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Privacy Policy

Last updated: June 2021

This privacy notice is to let you know how Fronted gathers and processes your personal information.

This notice provides you with information regarding your rights and obligations and explains how, why and when we collect and process your personal data.

We take personal data seriously. Anything containing personally identifiable information is kept safe and we have put in place appropriate technical and other security measures to protect it.

We need to collect certain types of information to allow us to make a decision on your request for financial products. We also need to comply with legal and regulatory requirements relating to anti-fraud, anti-money laundering, know your customer and responsible lending obligations.

We will only collect the information we need to be able to provide you with the service you have requested. You need to make sure that the information you provide is accurate, complete and not misleading. Your personal information may need to be disclosed when we are obliged to by law, for purposes of national security, taxation, defence of a legal claim or criminal investigations.

If you have any questions or want to exercise any of your rights set out in this Privacy Policy, please contact us at support@fronted.rent

Who are we?

We are Fronted Holding Ltd and all subsidiaries. Our registered office is at Fronted, 81 Rivington Street, London, England, EC2A 3AY. We are registered in England and Wales under company number 12278750. We are registered on the Information Commissioner’s Office (ICO) Register under number: ZA696252.

We can be contacted:

by post at Fronted, 81 Rivington Street, London, England, EC2A 3AY;

by email at support@fronted.rent

What data do we collect?

Here is the top line summary of the data we collect.

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:

  • consent: where you have given us clear consent for us to process your personal information for a specific purpose
  • contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
  • legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)
  • legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests)

We’ll break down the information further in the next sections. To use our full range of services and products, we will collect some or all of the following information:

When information is collected

Why we ask for this

How and why we use your information 

When you register with us we will need details including:

  • Your name

  • Email address

  • Renting information including moving date, postcode, rent cost, rent deposit, salary and living situation.

Legitimate Interest

We ask for this:

— to create and manage your account with us

— to communicate with you about your account

— to assess if we can pre-qualify you for a Fronted Deposit

We rely on legitimate interest as the lawful basis for collecting and using your personal information.

Our legitimate interests are for you to have a clear understanding of our products and if we can provide our services to you.

We will keep this information until:

— you close your account with us

— we close your account

When you continue your Fronted Deposit application, we will need details including but not limited to:

  • Identity verification e.g. photo ID

  • Property agent details

  • Property details of both your current and new address

  • Your account details, account numbers, information about your transactions

Legitimate Interest

We ask for this:

— to assess if we can continue your applications for a Fronted Deposit

— ensure your identity and application is legitimate 

We rely on legitimate interest as the lawful basis for collecting and using your personal information.

Our legitimate interests are to confirm your identity, affordability and property details.

We are required by regulation to keep this information for a period of 6 years.

When you interact with the Fronted platform 

  • Visiting and browsing the site

  • Interactions with chat bot, email or any other form of communication

  • Clicking through links.

Legitimate Interest

We use this information to improve our platform and product offering. 

Your details may be shared with third party platforms including Google Analytics, Intercom, MixPanel, and Smart Look.

Personal data will not be kept longer than is viewed as necessary as per GDPR guidelines. All storage of data will be with purpose.

We may need to keep personal information due to legal requirements, see more details of this in the ‘Your Rights’ section.

When managing products and services including

  • our existing relationship with you

  • Informing you on product and service changes

  • Operating and providing lending services

  • Handling payments received from and provided to you

  • Appling charges, fees and interest due on your accounts

Contracts and Consent

To ensure that you are kept up to date with our policies when you have signed up as a user.

To provide you with the provided service that they have signed up for.

When following regulations and keeping our your information safe

  • To detect, investigate, report and seek to prevent financial crime.

  • To control risk for us and you (the customer).

  • To obey laws and regulations that apply to us

  • To respond to complaints and resolve them

  • To meet our business responsibilities of managing our financial position, business capability, planning, communications, corporate governance, audit and all that is outlined in FCA sandbox requirements

Legal Obligation and Legitimate Interest

When developing our products and services 

To comply with regulation and any other legal practices both under FCA and GDPR guidance.

To be efficient with our contractual duties

Continuing use of data

  • To develop and carry out marketing activity

  • Statistical analysis and research

  • To improve, guide, manage and develop our products and services.

Legitimate interest and Consent

  • Developing products and services to promote responsible lending and helping to prevent over-indebtedness

  • Promoting products to interested parties with similar needs and wants

Device & Website Usage Data

Data collected about your use of our websites. Information about your device, network, and web activity.

