Privacy Policy

Introduction

Thank you for reading our privacy notice.
We respect your privacy and are committed to protecting your personal data. This
privacy notice will inform you as to how we look after your personal data and tell you
about your privacy rights and how the law protects you.

1. Important information and who we are

1.1. Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your
personal data, including any data you may provide to us directly via our website,
platform or otherwise.

It is important that you read this privacy notice together with any other privacy notice,
fair processing notice or privacy policy we may provide on specific occasions when we
are collecting or processing personal data about you so that you are fully aware of how
and why we are using your data.

1.2. Controller

TAB is an alternative finance and property investment platform which offers investors
the opportunity to make loans secured against, and equity investments into, UK
properties.

TAB is made up of several legal entities, including TAB London Limited (ICO registration
number: ZA334719), TAB London Property Limited (ICO registration number: ZA792142),
TAB Developments Limited (ICO Registration number: ZA761591) TAB PM Limited (ICO
registration number: ZB037859), Halo Capital Partners Limited (ICO Registration:
ZB621059).
This privacy notice is issued on behalf of the TAB Group so when we mention the
company , we , us or our in this privacy notice, we are referring to the relevant company
in the TAB Group responsible for processing your data.

We have appointed a data protection manager who is responsible for overseeing
questions in relation to this privacy notice. If you have any questions about this privacy
notice, including any requests to exercise your legal rights, please contact the data
protection manager using the details set out below.

1.3. Contact details

Full name of legal entity: TAB London LImited

Name or title of Data Protection Manager: Mathura Paramjorthy

Email address: help@tabhq.com

Contact address: The Grain Yard, Theobald Street, Borehamwood, WD6 4PH

Telephone number: 0208 057 9070

1.4. Changes to the privacy notice and your duty to inform us of changes

We review our use of your personal data regularly. In doing so, we can change what
personal data we collect, how we keep it and what we do with it. As a result, we may
change this notice from time to time to keep it relevant and up to date.

Any changes will be immediately posted on our websites and we recommend that you
check this page regularly to keep up to date. This version was last updated on 24 July
2023 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please
keep us informed if your personal data changes during your relationship with us.

1.5. Third party links

Our website and platform 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 website or
platform, we encourage you to read the privacy notice of every third party website you
visit.

2. The data we collect about you

2.1. Personal data

Personal data, or personal information, means any information about an individual
from which that person can be identified. It does not include data where the identity
has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which
we have grouped together follows:

● Identity Data includes first name, maiden name, last name, username or similar
identifier, National Insurance number, title, gender, date of birth and residency.
We may also collect identification documents and information (such as your
passport or driving licence) or image either a photo or video (where required as
part of our anti-money laundering checks).

● Contact Data includes current address, previous address (where required) email
address and telephone numbers.

● Financial Data includes bank details, information about your work or
profession, your financial position and history, which may include source of
funds,source of wealth, bankruptcy or insolvency filings.

● Transaction Data includes details about payments to and from you and other
details of services you have purchased from us.

● Technical Data includes cookies, internet protocol (IP) address, your login data,
browser type and version, time zone setting and location, browser plug-in types
and versions, operating system and platform and other technology on the
devices you use to access our website and platform.

● Profile Data includes your username and password, purchases or orders made
by you, your interests, preferences, feedback and survey responses.

● Usage Data includes full Uniform Resource Locators (URL) clickstream to,
through and from our website (including date and time), products you viewed or
searched for, page response times, download errors, length of visits to certain
pages, page interaction information (such as scrolling, clicks, and mouse-overs),
methods used to browse away from the page and other similar information
about how you use our website, platform and services.

● Marketing and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data
for any purpose. Aggregated Data may be derived from your personal data but is not
considered personal data in law as this data does not directly or indirectly reveal your
identity. For example, we may aggregate your Usage Data to calculate the percentage of
users accessing a specific website or platform 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 notice.

We do not generally 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). We may however, collect Special Categories of
Personal Data such as information about your health, including any medical condition
to allow us to help vulnerable customers. We will only collect the minimum amount of
information required.

Where permitted by law we may process information about criminal convictions,
criminal offences, related security details, alleged offences including unproven
allegations, spent or previous convictions, or other details provided in relation to a
criminal reference check or similar.

2.2. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we
have with you and you fail to provide that data when requested, we may not be able to
perform the contract we have or are trying to enter into with you (for example, to
provide you with goods or services). In this case, we may have to cancel a product or
service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

3.1. Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by
corresponding with us by post, phone, email or otherwise. This includes personal data
you provide when you:

● avail of our services;

● create an account on our website or platform;

● update your information (such as when you change your address)

● subscribe to our service or publications;

● request marketing to be sent to you;

● enter a promotion or survey; or

● give us some feedback.

