We are committed to protecting and respecting your privacy. We collect, store and use information in accordance with the General Data Protection Regulations (EU) 2016/679 (the "GDPR") and any other relevant legislation and regulations as amended from time to time. For the purposes of the GDPR, we are the data controller of any personal data we hold or process about you.
Please do not provide us with such consent if you do not want that information to be used by us in this manner.
3. How we may collect and/or receive your personal information
This is collected and/or received by us when you:
- fill in forms on our Website, including any information you provide when you register, create or modify an online account with us;
- communicate with us by email, telephone, in writing, through our Website or via social media;
- use or access our Website (including, but not limited to, traffic data and data in relation to the resources you access);
- respond to surveys or questionnaires you may asked to complete.
We may also collect your personal information from publicly available information such as information on third party websites or from companies within the Exo group, partners and joint ventures and other companies under common control (together, the "Affiliates").
4. What is personal information?
The types of personal information we receive, store and use may include:
- Data provided by you to verify your identity, including your title, name, gender, address, telephone numbers, passport details, National Insurance no., email address and date of birth;
- your account information (including your username and password);
- your financial details including your bank account details, online banking information, credit or debit card number and transaction and credit information;
- information about your interactions you may have with us and our staff, including interactions via email, telephone or through our Website;
- information regarding your personal or professional interests, employment status, demographics, experiences with our products, and contact preferences in order to provide you with further services or information about our products and services;
- any other information we require to assess your knowledge and experience in investing including your financial situation and investment goals; and
- records of transactions, dealing & payment instructions and without limitation all data generated through the operation of your account with; our firm, bankers, executing brokers, custodians and professional advisors.
5. Changes in your personal information
In order to ensure our records are accurate and update we may make periodic requests for you to confirm any or all of the relevant data items that we hold.
We would ask that where you are aware of a material change in your own data set e.g. Change of address, name, contact no., email address or similar you notify us in a timely fashion via firstname.lastname@example.org. Where such changes might, in our opinion, affect the operation or functionality of the account we may ask for documentary evidence to verify the new data.
6. How we use personal information
We use the personal information we collect and receive to help us understand your needs and to help us provide you with a better service. In particular, we (including third party data processors, agents and subcontractors acting on our behalf) collect, store and process your personal information for the following reasons:
- to allow you to use the various features of our Website;
- to provide our products and services to you in connection with our legitimate business interests;
- for purposes related to providing our products and services to you, including verifying and authenticating your identity, processing your payments, completing transactions and processing your purchasing requests;
- to improve and tailor our products and services and train our staff;
- for our own internal record-keeping requirements;
- to help protect your account and prevent unauthorised access to your account;
- to meet our regulatory & anti-money laundering obligations;
- to assist in the detection, prevention of fraud and financial crime;
- for market research, analysis, testing, monitoring, risk management, audit and administrative purposes;
- to contact you, for example, to send service communications through our Website, email or any other medium such as to notify of material information relevant to our legitimate business interest including when you check your dashboard or when financial transfers (receipts or payments) have been made on your behalf; and
7. Do we share personal information with anyone else?
We may disclose personal information we collect or receive:
- to you, your lawfully appointed attorney-in-fact or those we reasonably believe to be acting on your behalf;
- to third parties to provide a service to, or perform a function for us, or you, or who are otherwise appointed by us in connection with the services we offer you including those who are acting as our agent or sub-contractor, including, without limitation, data processing service providers executing brokers, custodians and our legal and professional advisors;
- to third parties in connection with a proposed or actual financing, securitization, insuring, merger, restructure, sale, acquisition, assignment or other disposal of all or any part of our business or assets or the assets of any Affiliate or to anyone whom we may transfer our rights and/or obligations for the purposes of evaluating / performing the proposed transaction; and
- to any entity to whom we are required by any applicable law, regulation or legal process, to disclose the data. We would advise that on such occasions we may be restricted by law from notifying you of such disclosure.
However, we never store or disclose your financial account log-in information (such as your online banking username and passwords) to anyone. Furthermore, we will never ask you for your banking username, passwords or such information. Please contact us directly at email@example.com if you have concerns about being asked to provide this information.