We collect personal information about you when you access our website, register with us, contact us, send us feedback, purchase products or services via our website, post material to our website and complete customer surveys or participate in competitions via our website.

We collect this personal information from you either directly, such as when you or indirectly, such as your browsing activity while on our website.

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data through forms or by corresponding with us through website chat phone, email or otherwise. This includes personal data you provide when you:

  • create an account on our website;
  • enquire about our products;
  • request marketing to be sent to you;
  • give us feedback or contact us.

We may also request a scan of an identity document if this is required for “know your customer” or anti-money laundering purposes.

To make it clear, here are the definitions and uses of

– “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, read our cookie policy.

– “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

– “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site. More information about the use of these can be found in our cookie policy.

Account & Profile Data

Data about you as a customer, prospect or subscriber. Terms are as per the below:

  • Customer is a person who has successfully received a Fronted Deposit
  • Prospect is a person who has applied for a Fronted Deposit
  • Subscriber is a person who is interested in Fronted and its related products


Data includes details such as your name, email address, address and product interests.

How Do We Use Your Personal Information

We may use your information to:

Deliver our products and services.

We use information to fulfil our contracts with you, and to deliver our products and services effectively. This allows us to:

Improve our products and services.

  • Your use of our product and service means we can create insights which will assist us in improving our products and services.

Market our products and services.

  • We only send what you want is relevant to you, including communication about products and services and advertising our products and services to you.

Prevent fraud and abuse.

  • This includes identifying unusual or suspicious interactions with our website and payment systems.

Comply with local laws and regulations.

  • This includes maintaining accurate financial records as required by local laws and regulations.

Our use of third parties

Third parties assist us in our marketing efforts and to deliver our products to you and in the provision of our services.  We collect this personal data by using cookies, server logs, visit statistics such as Google Analytics and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details. We may also record within the browser information necessary for the functioning of the website, for example whether cookie consent has been agreed to or progress through online form

We collect personal information received from other sources such as data from credit reference agencies, open banking data (including name, address, bank account number, sort codes, balance, transactions, overdraft limit and statement information) and results of “politically exposed persons” or sanction checks.

What third parties we currently use

Google Analytics

Google Analytics allows us to see how users are finding out about Fronted and if our use of social or paid campaigns are working to draw users to sign up to our platform.

You can read more about how Google uses your Personal Information here:  https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.


Intercom

Intercom allows us to communicate with you via the chatbot or emails. As part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience.

You can read more about how Intercom uses your Personal Information here: https://www.intercom.com/legal/privacy. You can also enquire directly to Intercom at team@intercom.com. If you would like to opt out of having this information collected by or submitted to Intercom, please contact us.

MixPanel

MixPanel helps us to understand how visitors navigate through our site. We use this data when seeing how we can better display and structure information.

You can read more about how MixPanel uses your Personal Information here: https://mixpanel.com/legal/privacy-policy/. You can also opt-out of MixPanel here: https://help.mixpanel.com/hc/en-us/articles/360001113426-Opt-Out-of-Tracking

Segment

Segment acts as an intermediary between the third parties, and uses cookies to connect this data. It connects your information so we know if you’ve been sent a reminder or allows us to review how customers use our site to improve your experience.

You can read more about how Segment uses your Personal Information and opt-out at: https://segment.com/legal/privacy/ or by emailing privacy@segment.com.

Sentry

Sentry allows us to fix and optimise the code that keeps Fronted running. To monitor if there are any errors or ways that we can make your experience smoother, Sentry may collect information including how you interact with Fronted using cookies and monitoring to see that all sensitive information (including financial information) is confidential and encrypted. No private information is stored on Sentry’s servers.

You can read more about how Sentry uses your Personal Information here: https://sentry.io/privacy/. You can also opt-out of Sentry at security@sentry.io or by https://sentry.io/contact/support/.

Smart Look

Smart Look allows us to understand and make changes to our site and services to allow a better user experience. This includes tracking user activity e.g. site navigation and using this information to see if our team can fix any problems a user had when completing sign up. Smart Look uses cookies and other technologies to collect data on our users’ behaviour including the anonymised capture of devices’ IP addresses. Smart Look also processes and stores data when a user completes account registration.

You can read more about how Smart Look uses your Personal Information here: https://help.smartlook.com/en/articles/3244452-privacy-policy/. You can also opt-out of Smart Look at privacy@smartlook.com or by accessing their opt-out service here.

During your Fronted Deposit application, we use additional third parties

You will be unable to proceed in our application process without opt-ing into the following legitimate uses of your personal data. This protects you from identity theft and allows us to confirm your suitability for a Fronted Deposit and perform our due diligence to prevent fraud.

