Privacy Policy

Last Updated: 21st of July, 2026

1. INTRODUCTION

Your trust is important to us and we’re committed to protecting the privacy and security of your personal information. The information that’s shared with us helps us to provide a great experience wit

This Privacy Policy describes how we collect, use, procesnal information, in conjunction with your access to and use of the Scraye Platform and the Ribbon Rewards Platform. This privacy policy describes our privacy practices for all websites, platforms and services that link to it. Please read the privacy policy

1.1 Definitions

If you see an undefined term in this Privacy Policy (suchtform” or “Ribbon Rewards Platform”), it has the samedefinition as in our Terms of Service (“Terms”).

1.2 Data Controller

When these Terms mention “Scraye,” “Ribbon”, “we,” “us,” or “our,” it refers to the Scraye company that is responsible for your information under this Privacy Policy (the “Data Conller is Scraye Technologies Ltd. Ribbon and Ribbon Rewards are trading names for Scraye’s rent rewards service (see clause 7 of the Terms of Servicea).

1.3 Applicability to Payments

This Privacy Policy also applies to the Payment Services provided to you by Scraye. When using the Payment Services, you will be also providing your information, including personal informationtities, which will also be the Data Controller (the"Payments Data Controller") of your information related to the Payment Services, generally depending on your country of residence. The Payments Data Controller is Scraye Technologies Ltd.

2. INFORMATION WE COLLECT

There are three general categories of information we coll

2.1 Information You Give to Us.

2.1.1 Information that is necessary for the use of t

                                                                                                                                           We ask for and collect the following personal informatione Scraye Platform. This information is necessary for theadequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able   to provide you with all the requested services.
                                                                                                                                           - **Account Information**. When you sign up for a Scraye n information such as your first name, last name, emailaddress, and date of birth.                                                                                                                    - **Profile and Listing Information**. To use certain fearm (such as renting a Listing), we may ask you to provideadditional information, which may include your address, phone number, and a profile picture.                                                   - **Identity Verification Information**. To help create aronment, we may collect identity verification information(such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other        authentication information.

Payment Information. To use certain features of the Scraye Platform (such as renting a Listing), we may require you to provide certain financial information (like your bank account or credit cto facilitate the processing of payments.
Communications with Scraye. When you communicate with Scraye, we collect information about your communication and any information you choose to provide. #### 2.1.2 Information you choose to give us. You may choose to provide us with additional personal infn a better user experience when using Scraye Platform. This additional information will be processed based on our legitimate interest or when applicable, your consent.
Additional Profile Information. You may choose to provide additional information as part of your Scraye profile (such as gender, preferred language(s), city, and a personal description).
Address Book Contact Information. You may choose to import your address book contacts or enter your contacts’ information manually to access certain features of the Scraye Platform, like invi
Other Information. You may otherwise choose to provide us information when you fill in a form, update or add information to your Scraye Account, respond to surveys, post to community forums, paommunicate with our customer care team, share yourexperience with us, or use other features of the Scraye Platform.

2.1.3 Information that is necessary for the use of the Payment Services.

The Payments Data Controller needs to collect the following information necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering you will not be able to use Payment Services: - Payment Information. When you use the Payment Servitroller requires certain financial information (like yourbank account or credit card information) in order to process payments and comply with applicable law. - Identity Verification and Other Information. If yous Data Controller may require identity verificationinformation (such as images of your government issued ID, passport, national ID card, or driving license) or other authentication information, your date of birth, your address, email address, phone nu in order to verify your identity, provide the PaymentServices to you, and to comply with applicable law.

2.1.4 Information We Automatically Collect from Your Use of the Scraye Platform and Payment Services.

When you use the Scraye Platform and the Payment Services, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequtract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Scraye Platform and Payment Services.

