Little Steps Financing: Privacy Policy

1.   Introduction

Little Steps Financing Limited (collectively referred to as “Little Steps Financing”, “we”, “us” or “our” in
this privacy policy) is committed to protecting and respecting your privacy. This privacy policy, together with
any agreement you enter into with us, details how we collect and use your personal data as well as your privacy
rights and how the law protects you.

Purpose of this privacy policy

This privacy policy aims to give you information on how Little Steps Financing collects and processes your
personal data through your use of this website and our services, including any data you may provide through this
website when you apply for financing, and each time you use our services.

It is important that you read this privacy policy together with any other privacy policy or fair processing
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. This privacy policy supplements other notices and
privacy policies and is not intended to override them.

Controller

Little Steps Financing Limited is the controller and responsible for your personal data.

The childcare providers that we work with are independent of Little Steps Financing and may have their own
privacy policies which are different from ours.

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

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy
manager in the following ways:

Full name of legal entity: Little Steps Financing Limited

Email address: support@littlestepsfinancing.co.uk

Postal address: 7 Brymay Close, London, England, E3 2SY United Kingdom

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 (www.ico.org.uk); however, we would appreciate the chance to
deal with your concerns before you approach the ICO so please contact us in the first instance.

The ICO’s address is : Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9
5AF, Helpline number: 0303 123 1113

Changes to the privacy policy and your duty to inform us of any changes to your personal
information

We keep our privacy policy under regular review.

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.

2.   The data we collect about you

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 as follows:

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data could be derived from your personal data but is not considered personal data in law as this data
will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data and
Transaction Data and (a) use it for internal management purposes, (b) share it with current or prospective
childcare providers, and (c) to calculate the percentage of users accessing a specific website 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 policy.

We do not 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). Nor do we collect any information
about criminal convictions and offences.

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 our services). In this case, we may have to cancel a 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:

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 obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get
your consent before sending direct marketing communications to you via email or text message. You have the right
to withdraw consent to marketing at any time by contacting us.

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 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.

Marketing

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

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 products, 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 requested to use
our services and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing
purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website
and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links
on any marketing message sent to you, by contacting us at any time.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access
cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible
or not function properly.

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.

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.

5.   Disclosures of your personal data

We will share your personal data with the parties set out below for the purposes set out in the table above.

• Childcare Providers – we may share your Identity and Transaction Data with Childcare
  Providers in order to process your purchase and refunds.
• Credit reference agencies – In order to process your application we will supply some of
  your personal information to TransUnion International UK Limited, which is a credit reference agency
  providing services such as credit risk and affordability checking, fraud prevention, anti-money
  laundering, identity verification and tracing.

TransUnion will use your personal information to provide services to us and its other clients. We use their
services in order to assess your creditworthiness and product suitability, check your identity, manage your
account, trace and recover debts and prevent criminal activity such as fraud and money laundering. More
information about TransUnion and the ways in which it uses and shares personal information can be found in its
privacy notice at https://www.transunion.co.uk/CRAIN.

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

• Credit reference agencies – we may share your Identity, Financial and Transaction Data
  with credit reference agencies where you are late in repaying us.
• Service providers such as professional advisers (e.g. lawyers, accountants),
  advertising service providers, web- and app-hosting services, website optimisation services, website
  usage services, email service provision, mobile push notification services, data management platform
  provision, customer relationship management services, marketing tracking partners, messaging services,
  social media platforms, online and offline marketing services, research and profiling services.
• Our affiliates and partners involved in transactions, making Funds available, and
  providing cashback.
• HM Revenue & Customs, regulators and other authorities acting as processors or
  joint controllers based in the United Kingdom who require reporting of processing activities in certain
  circumstances.
• 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 policy.

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.

6.   International transfers

Your personal data may be transferred to, and processed in, a destination outside of the UK for example when we
use a supplier or subcontractor located outside of the UK.

We ensure that an adequate level of protection is maintained, and that suitable safeguards are adopted in line
with applicable UK data protection legislation requirements, such as the UK GDPR, when we transfer your data
outside of the UK. These safeguards consist of ensuring that the third country or state at hand is subject to an
adequacy decision by UK authorities or by implementing so-called standard contractual clauses originating from
the European Commission.

7.   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.

8.   Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected
it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting
requirements. We may retain your personal data for a longer period in the event of a complaint or if we
reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and
Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will 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.

9.   Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You
have the right to:

• Your right of access – 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.
• Your right to rectification – 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.
• Your right to erasure – 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.
• Your right to object to processing – 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.
• Your right to restriction of processing – 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:
• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• 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.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate
  grounds to use it.
• Your right to data portability – 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.

If you wish to exercise any of the rights set out above, please contact us.

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
could refuse to comply with your request in these circumstances.

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month
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.

10.   Glossary

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.

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

Childcare Provider means the nursery to whom we pay, on your behalf, the childcare costs for
the month specified in the Application Form;

Little Steps Financing, we, our, or us means Little Steps Financing Limited;