Yobota

Yobota is a loan management platform. When you are approved for a Fronted Deposit, Yobota helps us manage your account including (but not limited to) keeping track of your loan repayments, adjusting any details associated with your loan and/or early settlement of your account.

You can read more about how Yobota uses your Personal Information here: https://yobota.xyz/privacy-policy/.    

Shufti Pro

Shufti Pro is an identity verification service provider which is used during the Fronted Deposit application to satisfy our Know Your Customer obligations.

You can read more about how Shufti Pro uses your Personal Information here: https://shuftipro.com/privacy-policy.

Modulr

We work with Modulr to securely send and receive payments.

We share information with Modulr about you and your estate agent that your provide to us. This includes account details of the destination bank account to pay the deposit and repayment data such as payment reference numbers to track repayments.

You can read more about how Modulr uses your Personal Information here: https://www.modulrfinance.com/privacy-policy.

London & Zurich

London & Zurich are our direct debit collection & processing service.

We use London & Zurich to set up your Direct Debit mandate. A Direct Debit mandate means we can collect and track your monthly repayments automatically. To set up your Direct Debit mandate we share information including your bank account details, repayment amount and repayment reference number with London & Zurich via Modulr. This is a secure way for you to repay your loan as we don't have to share your information twice, and it is automatically deducted meaning you don't miss any repayments.

You can read more about how London & Zurich uses your Personal Information here: https://www.londonandzurich.co.uk/privacy-cookies/.

Credit Kudos

Credit Kudos, a Credit Reference Agency that uses Open Banking data to access your transactional data and verify the information you provided in your application.

You can read more about how Credit Kudos uses your Personal Information here: https://www.creditkudos.com/legal/privacy.

Goodlord

Goodlord is a provider of estate agent software that offers Fronted to its customers for the purpose of spreading the cost of a deposit. When they send customers to Fronted they also share the deposit amount and rent amount that the customer has been quoted.

You can read more about how Goodlord uses your Personal Information here: https://www.goodlord.co/privacy-policy

Tenancy Deposit Schemes

You agree that we may request and receive information about you and your deposit from the licensed deposit protection scheme where your deposit is protected, including but not limited to::

  1. information about the beginning and end of the tenancy
  2. information about money returned, and any claims for arrears, damages or unpaid bills submitted by the customers landlord with the deposit protection schemes.
  3. any information we may need to exercise our rights as a relevant party and as the payer of the deposit.

Privacy Shield information

At Fronted we are committed to protecting your data and where possible we use UK based processing. There has been a recent GDPR legislation change in which Privacy Shields are now invalid. Though the UK is not a part of the EU, we are still conscious of US based processing of data and how to ensure you are protected.

Fronted are following guidance from the Information Commissioner’s Office (ICO), the UK’s information rights body and the European Data Protection Board (EDPB) that US data processing will only happen where suitable. If there is further authorisation needed, we will add the option onto our website.

We have identified MixPanel, Smart Look and Sentry as third parties with potential US data processing. We will be updating our practices and Privacy Policy if a review is needed of the aforementioned companies as per ICO and EDPB guidance.

How we work with Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FPAs)

When you create an account with Fronted, you’ll submit information that allows us to verify your identity, provide our services, customise our website and its content to your particular preferences, notify you of any changes and improve our services. We share your data with service providers, firms, businesses and professional advisors (e.g. lawyers and auditors) to provide you with the right product and services.

We will be working with these legitimate agencies:

  • Credit Kudos; a Credit Reference Agency (“CRAs”) and Account Information Service Provider (“AISPs”) that uses Open Banking data
  • Equifax; to connect consumer credit ratings and protect consumers against fraud.
  • HM Revenue & Customs, regulators and other authorities acting as processors or controllers who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful requests for information we receive, or to otherwise protect our rights.

What information is shared with CRAs and FPAs

This information includes (but is not limited to):

  • your name, address and contact details
  • date of birth
  • bank account and payment details
  • information about the services we provide to you
  • your account details
  • details of any feedback you give us by phone, email, post or via social media

How CRAs and FPAs use your data

This information is recorded by both Fronted and external organisations that may access and use this information to prevent fraud and money laundering. CRAs and FPAs may use your information for statistical analysis. Information held by CRAs and FPAs will be disclosed to us and to other organisations in order to (for example):

  • prevent fraud and money laundering and to check and assess applications for credit, credit related facilities or other facilities;
  • recover debts that you owe and trace your whereabouts;
  • manage credit accounts and other facilities and decide appropriate credit limits;
  • verify your identity;
  • make decisions on credit and other facilities for you or your business;
  • check details on proposals and claims for all types of insurance; and
  • check details of job applicants and employees.