Geo-location Information. When you use certain featm, we may collect information about your precise orapproximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use oflications in the device’s settings menu. Scraye may alsocollect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
Usage Information. We collect information about youraye Platform such as the pages or content you view, yoursearches for Listings, bookings you have made, and other actions on the Scraye Platform.
Log Data and Device Information. We automatically c information when you access and use the Scraye Platform,even if you have not created an Scraye Account or logged in. That information includes, among other things: details about how you’ve used the Scraye Platform (including if you clicked on links to thi address, access dates and times, hardware and softwareinformation, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Scraye Platform.
Cookies and Similar Technologies. We use cookies and other similar technologies when you use our platform, use our mobile app, or engage with our online ads or email communications. We may colleautomated means using technologies such as cookies, webbeacons, pixels, browser analysis tools, server logs, and mobile identifiers. In many cases the information we collect using cookies and other tools is only used in a non-identifiable without referenc For example, we may use information we collect to betterunderstand website traffic patterns and to optimize our website experience. In some cases we associate the information we collect using cookies and other technology with your personal informatimay also use these tracking technologies on the ScrayePlatform or engage others to track your behavior on our behalf.
Do Not Track Signals. While you may disable the usa browser settings, the Scraye Platform currently does notrespond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardisation regarding how that signal should be interpreted.
Payment Transaction Information. Scraye Payments collects information related to your payment transactions through the Scraye Platform, including the payment instrument used, date and time, payument expiration date and billing postcode, your addressand other related transaction details. This information is necessary for the adequate performance of the contract between you and Scraye Payments and to allow the provision of the Payment Servic

2.1.5 Information We Collect from Third Parties.

Scraye and Scraye Payments may collect information, inclu that others provide about you when they use the ScrayePlatform and the Payment Services, or obtain information from other sources and combine that with information we collect through the Scraye Platform and the Payment Services. We do not control, supthe third parties providing your information process yourPersonal Information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

Reference Checks. For Tenants seeking to rent a Listed by applicable laws, Scraye and Scraye Payments mayobtain reports from third party databases regarding among others your address history, credit score, any bankruptcies and other referencing-related matters. We may use your information,and date of birth, to obtain such reports. Where you opt in to our rent reporting service, we also share your rental payment data with Credit Reference Agencies — see section 4.9 for details.
Referrals. If you are invited to Scraye, the persont personal information about you such as your email address or other contact information.
Other Sources. To the extent permitted by applicabltional information about you, such as demographic data orinformation to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background chsent where required) or fraud warnings from serviceproviders like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Scraye Platform through paexperiences and interactions from our partner ad networks.

2.2 Children’s Data.

Our websites and applications are not directed to childrenowingly collect any personal information directly fromchildren under 16. If you believe that we processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us using the informatioact Us” section below.

3. HOW WE USE INFORMATION WE COLLECT

We may use, store, and process personal information to (1rove, and develop the Scraye Platform, (2) create andmaintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with Scraye Policies) and (3) provide, personalize, measure, and improve our advertisin

3.1 Provide, Improve, and Develop the Scraye Platform

We may use the personal information to provide, improve, tform such as to:

enable you to access and use the Scraye Platform,
operate, protect, improve, and optimize the Scraye Platform and experience, such as by performing analytics and conducting research,
provide customer service,
send you service or support messages, updates, security alerts, and account notifications,
if you provide us with your contacts’ information, we mn: (i) to facilitate your referral invitations, (ii) sendyour requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection, and
to operate, protect, improve, and optimise the Scraye Pd personalise and customize your experience (such as making Listing suggestions, ranking search results), and facilitate claims with our Damage Protection, Rent Protection or other similar landlord protection programs, we conduct profiling based on your ie Platform, your search and rental history, your profileinformation and preferences, and other content you submit to the Scraye Platform.

We process this personal information for these purposes given our legitimate interest in improving the Scraye Platform and our Users’ experience with it, and where it is necessary for the adeontract with you.