3.2. Automated technologies or interactions

As you interact with our website and platform, we may automatically collect Technical
Data about your equipment, browsing actions and patterns. We collect this personal
data by using cookies, server logs and other similar technologies. We may also receive
Technical Data about you if you visit other websites employing our cookies. We will ask
you to consent to our use of cookies when you first visit our website. You can reset your
cookie preferences as part of our Cookie Policy https://tabhq.com/cookie-policy

3.3. Third parties or publicly available sources

We may receive personal data about you from various third parties and public sources.

1. Technical Data from the following parties:

○ analytics providers;

○ advertising networks; and

○ search information providers.

2. Contact, Financial and Transaction Data from providers of technical, payment
and delivery services.

3. Identity and Contact Data from data brokers or aggregators.

4. Identity, Contact and Financial Data from publicly available sources such as
Companies House, the Electoral Register and HM Land Registry.

5. Identity, Contact and Financial Data from AML / anti-fraud and Credit Reference
Agencies

6. Identity, Contact, Financial, Transaction Data from people acting on your behalf.
This could be from your solicitor, a broker, as part of a joint application on an
account (e.g. joint, partnership or corporate applications) or anyone nominated
to act on your behalf, including a Power of Attorney. If someone acting on your
behalf provides this information, we will record what’s been provided and who
gave it to us.

7. In the event that you are providing information about another individual, you
must make sure that you have their permission before you share their data with
us or make decisions on their behalf about how we use their data, including
credit checks. Please make them aware of this privacy notice.

8. Sometimes we may use other data in addition to this, for example we may use
data that you have made public such as when you reference or interact with us
via social media.

4. How we use your personal data

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

● Where we need to perform the contract we are about to enter into or have
entered into 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.

Generally we do not rely on consent as a legal basis for processing your personal data
other than in relation to sending third party direct marketing communications to you via
email or text message. You have the right to withdraw consent to marketing at any time
by emailing help@tabhq.com .

5. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use
your personal data, and which of the legal bases we rely on to do so. We have also
identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground
depending on the specific purpose for which we are using your data. Please contact us
by emailing help@tabhq.com if you need details about the specific legal ground we are
relying on to process your personal data where more than one ground has been set out
in the table below.

Purpose/Activity Type of data Lawful basis for processing
including legitimate interest

To register you as a new
customer (investor or
borrower) introducer or
broker. This may include
carrying out checks with
fraud prevention, credit
and tracing agencies.

(a) Identity

(b) Contact

(a) Performance of a contract
with you

(b) Necessary to comply with a
legal or regulatory obligations
(prevention and detection of
crime, to comply with laws
relating to money laundering,
fraud, terrorist financing,
bribery and corruption)

(c) It is in our legitimate
interest to manage our risk
and determine what products
and services we can offer and
the terms of those products
and services.)

To process your orders
or requests and to
deliver services to you
including:

(a) Manage payments,
fees and charges

(b) Collect and recover
money owed to us

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing
and
Communications

(a) Performance of a contract
with you

(b) Necessary to comply with a
legal or regulatory obligation
(prevention and detection of
crime, to comply with laws
relating to money laundering,
fraud, terrorist financing,
bribery and corruption

(c) Necessary for our
legitimate interests (to
manage our risk, determine
what products and services
we can offer and the terms of
those products and services
and recover debts due to us.)

To manage our
relationship with you
which will include:

(a) Notifying you about
changes to our terms or
privacy notice

(b) Asking you to leave a
review, take a survey or
provide other feedback

(a) Identity

(b) Contact

(d) Marketing
and
Communications

(a) Performance of a contract
with you

(b) Necessary to comply with a
legal or regulatory obligations

To determine whether or
not to offer a loan to a
borrower

(a) Identity

(b) Contact

(d) Transaction

(a) Performance of a contract
with you

(b) Necessary to comply with a
legal or regulatory obligation
(prevention and detection of
crime, to comply with laws
relating to money laundering,
fraud, terrorist financing,
bribery and corruption

To manage any loan
through to redemption

(a) Identity

(b) Contact

(d) Transaction

(a) Performance of a contract
with you

(b) Necessary for our
legitimate interests (to
establish whether we can
enter into a contract with you)

To manage any
relationship with
intermediaries including
a record of introductions,
payments made and
other relevant
information appropriate
to managing the
relationship

(a) Identity

(b) Contact

(a) Necessary to comply with a
legal or regulatory obligation
(prevention and detection of
crime, to comply with laws
relating to money laundering,
fraud, terrorist financing,
bribery and corruption

(b) Necessary for our
legitimate interests (for
running our business)

To manage business
relationships with our
professional advisers,
contractors and third
party providers

(a) Identity

(b) Contact

Necessary for our legitimate
interests (for running our
business)