Use of CRAs and FPAs during your Fronted Deposit application

When you apply to us for a loan, we will check the following records about you (and others where applicable):

Any records we may already have about you;

  • those held by CRAs; and
  • those held by FPAs.
  • CRAs supply us with public information (including from the electoral register, county court judgments and bankruptcies registers) and shared credit and fraud prevention information, including information about previous applications and the conduct of accounts in your and your financial associate(s)' name(s).

You should be aware that whether or not your loan application is successful, when CRAs receive a search from us they will place a soft search footprint on your credit file that may be seen by other lenders. Large numbers of applications within a short time period may affect your ability to obtain credit. This is applicable whether your application is accepted or declined.

We will send the information that you submit through our website to CRAs. This information will be recorded by them. We and other organisations may access and use this information to prevent fraud and money laundering and CRAs and FPAs may use your information for statistical analysis. Information held by CRAs and FPAs will be disclosed to us and to other organisations as outlined in the previous “Credit Reference and Fraud Prevention Agencies use your data” section.

Use of CRAs and FPAs once you are issued a Fronted Deposit

If you are to use a Fronted Deposit, we will give details of your loan and how you repay it to the CRAs. If you borrow and do not repay in full and on time, the CRAs will record the outstanding debt and, in some cases, the length of time that the debt remains outstanding. Other organisations may see these updates and this may affect your ability to obtain credit in the future.

If you fall behind with your payments and a full payment or satisfactory proposal is not received within 14 Days of a “Notice of Default” being issued then a “Formal Demand” will be issued and a default registered on your Credit File with CRA’s.

This information may be supplied to other organisations by CRAs and FPAs to perform similar checks and to trace your whereabouts and recover debts that you owe.

If you give us false or inaccurate information and we have reasonable grounds to suspect fraud or we identify fraud we may record this and may also pass this information to FPAs and other organisations involved in crime and fraud prevention including law enforcement agencies who may then access this information.

Equifax, Experian and TransUnion, the ICO and the major financial services trade associations have developed a common statement, Credit Reference Agency Information Notice (CRAIN). This defines the standards that all three Credit Reference Agencies will apply across all products and services in relation to processing consumer data. You can read the CRAIN here.

Use of Automation

We may use systems to send you automated communications or to make automated decisions using the personal information we have obtained from you and other sources about you. Automating decisions allows us to make consistent, efficient and quick decisions regarding the products and services we offer. These automated decisions can affect the products and services we may offer you now or in the future, or the price that we charge you for them.

We will ensure that you are aware of when automated decisions are being made. Currently all your interactions will be reviewed manually by an underwriter. This data will then be used to help move towards more automated decisions and communication.

Currently we use automation in the following areas:

Decision

How Automation occurs

Fronted Deposit affordability

When you apply for a Fronted Deposit, from your salary, rent and other details, we automatically calculate what deposit range we could offer you.

Audience grouping

We may group you with other customers with similar characteristics e.g. living with roommates. This is so we can tailor messaging and products to your needs.

Detecting Fraud

We use analytics to alert us if there are discrepancies or there is usual activity.

Opening Accounts

Both when you sign up for an account or connect your details, automation occurs when creating your user profile. Before issuing a loan, all information is manually checked by an underwriter.


Your data rights and preferences

Do Not Track

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

Security

We are committed to ensuring that your information is secure. Appropriate security measures are in place to protect against loss, misuse or alteration of information collected from you, including measures to prevent, as far as possible, access to our databases by parties other than Fronted.

Retention of Data

We will retain your personal data for as long as we are required to under relevant legislation and regulation, and where no specific rules apply, for no longer than it is necessary for our lawful purposes. This will usually be no more than six years from the end of our relationship with you. The retention period of your personal data may need to be extended where we require this to bring or defend legal claims.

We may also retain data for longer periods for statistical purposes, and if so we will anonymise this.

Why do we collect and store data?

We will keep your personal information for as long as is necessary to fulfil the purposes outlined in this privacy policy, unless we are required or permitted by law to retain that information for longer than this.

We will need to keep your personal information for as long as you are a customer. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

How long do we store your data?

After your relationship with Fronted ends, we may keep your data for up to 6 years for the following scenarios:

  • To respond to any queries or complaints
  • To show that we have acted and treated you fairly
  • To maintain records according to rules and regulations that apply to us

In some circumstances, we will keep your data for longer than 6 years if we cannot delete it for regulatory or legal reasons. If it is required to extend our retention period, we will continue to ensure that your privacy is protected and we will only use it for the specified reasons.

