Privacy Policy

By registering with Klink App Limited you are entrusting us with your personal data. Your privacy is protected by law, and it is also protected by our privacy policies. This page gives you an idea of how we use your data and the safeguards we put in place to protect it.

You can contact our voluntarily appointed Data Protection Officer at [email protected]. If you have any concerns or wish to exercise your rights or you can write to us at LABS Atrium, Chalk Farm Road, London, United Kingdom, NW1 8AH.

Our Promise:

When you sign up to Klink App, you will learn about your home buying goal and find out ways to get there faster by following spending insights and earning rewards based on improving your financial health. To make this as relevant to you we will need data about you and your circumstances and in some cases share this with partners.
We promise to respect your rights and be transparent with you in what we hold about you and who we share your data with so that you can exercise your rights should you wish to.

Your Rights:

You may have the following rights over any data we hold about you:

• Right to object to processing at any time
• Right to opt out of marketing at any time
• Right to have inaccurate data corrected
• Right to erasure of personal data from our database
• Right to export of personal data

You can read more about your rights here.
If you would like to uphold your rights then please contact our Data Protection Officer at [email protected].
If you are dissatisfied with our response you also have the right to lodge a complaint with the Data Protection Authority. This can be done at https://ico.org.uk/concerns.

Collecting Data:

We collect information about you in two key ways:

• From you – The more information you provide the better the insights we can provide and the easier it is to align your circumstances with our partners. For example, you may share information for us to assess your suitability for a mortgage; banking transactions; car and other insurances or other data associated with a product you express an interest in or you signed up for our newsletter, or met one of us at events or meetings or have approached us on social media;
• From others – This is data about you that we may hold from credit rating agencies, mortgage providers, especially if you have had a mortgage offer rejected, mortgage brokers and their agents or from proactive marketing activity and referrals. We may also receive data from other partners we use for prizes, competitions, and offers.

We try and minimise the personal data held on you and only in line with the purposes of our services. This will typically include:

• Identity Data including your first name, last name, associated others with you, such as your partner or next of kin, current and previous addresses and date of birth.
• Contact Data including email address, telephone numbers, home address, employer address, employer name.
• Account Data including information you give us when you register your account.
• Financial Data including account and card payment details, bank income, savings, spending and credit history and verification of this data (see below).
• Technical Data including internet protocol (IP) address, browser type and version, location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the website and services.
• Application and Retailer Data including details about your living situation, insurance policies, property preferences and housing history as well as proof of purchases you may need to share with us as part of our services.
• Usage Data including information about how you use our app, website, and services.
• Marketing and Communications Data including your consent, if required, to get updates from us.
• Research Data including third party consumer research and surveys that we manage.

Our website and other materials sent to you may contain links to other third party websites. We may also offer buttons to social media that link to third party services. We’re not responsible for the content or the data privacy these sites provide through their tools or sites.

Special Categories of Data

In some cases, we may need to process “special categories” of your personal data. This data requires a higher level of governance. We will not usually ask for this type of data, however, if you belong to a union for example and link your accounts and spending through the app or you provide us with other special category data, for example, to let us know that you’re vulnerable we will be processing this data. This data will not be used for any other purpose whilst identified to you and by using the app you acknowledge and agree that this processing is done with your consent.

We will only ask about special categories of data if we think it is causing a difficulty with your account. We will always explain why we are asking for it and how we might use it.

Cookies Use

Our App uses cookies. Cookies allow us to recognise a user’s device and enhance your user experience while helping us with analytics, fraud detection and advertising. For more information see: https://www.allaboutcookies.org/

You acknowledge and agree that by using the App you give us the consent to use cookies for these purposes.
The cookies we use are as follows:

• Mixpanel
• Google Analytics
• Segment
• AppsFlyer
• Firebase
• Pushwoosh
• Hotjar

Securing your Data

All our processes are subject to policies and procedures to ensure that your data privacy and security is upheld at all times. Data is processed/stored locally and on encrypted third party hosted cloud services. We use several different platforms to deliver our services including Microsoft, Box, Monday, Heroku, Google, Segment, AppsFlyer, Firebase, Pushwoosh, and Hotjar.
As such, some data will either be in UK, EEA/EU data centres or on US based servers that have demonstrated strong Data Security. We may also process your data in countries outside the UK or European Union from time to time in other aspects of our business.
Further to Section 119A of the Data Protection Act 2018 and noting Case C-311/18 in the European Court of Justice, if your data is transferred or processed outside of the UK or EEA we ensure the safeguards of International Data Transfer Agreements (IDTAs) or Addendums are enforced. Where this is not possible, we ensure that European Standard Contractual Clauses are entered.
We regularly review suppliers for data security compliance to ensure your data is safe and track where your data is held. We will never ask you for your username or password for the App or ask you for any credentials for other applications or websites.

