you have consented before the processing.
• Where we need to perform a contract we are about to enter or have entered with you.
• 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.
• Where we need to comply with a legal or regulatory obligation.

See “Glossary Legal Basis” below to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purpose/activity: To register you as a new user
Type of data: Identity,
Contact,
Device
Lawful basis for processing: Your consent

Purpose/activity: To process purchases and deliver Services including managing payments and collecting money owed to us
Type of data: Identity,
Contact,
Estate,
Transaction,
Device,
Marketing & Communications
Lawful basis for processing: Your consent. Performance of a contract with you. Necessary for our legitimate interests (to recover debts due to us)

Purpose/activity: To manage our relationship with you including notifying you of changes to Our App or any Services
Type of data: Identity,
Contact,
Estate,
Profile,
Marketing & Communications
Lawful basis for processing: Your consent
Performance of a contract with you.
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services).
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

Purpose/activity: To enable you to participate in a prize draw, competition or complete a survey
Type of data: Identity,
Contact,
Device,
Profile,
Marketing & Communications
Lawful basis for processing: Your consent,
Performance of a contract with you,
Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

Purpose/activity: To administer and protect our business and Our App including troubleshooting, data analysis and system testing
Type of data: Identity,
Contact,
Device
Lawful basis for processing: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

Purpose/activity: To deliver content and advertisements to you,
To make recommendations to you about goods or services which may interest you,
To measure and analyse the effectiveness of the advertising we serve you,
To monitor trends so we can improve Our App
Type of data: Identity,
Contact,
Estate,
Device,
Content,
Profile,
Usage,
Marketing & Communications
Lawful basis for processing: Consent,
Necessary for our legitimate,
interests (to develop our products/Services and grow our business)

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table above.

• Internal Third Parties as set out in the Glossary below.
• External Third Parties as set out in the Glossary below.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Within Our App you will be able to share your Estate Data with people you trust such as, for example, your spouse, friend, beneficiary or a trusted third party advisor such as your accountant or your lawyer. Please only share your Estate Data with people you trust and note that you do you do so entirely at your own risk, and we shall bear no liability for any harm, loss or damage resulting from such disclosure by you.

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of 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.
• Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access Our App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features and take all reasonable steps to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your Device using application data caches and browser web storage including HTML5 and other technology.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

By law we have to keep basic information about our customers (including Contact, Identity and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see “Your Legal Rights” below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use Our App for a period of 2 years then we will treat the account as expired and your personal data may be deleted.

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

• 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 continuing 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 on 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:
- - if you want us to establish the data's accuracy;
- - where our use of the data is unlawful but you do not want us to erase it;
- - 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
- - 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.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us.

We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have. You also have the right to lodge a complaint with the Information Commissioner (www.ico.org.uk).

Our App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave Our App, we encourage you to read the privacy policy of every website you visit.

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our full details are:
‍
• Full name of legal entity: Auderli Limited
• Email address: support@auderli.com
• Postal address: Stanford Gate, South Road, Brighton, BN1 6SB, United Kingdom

We keep our privacy policy under regular review. This version was last updated on 27th January 2023. It may change and if it does, these changes will be posted on this page.

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Internal third parties

• There are no internal third parties.

External third parties
‍
• Service providers acting as processor based inside and outside of the United Kingdom who provide IT and system administration, payment gateway and other services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.