Share information with
your broker about your
application or the
performance of your
loan

(a) Identity

(b) Contact

(d) Transaction

Necessary for our legitimate
interests (for running our
business)

To enable you to
complete a survey or to
provide other feedback

(a) Identity

(b) Contact

(d) Usage

(e) Marketing
and
Communications

Necessary for our legitimate
interests (to study how you
use our products/services, to
develop them and grow our
business)

To administer and
protect our business, our
website and our platform
(including
troubleshooting, data
analysis, testing, system
maintenance, support,
reporting and hosting of
data)

(a) Identity

(b) Contact

(a) Necessary for our
legitimate interests (for
running our business,
provision of administration
and IT services, network
security, to prevent fraud and
in the context of a business
reorganisation or group
restructuring exercise)

(b) Necessary to comply with a
legal obligation

To use data analytics to
improve our website,
platform, services,
marketing, broker and
customer relationships
and experiences

(a) Technical

(b) Usage

Necessary for our legitimate
interests (to define types of
broker and customers for our
services, to keep our website
and platform updated and
relevant, to develop our
business and to inform our
marketing strategy)

To deliver relevant
website content and
advertisements to you
and measure or
understand the
effectiveness of the
advertising we serve to
you

(a) Identity

(b) Contact

(d) Usage

(e) Marketing
and
Communications

(f) Technical

Necessary for our legitimate
interests (to study how you
use our products/services, to
develop them, to grow our
business and to inform our
marketing strategy)

To make suggestions and
recommendations to you
about services that may
be of interest to you

(a) Identity

(b) Contact

(d) Usage

(e) Profile

Necessary for our legitimate
interests (to develop our
services and grow our
business)

Share information with
any recruitment agency
or search provider about
your job application

(a) Identity

(b) Contact

Necessary for our legitimate
interests (for running our
business)

To consider any
application for a job,
including CVs, and
whether to progress it

(a) Identity

(b) Contact

Necessary for our legitimate
interests (for running our
business)

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 via the Support section of our website.

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

6. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly
around marketing and advertising.

6.1. Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on
what we think you may want or need, or what may be of interest to you. This is how we
decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information
from us or purchased goods or services from us or if you provided us with your details
when you entered a competition or registered for a promotion and, in each case, you
have not opted out of receiving that marketing.

6.2. Third party marketing

We will get your express opt-in consent before we share your personal data with any
company outside our group of companies for marketing purposes.

6.3. Opting out

You can ask us or third parties to stop sending you marketing messages at any time by
contacting us by emailing help@tabhq.com.

Where you opt out of receiving marketing messages, this will not apply to personal data
provided to us as a result of a product/service purchase, warranty registration,
product/service experience or other transactions.

7. Change of purpose

We will only use your personal data for the purposes for which we collected it, unless
we reasonably consider that we need to use it for another reason and that reason is
compatible with the original purpose. If you wish to get an explanation as to how the
processing for the new purpose is compatible with the original purpose, please contact
us by emailing help@tabhq.com.

If we need to use your personal data for an unrelated purpose, we will notify you and
we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or
consent, in compliance with the above rules, where this is required or permitted by law.

8. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the
purposes set out in the table in paragraph 5 above.

8.1. Internal Third Parties

Other companies in our corporate group who may act as joint controllers or processors
and who may be based inside or outside the UK.

8.2. External Third Parties

These are service p roviders who may act as processors based inside or outside the UK
and who provide IT, system administration and other services.

8.3. Sharing with CRA’s

In order to process your application, we will perform credit and identity checks on you
with one or more Credit Reference Agencies (CRAs). We may also carry out further
periodic searches at CRA’s to allow us to manage your account with us.

To do this, we will supply your personal information to CRAs. This will include your
name, date of birth and residential address. It may also include additional information
such as your salary, previous residential addresses and other information you provide
as part of your credit application.

The CRAs will match this information to the records they hold about you, and provide in
return, both public information (including the electoral register) and shared credit
information in relation to your financial situation and financial history.

CRA’s will supply to us both public (including the electoral register) and shared credit,
financial situation and financial history information and fraud prevention information.

We will use this information to:
● Assess your creditworthiness and whether you can afford to take the product;
● Verify the accuracy of the data you have provided to us;
● Prevent criminal activity, e.g fraud and money laundering;
● Manage your account(s);
● Trace and recover any debts; and
● Ensure any offers provided to you are appropriate to your circumstances.

We will continue to exchange information about you with CRA’s while you have a
relationship with us. We will also inform the CRA’s about your settled accounts. If you

borrow and do not repay in full or on time, CRA’s will record the outstanding debt. This
information may be supplied to other organisations by CRA’s

When CRA’s receive a search from us they will place a search footprint on your credit file
that may be seen by other lenders.

