Kroo Ltd (formerly B-Social Limited), a company registered in England and Wales under company number 10359002 with its registered office at LABS House, 15-19 Bloomsbury Way, London, United Kingdom, WC1A 2TH (Kroo, we, us, our) are committed to protecting and respecting your privacy. This policy (together with our Terms and Conditions) explains how we collect, store and use personal data about you when you use our mobile application (the App), browse our website at https://b-social.com (our site) or otherwise provide your personal data to us.

Please read this Privacy and Cookie Policy carefully so that you understand our policies and procedures regarding your personal data and how we will treat it. We will at all times only collect and process your personal information in accordance with the EU Data Protection Regulation (GDPR) 2018 as set out in the Data Protection Act 2018 (the Act), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any other applicable data protection legislation.

BY VISITING OUR SITE OR DOWNLOADING OR USING OUR APP, YOU ARE AGREEING TO AND CONSENTING TO OUR PROCESSING OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY AND COOKIE POLICY. WE WILL CONSIDER THIS TO BE EXPLICIT CONSENT UNDER THE GDPR.

You acknowledge that our legal basis for processing your personal data is your consent, for the performance of a contract to which you are a party, and in fulfilment of certain legal obligations we have (including amongst other things for the prevention of fraud, money laundering, terrorist financing or misuse of services).

We have a legitimate interest in processing your personal data (as defined in 3. below) where it is necessary (or reasonably expected) for carrying out the terms of our contractual relationship and providing you with the services to which you have subscribed.

We may change this Privacy and Cookie Policy at any time by amending this page. We will display the effective date of this Privacy and Cookie Policy at the top of this page and your continued use of our site after such effective date constitutes your agreement to such changes.

Please check this page from time to time to take notice of any changes we have made. If the changes made are significant, we will also let you know by email, text message or in app message.

When you use the App, visit the Site or contact us by in-App messenger, post, telephone, e-mail or SMS, we may collect, store and use certain personal information that you disclose to us. The information that we may collect from you includes:

• Information that you provide directly via the App or Site, for example, during registration;
• Information you provide regarding your marketing preferences or in the course of participating in surveys, contests or promotional offers;
• Details of how you use the Service;
• Your internet protocol address;
• If you contact us, we may keep a record of that correspondence, including any phone number or email address you use;
• Details of your transactions (including details of payment cards and bank accounts used) made via the Service;
• Details of your usage of the App and Site including, but not limited to, traffic data, location data, logs, error and crash reports, and other communication data and the services that you access;
• The information available about your usage or configuration of your mobile device, including the presence of other applications, unique device-identifying information, and any cellular network, IP, wifi, Bluetooth data or similar technology; and
• Information you give us explicit permission to access from your mobile device, including your address book, photos, geolocation, and data from your cameras or microphones.

By using the App or visiting the Site, you agree that your information may be used by us and be disclosed by us to third parties who are carefully selected for any of the following purposes:

1. to provide you with a personalised experience when using our App or Site;
2. to deliver the Service;
3. to improve the Service;
4. to understand your needs in order to develop new features for the App;
5. to service and manage your account and service preferences;
6. to learn about our markets and improve our products and services;
7. to fulfil any contractual agreements between you and us;
8. to comply with legal and regulatory requirements;
9. to access specific account information for administrative purposes and to keep you informed of your account status and activities; and
10. to contact you using any of your personal information to obtain feedback about your experience of our products and services in order for us to undertake continuous improvements and to keep you informed of new features, functionality and events.

And with your permission:

11. to send you details (including by in-App messenger, post, phone, e-mail or SMS) of other products and services which we think may interest you, and send you offers and promotions unless you inform us in writing that you do not want to receive these details.

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

We may share your information with partner organisations which support any of our services including communications, to the extent that they need it to provide those support services, including:

• Card producers and Card schemes;
• Services used for credit reference agencies;
• Services that we use to verify your identity and address;
• In connection with the sale, transfer or disposal of our business, provided that we obtain assurance that they will continue to use your information substantially in accordance with this Privacy and Cookie Policy.

