Relm Privacy Policy

1. Introduction

This is the Privacy Policy of Real Estate Loan Management Limited, trading as Relm Finance, having its principal place of business at 3rd Floor, Longphort House, Earlsfort Centre, Earlsfort Terrace, Dublin 2, Ireland (‘Relm’). Please read this Privacy Policy carefully. By accessing and using our website, platform and services, you confirm that you have had a proper opportunity read this Privacy Policy, that you understand it and that you agree to it. If you do not agree to this Privacy Policy in its entirety, you must immediately cease use of our website and platform, and any services provided by us.

We may amend this Privacy Policy from time to time. You are encouraged to periodically review this page for the latest information on our privacy practices and amendments to our Privacy Policy. By continuing to use our website or platform you agree to be bound by all such updates and amendments. We are committed to protecting and respecting your privacy. Any personal information provided to Relm will be treated in accordance with the Data Protection Acts 1988 and 2003 ("DPA").

This Privacy Policy explains and governs:

• how we collect personal information belonging to visitors to our website as well as personal information belonging to Borrowers and/or persons connected with Borrowers (such as directors, shareholders and beneficial owners), and those representing Borrowers (“you” and “your”, as appropriate);
• how we store and protect your personal information;
• how and why we use your personal information; and
• your rights to control your personal information.

References in these terms and conditions to "Relm", "we", "us" and "our", means Real Estate Loan Management Limited. References to "systems" or "platform" means the platform, any other online services provided by us and any data managed by, displayed on or transmitted from such services. References to "you" and "your" mean a user of the platform and the services provided via our systems.

2. If you engage with us, we may collect information about you such as:

2.1 If you engage with us, we may collect information about you such as:

• information you provide through our website via registration, the Cents Check and/or the loan application process;
• information you provide through communications with us, whether in writing (including email) or on the telephone (including by way of recorded calls);
• information we obtain through your engagement with us on social media, including on blogs, forums and through Facebook and Twitter;
• information provided on your behalf by your representatives or agents (“Agents”) who engage with us on your behalf in the ways described above; and
• information from outside sources such as credit reference agencies, fraud prevention agencies, public records and other publicly available information sources.

2.2 If you wish to register with Relm and apply for a loan you will need to provide us with certain information including:

• your personal details (including name and contact details);
• for Borrowers (and those representing Borrowers), the name of at least one director and your contact information;
• Information required to complete KYC and AML for shareholders, beneficial owners and controlling parties;
• passwords and security question answers for your online account;
• information that we may reasonably request to assess your loan application including, but not limited to, tenancy schedules, lease information, and financial information.

2.3 Where you provide information about other people (for example, if you represent a Borrower and you provide information about directors, shareholders or beneficial owners other than yourself) then you confirm:

• you have obtained their consent to disclose such information in accordance with this Privacy Policy; and
• by providing such information, that you have all relevant permissions and authority (a) to make all such disclosures, (b) to act on their behalf and (c) in relation to shareholders or beneficial owners of Borrowers, to allow us to make credit checks at credit reference agencies in respect of such persons

3. Cookies

• The Relm site uses "session" cookies to collect information about visitors' use of the website, including things like connection speed, operating system, and time and duration of visits. This information is used on an aggregate, and not an individual, basis to help provide visitors with a better experience on our website.
• We use cookies to improve the performance of the site and give you a better experience. The cookies we use can’t harm your computer and we don’t ever store confidential data, such as bank details, in cookies.
• Relm will not personally identify visitors and will not use cookies to contact you. We are committed to respecting your privacy at all times.
• You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

• Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
• You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
• Except for essential cookies, all cookies will expire after 2 years.

4. Using your information

4.1 Why we collect, store and use your personal information:

• to open your online accounts and to manage and maintain those accounts;
• to verify your identity for AML and KYC purposes;
• to update the records we hold about you from time to time;
• to inform you of platform developments and activity and of changes to our products and services;
• to develop and improve our services, products and business, including analysing and improving our credit risk models and our customer service offering;
• if you are a Borrower (or a director, shareholder or beneficial owner of a Borrower) we may use your information:
  • to ascertain your borrowing needs;
  • to assess your creditworthiness and to make credit-related decisions;
  • if you miss any repayment of your loan, to contact you to discuss remedy options
  • to carry out mandatory or other regulatory checks;
  • to comply with our legal and regulatory obligations;
  • to carry out statistical analysis and market research and testing;

5. Disclosing your information

5.1 To whom may disclose your personal information:

• to companies in our group and our affiliates;
• to our suppliers, sub-contractors and third party data processors. These providers are only permitted to process your personal data on our behalf and in accordance with our instructions and we will take steps to ensure that such transfer and any on-going processing by such third parties is carried out securely and in accordance with applicable privacy law;
• to a third party if it acquires all or part of our business or assets in connection with the acquisition, or to a successor in interest in the unlikely event of our insolvency, winding up or liquidation;
• where we are required to do so by applicable law and regulation, governmental, tax or regulatory body or law enforcement agency;
• if you are represented by an Agent, to your Agent; and
• to any other person with your prior consent to do so.

5.2 Save as expressly provided above, or otherwise without your consent, Relm will not disclose, or transfer your personal information to any third party.

6. Storing your information

6.1 Personal data, sensitive information and all legal documentation will be stored safely and securely;

6.2 Any other hard copy client related information and files will be stored in a secure location with restricted access;

6.3 Soft copy information will be maintained on a secure IT platform with adequate password protection and/or encryption codes;

6.4 Records will be maintained for a period of 6 years from:

• The date of a transaction, where records relate to the transaction
• The date the provider ceases to provide any product or service to the customer, for all other records.

6.5 Information held will be reviewed on an annual basis in line with the annual review, and will be checked for accuracy.

6.6 Once the retention period lapses, the information will be destroyed.

7. Accessing and correcting your information

On request, we will supply copies of your personal data which you may have supplied via this website. If you wish to obtain such copies, you must write to Relm at the address below, or e-mail info@relm.ie OR Real Estate Loan Management Limited, 3rd Floor Longphort House, Earlsfort Terrace, Dublin 2.

• Your request will be dealt with as soon as possible and will take not more than 40 days to process.
• If you discover that Relm holds inaccurate or out-of-date information about you, you can request Relm corrects that information. Such a request must be in writing or via e-mail.
• In certain circumstances you may also request that data which you have supplied via the website be deleted, but this may adversely impact our ability to provide services to you.

8. Opting Out

You may, at any time out of any marketing communications that Relm may send you. Please contact us to tell us if you have changed your mind or, in relation to email marketing, unsubscribe following the link on an email you have received.

9. Security and other Third Parties

9.1 Whilst Relm takes appropriate technical and organisational measures to safeguard the personal information that you provide to it, we accept no liability if communications are intercepted by third parties or incorrectly delivered or not delivered.

9.2 If Relm transfers your information to third parties we will ensure that such transfer and any on-going processing by such third parties is carried out securely and in accordance with the DPA.

9.3 You also have a responsibility to ensure that your information is kept secure. If you are a member of our marketplace, you must:

• keep your login details secret;
• log out of your account when not using it;
• try and maintain good internet security (for example, be careful when using public WiFi or shared access internet connections); and
• tell us immediately if you think your account has been compromised.

10. Contact Us

You can contact us at info@relm.ie or Real Estate Loan Management Limited, 3rd Floor Longphort House, Earlsfort Terrace, Dublin 2.