If you are making a joint application, or tell us that you have a spouse of a financial
associate, we will link your records together, so you should make sure you discuss this
with them, and share with them this information, before lodging the application. CRA’s
will also link your records together and these links will remain on your and their files
until such time as your partner successfully files for a disassociation with the CRA’s to
break the link.

The identities of the CRA’s, their role also as fraud prevention agencies, the data they
hold, the ways in which they use and share personal information, data retention periods
and your data protection rights with the CRA’s are explained in more detail below

● SmartSearch: https://www.smartsearchsecure.com/dpa

● Plaid https://plaid.com/legal/#end-user-privacy-policy

● Equifax: www.equifax.co.uk/crain

We share your name, email address and the product/service you purchased (as
obtained during the order process) with Feefo, who will send you an email on our behalf
asking you to complete a review. Our legal basis for doing this is our legitimate interest
in asking for feedback in order to improve our products and services.

● Please see Feefo’s privacy policy for more information on how Feefo uses the
reviews you submit: https://www.feefo.com/en/business/privacy-policy

We may also share your personal data with:

● Professional advisers who may act as processors including lawyers, bankers,
auditors, valuers and insurers based inside or outside the UK who provide
consultancy, banking, legal, insurance and accounting services.

● Brokers or advisors about your application or the performance of your loan
and/or investment.

● HM Revenue & Customs, regulators, law enforcement and other authorities who
may act as processors based inside or outside the UK who require reporting of
processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it
in accordance with the law. We do not allow our third party service providers to use
your personal data for their own purposes and only permit them to process your
personal data for specified purposes and in accordance with our instructions.

8.4. Other

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 notice.

9. International transfers

TAB is based in the United Kingdom. So me of our external third parties may be based
outside the UK so the processing of your personal data may 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. The UK Government
formally confirmed in the UK Data Protection Act 2018 that the EEA is adequate
for personal data flows from the UK without the need for additional safeguards,
including Standard Contractual Clauses.

● Where we use certain service providers, we may use specific contracts approved
by the European Commission which give personal data the same protection it
has in Europe.

Please contact us by emailing help@tabhq.comif you want further information on the
specific mechanism used by us when transferring your personal data out of the UK.

10. Data security

We have put in place appropriate security measures to prevent your personal data from
being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents,
contractors and other third parties who have a business need to know. They will only

process your personal data on our instructions and they are subject to a duty of
confidentiality.

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

11. Data retention

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

To determine the appropriate retention period for personal data, we consider the
amount, nature, and sensitivity of the personal data, the potential risk of harm from
unauthorised use or disclosure of your personal data, the purposes for which we
process your personal data and whether we can achieve those purposes through other
means, and the applicable legal requirements.

By law we have to keep basic information about our borrowers and investors. (including
Contact, Identity, Financial and Transaction Data) for at least six years after they cease
being a borrower or investors for tax purposes. Note that we may need to retain
information for longer periods in order for defence of legal claims or litigation – such as
recovery of an advance.

Details of other retention periods for different aspects of your personal data are
contained in our retention policy which you can request from us by contacting us by
emailing help@tabhq.com.

In some circumstances you can ask us to delete your data and in some circumstances
we may 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.

12. Your legal rights

You have the right to:

● 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: (a) if you want us to establish the data’s accuracy; (b) where our use of
the data is unlawful but you do not want us to erase it; (c) 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 (d) 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 services to you. We will advise
you if this is the case at the time you withdraw your consent.

● Request human intervention. Automated decision-making takes place when
an electronic system uses personal information to make decisions without
human intervention. At present, there are no fully automated decision making

or profiling systems in use within TAB. This means that this right does not
currently apply to any processing activities.

● Make a complaint. You have the right to make a complaint at any time to the
Information Commissioner’s Office (ICO), the UK supervisory authority for data
protection issues at www.ico.org.uk , by telephone on 0303 123 1113, or by
writing to them at Information Commissioner’s Office, Wycliffe House, Water
Lane, Wilmslow, SK9 5AF. We would, however, appreciate the chance to deal with
your concerns before you approach the ICO so please contact us in the first
instance.

13. No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the
other rights). However, we may charge a reasonable fee if your request is clearly
unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your
request in these circumstances.

14. What we may need from you

We may need to request specific information from you to help us confirm your identity
and ensure your right to access your personal data (or to exercise any of your other
rights). This is a security measure to ensure that personal data is not disclosed to any
person who has no right to receive it. We may also contact you to ask you for further
information in relation to your request to speed up our response.

15. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take
us longer if your request is particularly complex or you have made a number of
requests. In this case, we will notify you and keep you updated.

If you wish to exercise any of the rights set out above, please email us at
help@tabhq.com .