Earnly (“Earnly”, “we”, “us”, “our”,) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how Earnly collects, uses, stores, shares, and otherwise processes information relating to an identified or identifiable individual (“Personal Data”), as well as the rights available to you under applicable UK data protection law.

If you have any questions or concerns about how Earnly uses your Personal Data, or if you wish to exercise any of your privacy rights, including your right to object where applicable, please contact us using the details provided in the How to Contact Us section below.

Earnly provides a digital platform designed to help individuals and businesses better understand their finances and tax obligations by connecting relevant financial data sources, including bank account data made available through Open Banking and, where applicable, connected accounting or financial platforms. Earnly uses this information to provide features such as transaction categorisation, financial insights, tax estimates, alerts, forecasts, and related functionality through its website, applications, and associated services (together, the “Services”).

This Privacy Policy applies only in relation to Earnly’s operations in the United Kingdom and is intended to reflect Earnly’s obligations under the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018, and other applicable UK privacy laws.

We recommend that you read this Privacy Policy in full so that you understand what Personal Data Earnly collects, how Earnly uses it, when Earnly shares it, and the rights and choices available to you.

1. Scope of this Privacy Policy

This Privacy Policy explains how Earnly processes Personal Data collected from or about you through:

• the Earnly website, including www.earnly.co.uk;

• Earnly’s web and mobile applications;

• Earnly’s customer support channels;

• Earnly’s communications with you; and

other interactions you have with Earnly in connection with the Services.

This Privacy Policy applies where Earnly acts as a data controller, meaning Earnly determines the purposes and means of processing your Personal Data.

Where Earnly processes data on behalf of a business customer, accountant, financial adviser, or another organisation using Earnly’s Services for its own purposes, that organisation may act as the data controller for certain processing activities. In those circumstances, the relevant agreement with that organisation will govern the processing relationship, and any questions relating to that organisation’s use of your data should be directed to them.

This Privacy Policy does not override any separate contractual terms, data processing agreements, or service-specific terms that may apply to your use of the Services.

2. Personal Data Earnly Collects

In the course of operating its business and providing the Services, Earnly may collect Personal Data in a number of ways and from a number of sources.

2.1 Information You Provide Directly

Earnly collects Personal Data directly from you when you create an account, connect services, subscribe to communications, contact Earnly, request support, or otherwise interact with Earnly.

This may include:

a) Account Information

When you register for an account or use the Services, Earnly may collect:

• your full name;

• email address;

• telephone number, where provided;

• login credentials;

• business information, where relevant;

• account preferences;

• communication preferences;

• subscription and billing details;

• transaction history with Earnly.

b) Customer Support and Communication Information

If you contact Earnly directly, submit a support request, complete a form, respond to a survey, or otherwise communicate with Earnly, Earnly may collect:

• your name;

• contact details;

• the contents of your messages;

• attachments or supporting information you provide; and

• records of correspondence and support interactions.

c) Marketing and Engagement Information

Where you request information from Earnly, download materials, subscribe to updates, engage with campaigns, or interact with Earnly on social media, Earnly may collect:

your contact details;

• your business or professional details where relevant;

• marketing preferences; and

• records of your interactions with Earnly’s emails, website, or campaigns.

2.2 Information Earnly Collects Automatically

When you visit Earnly’s website or use the Services, Earnly may collect certain information automatically from your device or browser.

This may include:

a) Log Data

• IP address;

• browser type and version;

• device identifiers;

• pages viewed;

• date and time of access;

• referring pages and navigation paths; and

• information about errors, crashes, or diagnostics.

b) Usage Data

• how often you access the Services;

• features you use;

• time spent on particular pages or functions;

• clickstream and interaction data;

• session activity; and

• general patterns of use.

c) Cookie and Similar Technology Data

Earnly uses cookies, pixels, scripts, local storage, and similar technologies to support the operation of the Services, enhance your experience, measure performance, and understand usage. For more information, please refer to Earnly’s Cookie Policy.

d) Device Information

• operating system;

• device type;

• browser settings;

• language settings;

• app version; and

• device model and network information.