8. Marketing Communications
Only when you have provided your explicit consent will we send you marketing communications electronically (e-mail or text). Such communications may relate to goods, products, services or opportunities which are in our legitimate business interest and substantively similar to those that you have previously purchased, invested or expressed an interest in or if you have explicitly consented to us contacting you in this way.
Please do not provide us with such consent if you do not want that information to be used by us in this manner.
During the setting up of your account, you will have the choice as to whether you wish to provide your explicit consent to receive marketing communications from us and/or third parties. You can change your marketing preferences at any time by contacting us at firstname.lastname@example.org.
Where we hold your email address and you have not proceed to open an account or make an explicit request to receive any marketing communications, unless otherwise instructed, and in the absence of a response we will delete such email address from our records after 28 days.
9. Statistical information
We may aggregate information about you with information about other users of our Website or services to create anonymised statistical data about users. This is statistical data that does not identify you nor contain any of your personal data. We may distribute any such aggregate information to third parties we work with in the legitimate interests of the business.
10. Third party links
Our Website may contain links to enable you to visit third-party websites, mobile sites and mobile applications. Please note that while we try to work with reputable parties we do not have any control over there third-party websites, mobile sites or mobile applications.
Therefore, we are not responsible for the protection and privacy of any information that you provide whilst visiting such sites.
We would therefore strongly recommend that if you have any concerns you should review their relevant Privacy / Data protection policy prior to providing them with any personal data.
11. Data storage
Personal information we collect from you may be transferred to and stored in destinations outside the European Economic Area ("EEA") and may be subject to be processed by staff operating outside the EEA. Countries outside the EEA may not offer the same levels of data protection as the UK.
By the use of our services and or Website, and by submitting your personal information to us, you agree that your personal information may be transferred, stored and processed outside of the EEA.
We will take steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. You should be aware that transmission of information via the internet is not entirely secure and we cannot guarantee the security of any data you transmit to our Website via the internet or any other means.
We will retain your personal information and other information which we have collected or received to the extent required by applicable laws and as we may require for operational and legal purposes.
12. Access to information
You have a right under the GDPR to access information we hold about you by contacting us at email@example.com. Please include your name and address and any other information which may identify you. We will not charge you for any reasonable and or periodic requests to access this information.
You will have the right to instruct us to move, copy or transfer your personal data from one IT environment to another in a safe and secure way, without any hindrance to usability. Where you request a transfer of your data we reserve the right to maintain a copy in line with our regulatory and statutory obligations. In addition, we may redact or remove any proprietary information relating to the activities of our firm or its affiliates.
13. Right to have your data deleted
You have the right to ask us to delete your personal data without undue delay and we shall comply where one of the following grounds applies:
- Your personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
- There is no other legal ground for us processing;
- You object to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2);
- Your personal data has been unlawfully processed;
- Your personal data must be erased for compliance with a legal obligation in the UK or a Member State law to which the we are subject; (note we will require written evidence of such legal obligation)
- Please note that any personal data we hold in relation to the opening and or operation of your account with us may be subject to our record keeping obligations as provided by the Financial Conduct Authority in the UK. If you require further information, please email us at firstname.lastname@example.org.
Cookies generally fall into one of the following categories:
- strictly necessary cookies which are cookies that are required to allow you to use a website and its features;
- performance cookies which recognise and collect information about how visitors use a website to create aggregated, anonymous information that does not identify the visitor;
- functionality cookies which allow the website to remember you and provide a more personalised service to you;
- targeting or advertising cookies which are used to deliver adverts relevant to you.
Our Website uses the following types of cookies: strictly necessary cookies, performance cookies, functionality cookies and those, where you have provided explicit consent, targeting or advertising cookies. Some of our cookies may remain on your device between your browsing sessions.
You can disable our cookies by changing the settings on your browser but doing so might mean you are unable to use certain features of our Website.
15. Contacting us
If you have any questions or comments on this policy or you would like to request a copy of your personal information, you can contact us at email@example.com.