3.2 Create and Maintain a Trusted and Safer Environme

We may use the personal information to create and maintaironment such as to:

detect and prevent fraud, spam, abuse, security incidenvity,
conduct security investigations and risk assessments,
verify or authenticate information or identifications p
conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required,
comply with our legal obligations,
Resolve any disputes with any of our Members and enforcd parties,
enforce our Terms of Service and other policies, and
in connection with the activities above, we may conductnteractions with the Scraye Platform, your profileinformation and other content you submit to the Scraye Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Scraye Pletect activity that we think poses a safety or other riskto the Scraye Platform, our community, or third parties. If you challenge the decisioning based on the automated process, please contact us as provided in the Contact Us section below.

We process this personal information for these purposes gst in protecting the Scraye Platform, to measure theadequate performance of our contract with you, and to comply with applicable laws.

3.3 Provide, Personalise, Measure, and Improve our Advertising and Marketing.

We may use the personal information to provide, personalise, measure, and improve our advertising and marketing such as to:

send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Scraye or partner campaigns edia advertising through social media platforms such asFacebook or Google),
personalise, measure, and improve our advertising,
Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Scraye or its third party partners,
conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Scraye Platform, information obtained from third parties, and yoory) to send you promotional messages, marketing,advertising and other information that we think may be of interest to you,
enrolling in an email subscription will not affect the e emails that we may send in connection with any ScrayeAccount. No fee is charged for sending promotional emails to you, but third-party data rates may apply. Note that you may not be able to take advantage of certain promotions if you do not have anScra
invite you to events and relevant opportunities.

We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be

3.4 How the Payments Data Controller uses the Persona

We may use the personal information as a part of Payment

Enable you to access and use the Payment Services.
Detect and prevent fraud, abuse, security incidents, and other harmful activity.
Conduct security investigations and risk assessments.
Conduct checks against databases and other information sources.
Comply with legal obligations (such as anti-money laund
Enforce the Payment Terms and other payment policies.
With your consent, send you promotional messages, markeer information that may be of interest to you based on your preferences.

The Payments Data Controller processes this personal information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for f the contract with you and to comply with applicable laws.

Where you have provided consent, we share your informatiormation, as described at the time of consent, such as whenyou authorise a third party application or website to access your Scraye Account or when you participate in promotional activities conducted by Scraye partners or third parties.

Where permissible according to applicable law we may use nformation about you, such as your email address, to hashit and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Scraye Platform.es are based on our legitimate interest in undertakingmarketing activities to offer you products or services that may be if your interest.

The social media platforms with which we may share your personal information are not controlled or supervised by Scraye. Therefore, any questions regarding how your social media platform servicpersonal information should be directed to such provider.

Please note that you may, at any time ask Scraye to ceasethese direct marketing purposes by sending an e-mail to**[email protected]**.

To help facilitate tenancies or other interactions between Users, we may need to share certain information, including personal information, with other Users, as it is necessary for the adequate peretween you and us, as follows:

When you as a Tenant submit a tenancy request, certain hared with the Landlord, including your profile, full name, the full name of any additional Tenants, your reference check results, and other information you agree to share. When your tenancy is confirmed, we will disclose additional information to assrental, like your phone number.

4.3 Compliance with Law, Responding to Legal Requestsection of our Rights.

Scraye may disclose your information, including personal w enforcement, governmental authorities, tax authorities,or authorised third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply or to respond to claims asserted against Scraye, (iii) torespond to a valid legal request relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liabildminister our Terms of Service, the Payment Terms or otheragreements with Users, or (v) to protect the rights, property or personal safety of Scraye, its employees, its Users, or members of the public. For example, if permitted due to the forgoing cirmation may be shared with tax authorities or othergovernmental agencies.

These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person's vital interests or for the purposes of our or a third party’s legitimate interesatform secure, preventing harm or crime, enforcing ordefending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.

