Privacy Policy

This Privacy Policy explains how Spring Financial Limited trading as Most (“Most”, “we”, “our”, or “us”) collects, uses, and protects your personal data when you use our website, app, and related services (the “Service”). We comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who We Are

Spring Financial Limited trading as Most, registered in England and Wales (Company No. 15579066).

Our registered office is: 1 Lyric Square, Addition Finance, The Office Group, London, Greater London, England, W6 0NB.

You can email us on: [email protected].

2. The Data We Collect

We collect and process the following personal data when you use our Service:
- Identification and contact data (e.g., name, email, date of birth)
- Financial information (e.g., income, expenses)
- Behavioural data (e.g., questions asked to our AI, how you use the app)
- Technical data (e.g., log files, essential cookies for service operation)

3. How We Collect Data

We collect data:
- Directly from you through sign-up forms, inputs into our AI, and customer support interactions
- Through essential cookies and analytics to operate and improve our Service
- Via third-party service providers necessary for running our Service (e.g., cloud and database providers)

4. How We Use Your Data

We use your personal data to:
- Provide and improve our financial guidance services
- Make the guidance you receive from our AI tools more relevant
- Comply with legal obligations and maintain business records
- Communicate with you about service updates and important notices

5. Our Use of AI and Profiling

We use automated tools, including AI, to analyse the information you provide and to give you more relevant financial guidance. This does not amount to automated decision-making that produces legal or similarly significant effects. All recommendations are for information and guidance only—you remain responsible for any financial decisions you make.

6. Lawful Basis for Processing

We process your data based on:
- Performance of a contract (to provide our services)
- Legitimate interests (to operate and improve our Service)
- Compliance with legal obligations (e.g., tax and accounting requirements)

7. Data Sharing

We only share personal data with third-party providers essential to operating our Service, such as secure cloud hosting and analytics. We do not sell or trade personal data.

8. Data Retention

We keep personal data for as long as your account is active and for up to six years after closure to comply with legal, tax, and accounting requirements. After this period, we securely delete or anonymise your data.

9. Your Rights

Under UK GDPR you have rights to:
- Access your personal data
- Correct inaccurate data
- Request deletion of your data
- Object to or restrict processing
- Data portability
To exercise your rights, contact [email protected].

10. Data Security

We implement appropriate technical and organisational measures to protect personal data against loss, misuse, and unauthorised access.

11. International Transfers

We primarily store and process data within the UK or EEA. If we transfer data outside these regions, we ensure appropriate safeguards (such as Standard Contractual Clauses) are in place.

12. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. Significant changes will be communicated to you.

13. Contact Us

For privacy inquiries or to exercise your rights, contact [email protected].