Investor privacy notice

First Issued: 1 November 2021

Last updated: 30 September 2022

Version 1.2

Introduction

Kroo Bank Ltd (“we“, “us“, and “ours” or “Kroo”) respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. If you have any questions or concerns about our use of your personal information please contact us using the contact details provided at the end of this Privacy Notice.


What does Kroo do?

Kroo is a company incorporated in England and Wales. It is authorised as a bank by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority (firm registration number 953772). Kroo is separately registered as a payment services / electronic money agent of Modulr FS Limited under registration number 902797 and also acts as an electronic money agent of Payrnet Ltd. At present Kroo provides a prepaid debit card to existing customers, and a banking app that enables customers to set up social groups of friends, flat mates, colleagues, family etc and split bills and settle directly with each other. It will shortly be offering a current account.

Information that you provide voluntarily

We ask you to provide certain information voluntarily. The types of information we ask you to provide, and the reasons why we ask you to provide it, include:

  • Types of personal information

    Why we collect it

    • Name and contact details such as address, telephone number and email.

      For the purpose of communicating with you in relation to fundraising and if you become a shareholder. Also to carry out ID and other due diligence checks on investors.

    • Personal data you may provide in communications.

      Where we are communicating with you, you may provide personal data, for example in connection with an enquiry or complaint.

    • Age/date of birth.

      To verify we are legally permitted to enter into a contract with you. Also to carry out due diligence checks on you, where a date of birth may help to distinguish you from individuals with the same or similar name.

    • Information such as copies of passports, driving licenses, or other government-issued IDs, passport numbers, signatures, tax identification numbers and utility bills.

      For identification purposes as part of our due diligence checks.

    Information that we collect automatically

    If you use a mobile phone or other similar electronic device to communicate with us, we may also collect certain information automatically from your device. This will include your IP address.

    Information that we obtain from third party sources

    From time to time, we may receive personal information about you from third party sources (including World Checking services), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

    The types of information we collect from third parties includes:

  • Types of personal information

    Why we collect it

    • Information on source of an investor’s or potential investor’s wealth.

      As part of our anti money laundering due diligence checks.

    • Records of open source searches carried out on investors and potential investors. This could include sources that refer to court judgments, criminal convictions, allegations made in relation to an investor or potential investor.

      As part of the due diligence checks we are required to make on potential investors.

    • Information about claims and proceedings (or potential claims and proceedings) by or against you.

      To identify, exercise and defend contractual and other legal rights.

    In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.


    Who does Kroo share my personal information with?

    We may disclose your personal information to the following categories of recipients:

    to our third party services providers and partners who provide data processing services to us, or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information, for example our solicitors provide a company secretarial service to us and maintain our share register;to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation including anti-bribery and corruption regulations and anti-money laundering laws, (ii) to exercise, establish or defend our legal rights, (iii) for fraud prevention purposes and (iv) to protect your vital interests or those of any other person;to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;to any other person with your consent to the disclosure.


    How does Kroo keep my personal information secure?

    We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include:

    physical access control systemsa physical security presencelogical access controls (such as passwords)perimeter security systems (such as firewalls)vulnerability management


    International data transfers

    Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

    Specifically, our servers are hosted by AWS in Ireland. Our third party service providers in relation to company secretarial matters, such as the maintenance of our REgister of Shareholder are based in the UK. This means that when we collect your personal information we or our data processors are unlikely process it outside the UK or the European Economic Area (EEA) except where you yourself are resident outside the UK or EEA and we need to file returns with the authorities in your country of residence, in particular the USA and Canada.

    If we entered into contractual relationships under which we might transfer your data outside the UK or EEA we would take appropriate safeguards to require that your personal information remained protected in accordance with this Privacy Notice. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between us and our data processors, which require such processors to protect personal information they process outside the EEA in accordance with European Union data protection law.

    Our Standard Contractual Clauses can be provided on request.


    Data retention

    We retain personal information we collect from you where we have an ongoing legitimate business need to do so, for example, to provide you with notices we wish to or need to give to shareholders or to comply with applicable legal, tax or accounting requirements.

    When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.


    Automated decision-making

    Automated decisions are decisions concerning you which are made automatically on the basis of a computer determination (using software algorithms), without human review. We do not use automated decision-making in relation to investors.


    Your data protection rights

    You have the following data protection rights:

    If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided at the end of this Privacy Notice.In addition, if you are a resident of the United Kingdom or the European Union, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details at the end of this Privacy Notice.You have the right to opt-out of marketing communications we send you at any time by contacting us using the contact details at the end of this Privacy Notice.Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact the UK’s Information Commissioner’s Office (ICO) www.ico.org.uk.

    We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.


    Updates to this Privacy Notice

    We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

    You can see when this Privacy Notice was last updated by checking the date displayed at the top of this Privacy Notice.


    How to contact us

    If you have any questions or concerns about our use of your personal information, please contact our Data Protection Officer using the following details: dataprotection@Kroo.com.