2.3 Financial and Connected Account Data

Where you choose to use features involving connected financial data, including Open Banking or integrations with third-party financial software, Earnly may collect or receive:

• account identifiers;

• account balances;

• transaction history;

• payment references;

• merchant information;

• incoming and outgoing payment data;

• categorised income and expense data; and

• linked business or tax-related financial records.

Earnly only accesses such data where you have provided the necessary permissions or consents, whether directly or through an authorised third-party provider.

Earnly does not collect or store your online banking passwords, PINs, or other bank login credentials.

2.4 Information Earnly Receives from Third Parties

Earnly may receive Personal Data from trusted third parties, including:

• Open Banking providers and other regulated financial data providers;

• payment processors;

• cloud service providers;

• analytics providers;

• customer support tools;

• identity or fraud prevention services; and

• marketing and communications platforms.

The information received will depend on the services you use and the permissions you grant.

3. How Earnly Uses Personal Data

Earnly may use Personal Data for the following purposes:

• to create and manage your account;

• to provide, operate, maintain, and improve the Services;

• to connect and process financial account data you authorise Earnly to access;

• to generate transaction categorisation, tax estimates, forecasts, insights, alerts, and related outputs;

• to personalise your experience and tailor relevant features;

• to provide customer service and technical support;

• to process payments, subscriptions, and billing;

• to monitor, investigate, and improve platform performance;

• to secure Earnly’s systems and prevent fraud, abuse, unauthorised access, or other unlawful activity;

• to communicate with you about your account, product updates, service notices, legal notices, or support matters;

• where permitted by law, to send you marketing communications about Earnly’s products, services, features, updates, events, or content;

• to comply with legal, tax, accounting, audit, and regulatory obligations; and

• to establish, exercise, or defend legal claims.

Earnly may also aggregate or anonymise information so that it no longer identifies you and use that information for analytics, research, product improvement, operational planning, and business reporting.

Earnly does not attempt to re-identify anonymised information except where required or permitted by law.

4. Lawful Bases for Processing

Where UK GDPR applies, Earnly relies on one or more of the following lawful bases for processing:

a) Contractual Necessity

Where processing is necessary to perform a contract with you or to take steps at your request before entering into a contract, including:

• account creation;

• delivery of the Services;

• support and account administration; and

• payment and subscription management.

b) Legal Obligation

Where processing is necessary to comply with legal or regulatory obligations, including:

• record-keeping;

• fraud prevention;

• legal disclosures; and

• compliance with tax, financial, and regulatory requirements.

c) Consent

Where required by law, or where Earnly chooses to rely on consent, including:

• connecting and refreshing certain financial data sources through Open Banking;

• use of non-essential cookies; and

• certain direct marketing activities.

Where Earnly relies on consent, you may withdraw it at any time. Withdrawal will not affect the lawfulness of processing carried out before withdrawal.

d) Legitimate Interests

Where processing is necessary for Earnly’s legitimate interests or those of a third party, provided those interests are not overridden by your rights and freedoms. These interests may include:

• operating and improving the Services;

• personalising functionality;

• protecting Earnly’s business, users, and systems;

• preventing fraud, misuse, and security threats;

• communicating with users and prospective customers;

• supporting growth, product development, and internal reporting; and

• enforcing terms and protecting legal rights.

5. Who Earnly Shares Personal Data With

Earnly may share your Personal Data with the following categories of recipients where necessary and lawful:

a) Service Providers

Third parties that help Earnly operate the Services and business, such as providers of:

• hosting and infrastructure;

• cloud storage;

• analytics;

• authentication;

• communications;

• payment processing;

• customer support; and

• technical operations.

