1. In general

In this privacy statement, “Horde”, “we”, “us” and “our” refer to Horde AS (org.nr. 921 695 322, Lars Hilles Gate 20 A, 5008 Bergen, Norway). When using the Horde app (“the app”) or when visiting our website, www.horde.app, your personal data is processed in accordance with this policy.

Horde AS is the data controller of personal data in connection with your use of our services. If you have questions about your privacy, please contact us at dpo@horde.app. We will handle your request as soon as possible and no later than within thirty days. Exceptions may occur if the request is unusually complicated, we will notify you if so.

2. What kind of personal data do we collect?

We process personal information you provide us with, information generated from your use of our services, and information collected from third parties:

• User profile (phone number, email address, name)
• Device information (such as device ID, type, version, encrypted IP)
• Technical information (such as logs, consents)
• User behaviour (your activity)
• Financial information (such as account information, transactions, app payments)
• Friend loan (the agreement, parties, changes)
• Support information and other communication with you

3. Legal basis for the processing of personal data

The EU Privacy Regulation (GDPR) requires a legal basis for processing your personal data. Under article 6, section 1, of the GDPR, we process personal data based on the following legal grounds:

• Your consent – GDPR art. 6 (1) a
• To enter or for the performance of our agreement with you – GDPR art. 6 (1) b
• To comply with a legal obligation – GDPR art. 6 (1) c
• For the purpose of our legitimate interest – GDPR art. 6 (1) f

4. Why we process personal data

We process data for the purposes listed here:

• Managing our customer relationship with you
• Providing our services to you in accordance with our agreement
• Customer due diligence and other legal requirements
• To ensure information security in our services
• Support
• Troubleshooting and bug fixing
• Product improvement and development of our services
• Statistics and analysis
• Marketing

For a more detailed description, please see the next section.

4.1. User profile

Information about you as a user is processed to manage our customer relationship with you and provide our services in accordance with the agreement. We can contact you with necessary or helpful information about our services and, if you have consented, marketing material.

When you use our services, we further process information about your activity for statistics and analysis, improving and developing our services, and tracking any illegal or unwanted activities.

4.2. Device and technical information

Information about your device and other technical data is processed for traceability and troubleshooting. The information is further processed to ensure network and information security in our services, creating a unique ID associated with your user and improving and developing our services.

4.3. Financial information

You can connect your bank accounts and initiate payments directly in the Horde app. Accessing your account information requires your explicit consent, which you may retract at any time. If you do not want to consent, you cannot use the account and payment features in the app.

Based on the accounts you have added, Horde will process your account information (such as consent token, balance, transaction history, account holder name, app payments) in connection to the services “My money”, “Friend loan” and “Action cards”.

We further process the information for statistics and analysis for product improvement and development of our services, to make our services more relevant to you and to comply with any legal responsibilities.

4.4. Friend loan

We process information about your friend loan to provide the service in accordance with the agreement and comply with any legal responsibilities. We further process the information for statistics and analysis, for example, on volume, trends etc., in order to be able to perform risk analysis and for product improvement and development.

Note that your contact information, account number, and any comments in relation to a friend loan may appear in the other party’ app and/or transaction history.

4.5. Support and other communication with you

Depending on your inquiry, we process information about your user profile, device and technical information and, if needed to solve your case, certain financial information. Please note that we also process other personal data you provide in communication with our support team.

4.6. Marketing

If you have consented, Horde can contact you with marketing material. If you do not want us to contact you directly with marketing material, you can opt-out at any time via the app settings or by unsubscribing in a received email.

Note that you may not opt-out from receiving important information from us, such as information regarding security or updated terms and conditions.

5. Cookies and similar technologies

We use cookies and similar technologies to obtain information about the use of our website. Read more about what kind of cookies we use and manage your consent on our website .

We use tracking identifiers in the app to get usage information, optimize our services and measure the impact of marketing material. The tracking identifiers are generated using so-called SDK’s. It is not possible to disable these while using the app.

6. Device permissions

To provide some of our functionality, we need the following device permissions:

• Push notifications

By allowing push notifications, we can send notifications to your mobile device. You choose whether you want to receive push notifications on the phone’s settings. The push notifications will consist of automated messages based on your app usage, information about new features and products, or the like.

• Contacts

Giving us access to your contact list makes it easier to register a friend loan in the app. We do not store your contact list.

7. Data retention

We store your data until you delete your user, or as long as necessary for the purpose it was collected for. However, we may store your data for longer if it is required by law.

We do not share your personal information with others unless it follows the agreement, you have expressly consented to it, or if we are legally obliged to do so

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8. List of data processors

• Microsoft Ireland Ltd. – cloud infrastructure
• Klarna – account- and payment initiation service provider
• Aiia – account aggregator
• Elasticsearch – logs
• Freshdesk – support
• Mailchimp – email service
• Twilio Inc. – SMS service
• Sentry – application error logs
• Google Inc. – analytics and notification service

The use of certain data processors means that Horde transfers personal data to countries outside of the EU, but only if the processing takes place in a country approved by the EU or based on the EU standard contractual clauses (SCC).

9. Privacy rights

To exercise your rights, please send your request to dpo@horde.app. Our support team will handle your request as soon as possible, within one month at the latest. Please be aware that we may ask you to provide identification or other information to confirm your identity. We do this to protect our users’ identities and ensure that any attempts at impersonation are handled accordingly.

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling

The Data Protection Officer (DPO) in Horde AS is Johan Haugland. If you have questions about your privacy rights, please contact our DPO at dpo@horde.app.

If you want to complain about our handling of your personal data, you can do so to the Norwegian Data Protection Authority (www.datatilsynet.no) or the national competent authority in your country. We hope, however, that you will contact us first so that we can assist you with any questions or dissatisfaction.

10. Changes to the privacy statement

Horde may change this privacy statement at any time without prior notice. If we make significant changes that will affect our processing of your personal data, you will be notified via the app, email, or push notifications. An updated version of the privacy statement is always available in the app and on our website.

11. Our contact information

Horde AS, org.nr. 921 695 322

Lars Hilles Gate 20A

5008 Bergen

Norway

support@horde.app

dpo@horde.app