Where appropriate, we may notify Users about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believuld be futile, ineffective, create a risk of injury orbodily harm to an individual or group, or create or increase a risk of fraud upon Scraye’s property, its Users and the Scraye Platform. In instances where we comply with legal requests without notmay attempt to notify that User about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

4.4 Service Providers.

Scraye and Scraye Payments uses a variety of third-party service providers to help us provide services related to the Scraye Platform. Service providers may be located inside or outside of the European particular, our service providers are based in Europe,India, Asia Pacific and North and South America.

For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or polon, and risk assessment, (iv) perform product development,maintenance and debugging, (v) allow the provision of the Scraye Services through third party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service services, or (vii) process, handle or assess insuranceclaims or other similar claims (such as claims under the Damage Protection or Rent Protection). These providers have limited access to your personal information to perform these tasks on our behalfund to protect the personal information and only use thepersonal information in accordance with our instructions .

Scraye will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.

4.5 Corporate Affiliates.

To enable or support us in providing the Scraye Platform,tion, including personal information, within our corporatefamily of companies (both financial and non-financial entities) that are related by common ownership or control.

Additionally, we share your information, including personal information, with our corporate affiliates in order to support and integrate, promote, and to improve the Scraye Platform and our affil

4.6 Programs with Managers and Owners.

We may share personal information and booking informationt companies, and/or property owners in order to facilitateprograms with these partners. For example, tenancy details and personal information may be shared with owners and property managers of the building, complex, or planned community where a Landlord s to facilitate hosting services, security, billing, andother services that may be provided.

4.7 Business Transfers.

If Scraye undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, includnnection with such transaction or in contemplation of suchtransaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

4.8 Aggregated Data.

We may also share aggregated information (information abone together so that it no longer identifies or referencesan individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.

4.9 Credit Reference Agencies.

If you are a Tenant and choose to opt in to Scraye’s rentl share your rental payment data with one or more CreditReference Agencies (“CRAs”), including Equifax, Experian and TransUnion. This is entirely optional — if you do not opt in, your rental payment information will not be shared with the CRAs for

To do this, we will supply the CRAs with your Identifiersress) and your financial account data (tenancy accountdetails and rental payment history, including whether payments are made on time).

The CRAs will match this information to the records they hold about you and add it to your credit file, which may help build your credit history and can be used by other organisations to assess

We — and, in turn, the CRAs and organisations they work wo:

verify your identity, age and address;
assess and report your rental payment history to help build your credit profile;
help us and other organisations make fair lending and c including assessing new tenancy applications and managingexisting accounts;
contact you and recover debts you may owe;
screen marketing offers to make sure they’re appropriate to your circumstances (this does not include using your data for prospect marketing purposes);
prevent fraud and money laundering; and
undertake statistical analysis, profiling, and system/p

We will continue to exchange information about your rentaor as long as you remain opted in and have an activetenancy managed through Scraye. When your tenancy ends, we will inform the CRAs, and if you have outstanding rental arrears at that point, this will be recorded by the CRAs. If you fall into arreale opted in, this may also be recorded and could adverselyaffect your credit score.

We do not process this rental payment data sharing on the basis of your consent (in the UK GDPR sense). We do so on the basis of our legitimate interest in providing Scraye’s rent reporting t, because it is necessary to perform our contract withyou. Where we ask you to opt in, this is a contractual permission that enables us to share your data with the CRAs, rather than the GDPR legal basis for the processing itself. Withdrawing this permissng, but will not affect data already shared with the CRAs.

Rental data is retained by the CRAs for the periods set oference Agency Information Notice (“CRAIN”). Theidentities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods, and your data protecare explained in more detail at:

Equifax: [www.equifax.co.uk/crain](https://www.equifax.
Experian: www.experian.co.uk/legal/crain/
TransUnion:www.transunion.co.uk/legal/privacy-centre/pc-credit-reference

5. OTHER IMPORTANT INFORMATION

5.1 Analysing your Communications.

We may review, scan, or analyse your communications on the Scraye Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, ses. For example, as part of our fraud prevention efforts,we scan and analyse messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyse messages to debug, improve, and expand product offerings.where reasonably possible. However, occasionally we mayneed to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or annications to send third party marketing messages to you,and we will not sell reviews or analyses of these communications.

