Privacy Policy

Outbehaving is operated by:

• Company name: Outbehaving Ltd
• Company number: 16393573
• Registered address: 55 Stirrups Farm Road, Lowton, WA3 2SX, United Kingdom
• Email: privacy@Outbehaving.co.uk

We are the data controller for your personal data unless stated otherwise.

Outbehaving is built with a clear intention:

• to act in the best interests of our users where possible;
• to use personal data responsibly and transparently;
• to improve outcomes for individuals and the wider community;
• to protect your privacy and data; and
• to continuously improve how we serve you.

We design our platform to support better decisions, stronger financial outcomes and a fairer system of participation over time.

This policy applies to account holders, users of our platform, prospective users, community members, people interacting with our services or partners, people who contact us, and people who receive our communications.

We may collect:

• Identity data (name, date of birth, nationality, ID details)
• Contact data (email, phone, address)
• Account data (login details, settings, tier)
• Verification data (identity checks, proof of address, screening results)
• Profile data (preferences, interests, activity)
• Usage data (how you use the platform)
• Technical data (IP address, device, browser)
• Transaction data (payments, billing, subscription info)
• Financial/service data (where needed for services)
• Impact Share data (awards, participation, limits, eligibility)
• Communications data (messages, support requests)
• Marketing data (preferences, engagement)
• Compliance data (fraud checks, sanctions screening)

We collect data directly from you, automatically via the platform, from third parties (e.g. verification, payment providers), from partners or referrals, and from public or lawful sources.

We use your data to create and manage your account, provide and improve the platform, verify identity and eligibility, enable features and services, manage tiers and participation, administer Impact Shares, personalise your experience, connect you with partners, manage payments and subscriptions, prevent fraud and abuse, comply with legal obligations, support analytics and improvements, and develop future services.

We process your personal data under the following lawful bases:

• Contract — to provide services and manage your account
• Legal obligation — to comply with laws and regulations
• Legitimate interests — to operate, improve and secure the platform
• Consent — where required (e.g. marketing or optional features)
• Vital interests — in rare safety situations

Where consent is used, you can withdraw it at any time.

We use personal data to personalise your experience, including recommendations, insights, service suggestions, tier progression, participation features, and Impact Share allocation logic.

We do not rely solely on automated decision-making where it would have a significant legal effect without safeguards. Where applicable, you may request human review.

Outbehaving may use personal data to operate Impact Shares and participation features.

Impact Shares do not represent ownership, equity or shares at the time they are awarded; they do not guarantee value or conversion into ownership; and they may be subject to eligibility, limits and conditions, or changed, paused or discontinued at any time.

We may share your data with group companies, service providers, identity and fraud verification providers, payment providers, partners and service providers you choose, regulators and authorities, professional advisers, potential investors or acquirers, and other parties where required or permitted by law. We ensure appropriate safeguards are in place when sharing data.

We may transfer your data outside the UK where necessary to operate the platform. Where we do so, we ensure appropriate safeguards are in place, including adequacy regulations, standard contractual clauses, transfer risk assessments, and contractual protections.

We only keep personal data for as long as necessary. Retention depends on account status, legal obligations, operational needs, compliance requirements, Impact Share and participation records, and audit and security requirements. When no longer needed, data is securely deleted or anonymised.

We use appropriate technical and organisational measures to protect your data, including encryption, access controls, monitoring systems, secure storage, and internal safeguards. No system is completely secure, but we work to protect your information.

You have the right to access your data, correct your data, request deletion, restrict processing, object to processing, request data portability, withdraw consent, and challenge automated decisions (where applicable).

To exercise your rights, contact us at privacy@Outbehaving.co.uk.

We may send marketing communications where permitted by law. You can opt out at any time. Service and account messages are not marketing.

Our platform is intended for users who meet our minimum age requirement. We do not knowingly collect data from children below the permitted age.

We may update this Privacy Policy from time to time. Where changes are significant, we will notify you.

As Outbehaving evolves, we may introduce new features or services that are subject to financial services regulation or other regulatory frameworks. Where this occurs, additional terms, disclosures and privacy notices may apply, and we will ensure appropriate safeguards and transparency are in place.

If you have concerns, contact us first at privacy@Outbehaving.co.uk or complaints@Outbehaving.co.uk.

You also have the right to complain to the Information Commissioner’s Office (ICO).