Privacy Policy – Consumer

Please read this Privacy Policy carefully before using our web app (the Services) operated by Inicio AI (“us”, “we”, or “our”).

Your privacy is important to us and we take care in how your data is used. This privacy notice tells you what we do with your personal information when you use the Budgie tool (the Services) to share your data and the choices you have associated with other organisations you owe money to.

 

Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Our contact details:

Name: Inicio AI Ltd

Budgie and MyBudgie are trading styles of Inicio AI Ltd

Registered Address: Number 3, Siskin Drive, Middlemarch Business Park, Coventry,

England, CV3 4FJ, a limited company registered in England under company number 12549674. Inicio AI Ltd is authorised and regulated by the Financial Conduct Authority.

Our Financial Services Register number is 1012328.

Email: budgie@inicio.ai

Definitions:

Budget– information including, your income (salary, pension, benefits etc), your expenditure (rent, bills, groceries etc) and what’s left each month in one place

Company – an organisation such as credit card, loan, energy or other provider who you have an existing relationship with, and you want to send them a copy of your Budget Form

Our clients – Companies who use the Budgie tool to support their customers

Information collection, use and why

Budgie is an online tool to help you understand your financial situation by completing a budget, so that you can see your income (salary, pension, benefits etc), your expenditure (rent, bills, groceries etc) and what’s left each month in one place. We can also help you to share your budget with other companies on your behalf.

If you ask us to share your budget with other companies this is known as passporting your data; and it is the regulated activity that we are authorised to undertake by the FCA.

We collect several different types of information for various purposes to provide and improve our Services to you.

Types of data collected

Personal Data

While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”).

Personally identifiable information may include, but is not limited to:

   • Contact details to allow us to identify you including any relevant account references

   • Data relating to your financial circumstances

   • Contact details and account references to allow us to share your income & expenditure with the companies you wish to disclose it to.

• Data relating to your household composition (the people you live with).

• Digital Data (for example your IP address)

We will not use your Personal Data to contact you with newsletters, marketing or promotional materials or any other information.

Special Category Data

Special category data includes:

   • Personal data revealing racial or ethnic origin

   • Personal data revealing political opinions

   • Personal data revealing religious or philosophical beliefs

   • Personal data revealing trade union membership

   • Genetic data

   • Biometric data (where used for identification purposes)

   • Data concerning health

   • Data concerning a person’s sex life

   • Data concerning a person’s sexual orientation

We will not ask directly for any special category data when you complete the form, but as a result of your answers we may capture data about your health, for example, if you disclose any benefits relating to disabilities or expenditure on health associated products such as hearing aids or glasses.

Usage Data

We may also collect information on how the Services are accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. For information about the cookies we use please visit our Cookie Policy here.

Other Data

If you have asked us to share your income and expenditure with another company, we will also ask you to confirm the company details and account information that will allow us to identify you to them.

How do we get personal information

The personal data we process is voluntarily provided to us directly by you for the following reasons:

   • To enable you to create an account and to complete an income & expenditure form.

   • To allow you to keep a record of your income & expenditure Form.

   • To tell us which companies you would like us to share your income & expenditure form with.

Use of data

Inicio AI uses the collected data for various purposes to:

   • Provide and manage your access to the Services.

   • To allow you to create a breakdown of your financial position.

   • Provide you with details of any potential benefits you may be able to claim.

   • To identify you to the companies you want us to share your Income & expenditure form with.

• Provide and maintain our Services.

• Gather analysis or valuable information so that we can improve our Services.

• Monitor the usage of our Services.

• Detect, prevent, and address technical issues.

We use anonymised data for analytical and statistical purposes to improve our understanding of how consumers use their money, and to understand where consumers are more likely to get into debt. This helps us improve our service to you and to provide services that can help companies understand their customers better. We may use third parties to assist us in this activity.

Quality of data

If you do not agree with any information displayed within your Budgie account, you should change the information and resubmit.

Legal basis for processing Personal Data under the General

Data Protection Regulation (GDPR)

Our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Inicio AI may process your Personal Data because:

   • You have given us permission to do so.

   • We need to perform a contract with you.

   • The processing is in our legitimate interests, and it is not overridden by your rights.

   • To comply with the law.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are detailed in the table below:

How we store your personal information

Your information is securely stored in the UK and complies with GDPR to ensure your data is safe and secure.

The security of your data is essential to us, and to protect your data, we take many necessary measures, including the following:

   • Data encryption

   • Intrusion Detection and Prevention

   • Access Management

We keep your data for the following time frames:

   • Five years from the submission date if you do not use our service and request deletion.

   • If you have shared your budget with a company using your Inicio AI account, you have 14 days to ask Budgie to cancel the request. After that point you must contact them directly to request that they delete your data from their systems.

   • Inicio AI will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer periods.

Transfer of data

Your information, including Personal Data, will not be transferred outside the United Kingdom – to another country or other governmental jurisdiction.

We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Disclosure of data

We share information with:

   • The companies where you have asked us to share it with them. If for some reason we cannot share your data with a company we will contact you and let you know we have not shared it.

   • Our clients, where a client has referred you to our service and they have requested a copy of your completed income & expenditure we will share this data with them. You will be advised that this is the case before you start to use this service. Please check their Privacy Policy and make sure you are comfortable with the processing they will carry out on your data.

   • Our partner, InBest.ai, will receive some non-personal data to enable them to provide details of potential benefits and financial help that you may be eligible for. We do not share any identifiable data about you and any data you share with InBest.ai after leaving our Services is not stored or accessed by Budgie.

Disclosure for law enforcement

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal requirements

Inicio AI may disclose your Personal Data in the good faith belief that such action is necessary to:

   • To comply with a legal obligation

   • To protect and defend the rights or property of Inicio AI Ltd

   • To prevent or investigate possible wrongdoing in connection with the Services

   • To protect the personal safety of users of the Budgie tool or the public

   • To protect against legal liability

Security of data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your data protection rights under the General Data

Protection Regulation (GDPR)

If you are a resident of the United Kingdom, you have certain data protection rights. Inicio AI Ltd aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

You have the following data protection rights:

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

• The right to object. You have the right to object to our processing of your Personal Data.

• The right of restriction. You have the right to request that we restrict the processing of your personal information.

• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

• The right to withdraw consent. You also have the right to withdraw your consent at any time where Inicio AI Ltd relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You are not required to pay any charge for exercising your rights. However, we have one month to respond if you make a request.

Please contact us at budgie@inicio.ai if you wish to make a request.

You have the right to complain to the Office of the Information Commissioner www.ico.org.uk

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at budgie@inicio.ai

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

More information

If you are still looking for more information, then you can contact us on budgie@inicio.ai or through the website contact form.