Such providers are authorised to use Personal Data only as necessary to provide services to Earnly and are subject to appropriate contractual safeguards.

b) Open Banking and Financial Data Providers

Where you choose to connect accounts or financial tools, Earnly may share or receive data through authorised third-party providers to enable the relevant functionality.

c) Professional Advisers and Regulators

Earnly may disclose Personal Data to professional advisers, auditors, insurers, legal advisers, regulators, law enforcement, courts, or competent authorities where reasonably necessary to comply with law, enforce Earnly’s rights, investigate wrongdoing, or protect persons or property.

d) Corporate Transactions

If Earnly is involved in a proposed or actual investment, financing, merger, acquisition, restructuring, sale of assets, or similar transaction, Personal Data may be disclosed to counterparties and advisers subject to confidentiality protections and transferred as part of that transaction.

e) Business Customers or Account Administrators

Where your access to the Services is provided through an employer, adviser, firm, or organisation, Earnly may provide them with account-level information relating to administration, billing, support, and use of the Services, as permitted by contract and law.

Earnly does not sell your Personal Data.

6. Automated Processing and Profiling

Earnly may use automated processing, including rules-based logic, models, and similar technologies, to:

• categorise transactions;

• identify patterns in financial activity;

• generate tax estimates or forecasts;

• deliver alerts, prompts, and recommendations; and

• detect unusual usage, fraud, or security risks.

These outputs are designed to support your use of the Services, but they may not account for every personal or business circumstance and should not be treated as professional tax, legal, or financial advice.

Where legally required, Earnly will provide additional information about significant automated processing and any rights you may have in relation to it.

7. How Earnly Keeps Personal Data Secure

Earnly takes the security of your Personal Data seriously and uses technical and organisational measures designed to protect it against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access.

These measures may include:

• encryption in transit and at rest where appropriate;

• access controls and least-privilege access;

• monitoring, logging, and alerting;

• secure development and deployment practices;

• vendor due diligence and contractual controls; and

• incident response procedures.

No system can be guaranteed to be completely secure. You are also responsible for maintaining the confidentiality of your account credentials and notifying Earnly promptly of any suspected unauthorised access.

8. Data Retention

Earnly retains Personal Data only for as long as necessary for the purposes described in this Privacy Policy, including for the purposes of:

• providing the Services;

• maintaining your account;

• complying with legal, tax, accounting, and regulatory obligations;

• resolving disputes;

• enforcing agreements; and

• protecting Earnly’s legal position.

Retention periods will vary depending on the category of data, the nature of Earnly’s relationship with you, and the legal or operational requirements that apply.

Where Personal Data is no longer required, Earnly will delete, anonymise, or securely isolate it, unless retention is required by law or necessary for backup, audit, dispute, or legal defence purposes.

9. Your Data Protection Rights

Subject to applicable law, you may have the right to:

• request access to your Personal Data;

• request correction of inaccurate or incomplete Personal Data;

• request deletion of your Personal Data;

• object to or restrict certain processing;

• request portability of data you have provided to Earnly;

• withdraw consent where processing is based on consent;

• opt out of marketing communications; and

• lodge a complaint with the Information Commissioner’s Office.

Earnly may need to verify your identity before responding to your request. Earnly will handle requests in accordance with applicable UK data protection law.

10. Marketing Communications

Where permitted by law, Earnly may send you marketing communications about Earnly’s products, services, features, updates, events, or content.

You can opt out of marketing emails at any time by using the unsubscribe link in the message or by contacting Earnly directly.

Even if you opt out of marketing, Earnly may still send you non-promotional communications relating to your account, transactions, support, legal notices, security issues, or changes to the Services.

11. Children’s Data

Earnly’s Services are not directed to children, and Earnly does not knowingly collect Personal Data from anyone under the age of 18.

If you believe that a person under 18 has provided Personal Data to Earnly, please contact Earnly and appropriate steps will be taken to investigate and, where appropriate, delete that information.

12. Changes to this Privacy Policy

Earnly may update this Privacy Policy from time to time to reflect legal, technical, regulatory, or business changes.

When changes are made, Earnly will update the effective date above and take appropriate steps to notify you where required by law or where the changes are material.

13. How to Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or Earnly’s use of your Personal Data, you can contact:

Email: support@earnly.co.uk

Company: Earnly Ltd

Registered Address: 41 New Cross Street, Swinton, Manchester, M27 4TU

You also have the right to make a complaint to the Information Commissioner’s Office if you believe that Earnly has not handled your Personal Data in accordance with applicable law.