These activities are carried out based on Scraye’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the a services.

5.2 Third Party Partners & Integrations

The Scraye Platform may contain links to third party websthird party integrations, co-branded services, or thirdparty-branded services (“Third Party Partners”). Scraye doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

Parts of the Scraye Platform may use third party services such as Google Maps/Earth services, including the Google Maps API(s).

6. YOUR RIGHTS

Consistent with applicable law, you may exercise any of the rights described in this section before your applicable Scraye Data Controller and Payments Data Controller. Please note that we may ask yound request before taking further action on your request.

6.1 Managing Your Information.

You may access and update some of your information througou are responsible for keeping your personal informationup-to-date.

6.2 Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your Scraye Account).

6.3 Data Access and Portability.

In some jurisdictions, applicable law may entitle you to your personal information held by us. You may also beentitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to anotherechnically feasible).

6.4 Data Retention and Erasure.

We generally retain your personal information for as longerformance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely. Please note that if you request the erasure of your personal informat

We may retain some of your personal information as neceusiness interests, such as fraud detection and preventionand enhancing safety. For example, if we suspend a Scraye Account for fraud or safety reasons, we may retain certain information from that Scraye Account to prevent that Member from opening a new re.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Scraye may keep some of your information for tax, legal reporting and aud
Information you have shared with others may continue to be publicly visible on the Scraye Platform, even after your Scraye Account is cancelled. However, attribution of such information to yonally, some copies of your information (e.g., log records)may remain in our database, but are disassociated from personal identifiers.
Because we maintain the Scraye Platform to protect fromoss and destruction, residual copies of your personalinformation may not be removed from our backup systems for a limited period of time.

If we are processing your personal information based on your consent you may withdraw your consent at any time by sending a communication to Scraye specifying which consent you are withdrawing. Pleal of your consent does not affect the lawfulness of anyprocessing activities based on such consent before its withdrawal.

Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your pere processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claimed to the processing pursuant to Section 6.6 and pendingthe verification whether the legitimate grounds of Scraye override your own.

6.6 Objection to Processing.

In some jurisdictions, applicable law may entitle you to require Scraye Payments not to process your personal information for certain specific purposes (including profiling) where such processing is bt. If you object to such processing Scraye will no longerprocess your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or

Where your personal information is processed for direct m, at any time ask Scraye to cease processing your data forthese direct marketing purposes by sending an e-mail to [email protected].

6.7 Lodging Complaints.

You have the right to lodge complaints about our data processing activities by filing a complaint with our Data Protection Officer who can be reached by the “Contact Us” section below or with a super

6.8 Third Parties.

We do not sell personal information to third parties. We collect personal information through our Service and sharepersonal information with third parties for the business purposes described in this Privacy Policy, including without limitation advertising and marketing on our Service and elsewhere based on usersime and across different sites, services, and devices.

7. SECURITY

We are continuously implementing and updating administratal security measures to help protect your informationagainst unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you ieve that your Scraye Account credentials have been lost,stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Scraye Account, please contact us following the instructions in the Contact Us s

8. CHANGES TO THIS PRIVACY POLICY

Scraye reserves the right to modify this Privacy Policy aith this provision. If we make changes to this PrivacyPolicy, we will post the revised Privacy Policy on the Scraye Platform and update the “Last Updated” date at the top of this Privacy Policy. If you disagree with the revised Privacy Policy, you may u do not cancel your Account before the date the revisedPrivacy Policy becomes effective, your continued access to or use of the Scraye Platform will be subject to the revised Privacy Policy.

9. CONTACT US

If you have any questions or complaints about this Privacy Policy or Scraye’s information handling practices, you may email us at the email addresses provided in the relevant sections above.