What we use your Data for

We use your data primarily to manage your financial milestones and set profiles aligned with these goals. We want Klink App to be your central hub for your financial journey. For example, depending on the information you provide and to get the best out of the service we may use your data to:

• Carry out analysis of spending habits so that we can help you unlock insights into how you can save money;
• Managing monthly subscription services to the Klink App;
• Help to build personalised spending missions so you can achieve your financial goals sooner;
• Assess your mortgage suitability and whether you can afford to take a product;
• Align services that may benefit you with our partners;
• Ensure any offers provided to you are appropriate to your circumstances;
• Administer quiz responses, competitions, referrals and award of points;
• Prevent criminal activity, e.g. fraud and money laundering;
• Link to your various financial accounts with an Open Banking provider;
• Provide marketing information about us and our services (you can unsubscribe any time);
• Let you know about any changes to the website and service;
• Collect for analytics purposes information about your journey with us including aggregating this data;
• Provide in-app advertising with our partners;
• Anonymise your data for statistical analysis for use internally and to enable us to provide industry insights to a wider audience (for example to highlight spending trends)

Calls may be recorded for information holding, quality and training purposes.

Legal Basis for Processing your Data

Your data is only processed based on a defined legal basis. These are:

• Consent – For most of the data you provide us directly we ask for your consent to process it for the purposes of fulfilling our service to you. This consent is asked for when you sign up for our app and includes your identity and financial information. We also use it for our marketing communication with you.
• Legitimate Interest – We may require to use some of your data for our Legitimate Interests, for example, data analytics, aligning your missions with our partners and making recommendations to you.
• Legal Obligation – We may need to process some of your data for legal obligations such as transactions with us.

Credit Reference Checks

As part of our Services, we may be required to carry out credit reference checks from Credit Reference Agencies (CRA). If we need this information, we will also inform you and gain your consent should a “hard search” be required.

We use TrueLayer Open Banking APIs to connect your financial accounts when you add them to the App. TrueLayer is a secure financial technology provider that connects your bank account to our service for seamless and safe transactions. To find out more information, you can view the TrueLayer Terms of Service and TrueLayer Privacy Policy.

Joint Goals

If your mission is to purchase a home and this will be based on a joint application we will not ask for any details of the joint applicant except for the income of that person.

Sharing your Data

So that we can give you the best service, we may need to share your personal information including affordability and mortgage readiness data with other trusted third parties in addition to Credit Reference Companies. For example, we may share your information with other entities that have partnerships Klink App including:

• Mortgage Providers and brokers where you would like to receive mortgage offers.
• Insurance Partners where we may refer you to for products and services for which you would like to have competitive quotes.
• Retailers that provide cashback, prizes or other benefits that require us to share your data for validation, engagement and analysis purposes. This may include grocery, leisure and other retailers.
• Where we are legally obligated to share your data.
• Between Klink App Limited associated companies including Kollitom Ltd.

All those we share data with are separate controllers to us and they may market services to you separately from Klink App. When this occurs, you should uphold your rights directly with them.

Automated Decisions

When you sign up for the Klink App you accept and consent that due to the complexity of the Klink App we may use AI and algorithmic models to profile your circumstances and data to align it with products and services or let you know if an application is likely to be successful or not and use such profiling to make an automated decision. For example, to judge if you would be accepted for a credit card or other financial product as permitted under Article 22 2(a) of the UK GDPR.

Klink App will only use appropriate mathematical or statistical procedures for the profiling, implement technical and organisational measures appropriate to ensure, in particular, that factors which result in inaccuracies in personal data are corrected and the risk of errors is minimised, secure personal data in a manner that takes account of the potential risks involved for the interests and rights of the data subject, and prevent, inter alia, discriminatory effects on you.

If you disagree with our conclusion you may appeal to us at any time for us to review by non-automated means. Typically this will involve an analysis of your spend and ensure the transaction descriptions are aligned with the correct category.

Retaining your Data

Dependant on the data you provide us and for what purpose it is provided we may need to retain your data for up to 6 years after you are no longer a customer of us. If you wish to find out more about your specific data retention, please contact us.

Data Permissions

Every marketing email sent from us allows you to opt out of receiving further emails from us, except for the purposes of fulfilling any contractual arrangements.
You can also contact us at the email address above and request to opt out, view, export or delete your data.
We allow you to delete all your data through the App should you so wish. We will only retain data if we are legally obliged to.

Legal Compliance

We seek to uphold our legal obligations as covered by the Data Protection Act 2018 and the General Data Protection Regulation 2016. Our Data Protection Authority is designated as the Information Commissioners Office (ICO).
No one under the age of 18 is permitted to use our application and we do not knowingly obtain data of anyone under the age of 18. If this has inadvertently happened please contact our DPO immediately at [email protected].
This Privacy Policy is reviewed on a regular basis and was last reviewed on the 7/5/2024.