For research or statistical purposes, we may anonymise your personal data. This data will no longer be identified with you and we may keep this information indefinitely without further notice to you.

How can you amend your marketing preferences?

Both when you enter our site or sign up as a user, we will confirm that you have opted into our services. Any electronic marketing communications we send you will include clear instructions to follow should you wish to unsubscribe at any time.

You may also amend your contact preferences by emailing us at support@fronted.rent.

Your Rights

As a data subject, you have a number of rights:

  • the right to be informed about the collection and use of your personal data;
  • the right to access the personal data we hold about you (Subject Access Request);
  • the right to rectify inaccurate personal data or complete it if it is incomplete;
  • the right to erasure and have your personal data deleted;
  • the right to request restriction of or suppression of your personal data;
  • the right to obtain and make use of your personal data for your own purposes across different services ("portability");
  • the right to object to the processing of your personal data in certain circumstances; and
  • rights related to automated decision-making including profiling.

Your data protection rights are subject to certain restrictions and conditions and financial organisations are required to retain a range of your information for legal and regulatory reasons including responsible lending and the prevention of financial crime.

Fronted is required to keep a record of the information reported to the Credit Reference Agencies about you and will therefore retain repayment information regarding your loan for six years from the date that the loan is settled/closed. If your account is recorded as defaulted, the data is kept for six years from the date of the default. This may be extended where we require this to bring or defend legal claims.

If you think that any of the personal data we hold about you is wrong or incomplete you have the right to challenge it.

We will not make a charge for handing your rights request, unless we consider it to be manifestly unfounded or excessive involving a disproportionate effort (particularly if this is a repeated request). If you would like to exercise any of the rights outlined above, you can make it in writing by emailing support@fronted.rent and we will respond within 30 days.

We will assess your request and if we decide not to act upon it or place certain restrictions on it, we will inform you of our reasons for this.

You have the right to complain to us and to the data protection regulator, the Information Commissioner’s Office. Their address is: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. They can be contacted by phone on 0303 123 1113 (local rate) or 01625 545745 if you prefer to use a national rate number.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation. You can find details on how to report a concern at: https://ico.org.uk/make-a-complaint/

International Data Transfers

We will only send your data outside of the European Economic Area ('EEA') to:

  • Follow your instructions (e.g. right to portability); or
  • Comply with a legal duty; or
  • Work with our agents and advisers who we use to help run your accounts and services

Some of our third parties as referenced in the ‘Third Parties’ section, are based outside the EEA, and stores your data as per the Standard Contractual Clauses (SCC) outlined in GDPR.  Transfer it to a non-EEA country with privacy laws that give you the same protection as the EEA as per Standard Contractual Clauses (SCC). You can find out more about data protection on the European Commission Justice website here. When you send an email to Fronted, you agree to your data being stored and processed in this way.

Fraud Prevention Agencies may also transfer your personal information outside of the EEA, when this occurs they impose contractual obligations on the companies or organisations that receive your information so that they protect your personal information to the standard required in the EEA. They may also require the companies or organisations who receive that personal information to subscribe to 'international frameworks' intended to enable secure sharing of personal information.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you would like to know how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit Get Safe Online.

Our website may contain hyperlinks to websites that are not operated by us. We urge you to review any privacy policy posted on any site you visit before using the site or providing any personal information about yourself.

Changes

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. Updated versions of this policy will be posted on our website. If there are significant changes we’ll let you know by email.

Contact Us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at: support@fronted.rent.

If you would like this website privacy policy in another format (for example: audio, large print, braille) please contact us at: support@fronted.rent.

v2.1 – Last Updated: June 2021

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Fronted is a trading name of Fronted Holding Ltd. We are registered in England and Wales (Company No.12278750), registered office address is 81 Rivington Street, London, EC2A 3AY. Fronted Loans Ltd (Company No.12307305) is authorised and regulated by the Financial Conduct Authority under a Consumer Credit Licence (FCA No. 933316). Fronted Ltd (Company No.12304059) is authorised and regulated by the Financial Conduct Authority under a Broker Licence (FCA No. 933317).

Fronted Loans Ltd and Fronted Ltd is a wholly owned subsidiary of Fronted Holding Ltd. We are part of the FCA regulatory sandbox - Cohort 6. The regulatory sandbox allows firms to test innovative offerings in a live environment. More information on the FCA's regulatory sandbox can be found here.

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