RESIDENT MOBILE APPLICATION - PRIVACY POLICY

PRIVACY STATEMENT

The Resident mobile application (“App”)is provided by Techno Orange Ltd (Techno Orange) ("we", “us” or “our”). We are committed to protecting and respecting the privacy of users of the App (“you” or “your”). This privacy policy (“Privacy Policy”) sets out the basis on which the personal data collected from you, or that you provide to us will be processed by us. Please read the following carefully to understand how we will use your personal data.

For the purpose of data protection legislation in the UK, the data controller is Techno Orange Ltd (Techno Orange) with company registration no. 11299702 and having its registered office at 10 Babbage Point 20 Norman Road, London, United Kingdom, SE10 9FA. Our ICO registration number is [ZA420301] and you can access our data protection register entry on https://ico.org.uk. The information set out below under ‘Information we may collect and process from you’ is stored on our cloud based servers in [United Kingdom].

INFORMATION WE MAY COLLECT AND PROCESS FROM YOU

We may collect and process the following information from you in accordance with data protection legislation in the UK:

- Information that you provide to us by registering to use the App, including your first name, middle name (if applicable), surname, email address, the name and contact details of your tax advisor, and your country of residence. We need this information to set up your account and to communicate with you should we need to during your use of the App, and have a legitimate interest to process this personal data for the purposes of providingthe App to you. We may also use this information to market to you about products and/or services we may offer from time to time. Where we process your information for direct marketing, we are relying on your consent as a means to process your informationwhere legally required to do so.

- Information that you provide to us by filling in forms on our App. We may also ask you for information when you report a problem with our App.

- If you contact us, we may keep a record of that correspondence for the purposes of processing any request, comment or complaint we may receive from you.We have a legitimate interest to process this personal data in order to respond to such request, comment or complaint.

- We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.We have a legitimate interest to process the personal data you provided in respect of these surveys to enable us to enhance or improve the services we provide to users of the App, and we rely on your consent as a basis for processing your responses in respect of any surveys you have chosen to respond to.

We are required to comply with certain legal and regulatory requirements, and may process your personal data for compliance with such legal or regulatory obligation, to which we or regulators or law enforcement agencies are subject.

Note that if any of your personal details change during your use of the App, we request that you update them by accessing the relevant section of the App, or by contacting us at hello@resident.tax.

INFORMATION GENERATED BY THE APP WHICH WE DO NOT COLLECT

We do not have access to and do not store any data recorded or generated by the App as part of its day to day use (which is separate to the information we may collect from you as set out above),and includes your location and day count data, which we require to provide you with the Services (as defined in theResident Mobile Application Terms & Conditions available www.resident.tax/legal (“Terms”)), and which is collected from the location data your Device makes available to the App, or via your Device’s mobile spectrum (such as the GPRS, 3G, 4G) or WiFi connection (“App Generated Data”).

All App Generated Data is stored within the App on your mobile device. If you enable the back-up feature, a back-up of the App Generated Data will be stored on your personal iCloud or Google Drive account (depending on the type of mobile device you use). We do not have access to App Generated Data.

RETENTION OF YOUR PERSONAL DATA

We take appropriate measures to ensure that any personal data is kept secure and kept for the duration of your use of our Appand a further[60] months from when you stop using the App.

Once a client relationship is terminated, the user’s account and personal details are deleted from theResident Admin Portal (RAP).

DISCLOSURE OF INFORMATION

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).

We may disclose your personal information to third parties:

- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

- if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;

- if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation;

Your App Generated Data is disclosed to Apple Inc. or Google Inc.(or one oftheir subsidiary companies) depending on the mobile device you are using to access the App and if you have enabled the back-up feature within the App. You can limit such disclosure by not enabling the back-up feature, but by doing such your App Generated Data will only be stored on your mobile device.

You may disclose your App Generated Data to your tax advisor by using the relevant features of the App. We will not disclose your personal data to your tax advisor at any time.

CROSS BORDER TRANSFERS

We will not transfer your personal data outside of the UK to carry out the Services via the App. The only exception to this is where you use the features of the App to send your App Generated Data externally, such as to yourself or your tax advisor, or to an external backup system. If the external person or backup system is outside the UK, then this process may result in your personal data being transferred outside of the UK.

If we sell or buy any business or assets and would be required to disclose your personal data to the prospective buyer or seller of such business or assets, or if we or substantially all of our assets are acquired by a third party, we may, to the extent that any of these situations occur, be required to transfer your personal data outside of the UK. In the event that either of these situations occur, where applicable, we will put appropriate safeguards in place to cover transfers of your personal data including, for example, signing standard contractual clauses/data protection clauses adopted by the European Commission, or where applicable, relying on a Privacy Shield certification where the transfer contains a US entity.

YOUR RIGHTS

As a result of us collecting and processing your information, you have the followinglegal rights:

- to access personal data held about you;

- to request us to make any changes to your personal data if it is inaccurate or incomplete;

- to request your personal data is erased where we do not have a compelling reason to continueto process such data in certain circumstances;

- to receive your personal data provided to us as a data controller in a structured, commonly used and machine-readable format where our processing of the data is based on: (i) your consent; (ii) our necessity for performance of a contract to which you are a party to; or (iii) steps taken at your request prior to entering into a contract with us and the processing is carried out by automated means;

- to object to, or restrict, our processing of your personal data in certain circumstances;

- to object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you; and

- to lodge a complaint with a data protection supervisory body, which at present, is the Information Commissioner’s Office.

To exercise any of your rights as set out above, including to withdraw your consent where we have stated we are processing your personal data based on your consent, please contact us at hello@resident.tax.

CHANGES TO OUR PRIVACY POLICY

This Privacy Policy was last updated in August 2018. We reserve the right to modify this Privacy Policy at any time. Any changes we may make to this Privacy Policy will be notified and made available to you using the App, where appropriate. By continuing to use the App, you are accepting any changes made to this Privacy Policy. Please check back regularly to keep informed of updates or changes to this Privacy Policy.

CONTACT

All questions, comments and requests regarding this Privacy Policy should be addressed to hello@resident.tax.