Additionally, any information you decide to share with members of a group will be seen by any current or future members of the group.

You have the right to opt out of our use of data as described in xi. above.

You can ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your personal data) if we intend to use your personal data for such purposes or if we intend to disclose your information to any third party for such purposes by asking that you check certain boxes on forms we use to collect your data. You can also exercise your right to ask us not to process your personal data for marketing purposes at any time by contacting us help@kroo.com.

You can inform us at any time that you no longer wish to be contacted by us or any third party whom we have instructed to do so, in relation to providing feedback on our products and services. You can exercise this right by contacting us at help@kroo.com.

In addition, we (or third parties acting on our behalf) may also store or process information that we collect about you in countries outside the European Economic Area, which may have lower standards of data protection; in which case we will ensure such processing is carried out to an equivalent standard.

We have put in place technical and organisational security measures designed to prevent the loss or unauthorised access to your personal information. However, whilst we have used our best efforts to ensure the security of your personal data, please be aware that we cannot guarantee the security of information transmitted over the internet.

Generally, we will store your information for six years after your relationship with us ends however we may in certain circumstances, including for regulatory reasons, store data for a longer period. We may also retain your information in an anonymised form - in which case the data is no longer classified as Personal Data.

Our App and Site use cookies and similar technologies to distinguish you from other users of the App and Site. This helps us to provide you with a good experience when you browse our App and Site and also allows us to improve our App and Site. By continuing to use our App or browse our Site, you are agreeing to our use of cookies and similar technologies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or mobile device when you visit a website or use an app if you agree. Cookies contain information that is transferred to the computer's or mobile device's hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our App and Site. They include, for example, cookies that for example enable you to log into secure areas of our site.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our App and Site when they are using it. This helps us to improve the way our App and Site work, for example, by remembering the user's previous interactions with and navigation around the Site and App and other technical details about the device/browser used to access the Site or App.
• Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our App and Site, the pages you have visited and the links you have followed including unique IP addresses or device identifiers associated with mobiles devices, and sites visited before or after visiting our Site. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can block cookies by activating the setting on your browser or App that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block cookies (including essential cookies) you may not be able to access all or parts of our App and Site or some features, services or activities that are available on our App and Site may be adversely affected and you may be unable to perform certain transactions, use certain functionality, and access certain content.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Your rights under the GDPR as a data subject, which apply whilst we hold or process your personal data (as defined by data protection legislation as any information relating to or that can be linked to an identifiable natural person; examples of this include but are not limited to name, location data, physical, medical, and genetic information, as well as identifiable cultural, racial, or social data) are as follows:

1. Right of access - you have a right to request a copy of the information we hold which relates to you;
2. Right of rectification - you have a right to correct any information which we hold about you where it is either inaccurate or incomplete;
3. Right to be forgotten - you have a right to ask us to delete your data from our records and those of data processors that we have instructed to process your data. This right will not apply where there are overarching legal obligations placed upon us in relation to the data, for example where we are obliged by law to keep records of transactions or to enable the prevention of financial crime.
4. Right to restrict processing - you may request that we cease use of your data for certain purposes.
5. Right of portability - you have the right to ask us to pass your personal data to another data controller
6. Right to object - you have the right to object to certain types of processing, for example direct marketing.
7. Right to object to automated processing - you have the right to object to our processing of your data by automated means, including profiling.
8. Right to judicial review - if you ask us to fulfil one of your above rights, we will do so unless we are unable to do so; in which case we will tell you the reason for this. In this case you have a right to complain to the Data Protection Officer by contacting us at dataprotection@kroo.com.

Our intention is that you should only receive marketing communications that will be useful to you and that you want to receive, so we provide you the ability to define and modify your mailing preferences online at any time including unsubscribing from all marketing communications, offers and promotions and research surveys. You can unsubscribe from any of our email programs by emailing us at help@kroo.com or by following the instructions in relation to opting out of future emails in any email you receive from us.

If you have any questions about how we collect, store and use your information, you may contact us by emailing us at help@kroo.com.