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Wenn du Fragen zu unserer Datenschutzpolitik hast, oder gerne eine deutsche Version davon hättest, schreib uns einfach eine Email: [email protected]
DATA PRIVACY POLICY
This is the data privacy policy of Investoo Group (“Investoo”).
Investoo respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit one of our websites (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you.
Purpose of this privacy policy
This privacy policy aims to give you information on how Investoo collects and processes your personal data through your use of this website, including any data you may provide through this website when you provide your personal details or consent to receive further materials from us or our business partners.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
Investoo is the controller of and is responsible for your personal data (also collectively referred to as “we”, “us” or “our” in this privacy policy).
Investoo Group may, from time to time, be made up of different legal entities. This privacy policy is issued on behalf of each Investoo Group company so when we mention Investoo, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Group responsible for operating this website and for processing your data.
We have appointed a data protection manager (“DPM”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPM using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our DPM in the following ways:
Full name of legal entity: Investoo Ltd
Email address: [email protected]
Telephone number: (+44) (0) 20 3488 2091
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy. We may notify you of changes to this policy by email.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website includes links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect and store information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
4. How is your personal data collected?
We use different methods to collect data from and about you, including through:
o apply or register for products or services; o create an account on our website; o subscribe to our service or publications; o request marketing materials to be sent to you; o enter a competition, promotion or survey; or o give us feedback or contact us.
o apply or register for products or services;
o create an account on our website;
o subscribe to our service or publications;
o request marketing materials to be sent to you;
o enter a competition, promotion or survey; or
o give us feedback or contact us.
Technical Data from the following parties:
o Contact, Financial and Transaction Data from providers of technical, payment and delivery services. o Identity and Contact Data from data brokers or aggregators. o Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
o Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
o Identity and Contact Data from data brokers or aggregators.
o Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
(b) Contact
(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
(a) Managing payments, fees and charges
(b) Collecting and recovering money owed to us
(c) Financial
(d) Transaction
(e) Marketing and Communications
(b) Necessary for our legitimate interests (to recover amounts due to us)
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(c) Profile
(d) Marketing and Communications
(b) Necessary to comply with our legal obligations
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use particular pages/products/services)
(d) Usage
(b) Necessary for our legitimate interests (to study how customers use pages/products/services, to understand user preferences, to develop our pages/products/services and grow our business)
(c) Technical
(f) Technical
(b) Usage
(e) Profile
(f) Marketing and Communications
(e) Technical
(f) Profile
(g) Usage
(h) Marketing and Communications
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us and/or certain External Third Parties if you have requested information and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express “opt-in” consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Cookies
Cookies are small pieces of information stored by your browser on your computer’s hard drive. We use cookies to allow us to understand who has seen which pages and advertisements, to determine how frequently particular pages are visited, to determine the most popular areas of a website and generally in order to monitor usage of a website. Most web browsers automatically accept cookies, though you do not have to. We do not control the use of cookies by third parties. You can set your browser to refuse all or some cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at www.allaboutcookies.org.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may transfer your data outside the European Economic Area (“EEA”).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. 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.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
With the exception of Contact Data (which will be retained for a period of three years from the date of our last contact or dealing with you) we will retain your data for a period of two years from the date of our last contact or dealing with you. At the end of the applicable retention period your data will be deleted from our systems.
In some circumstances you can ask us to delete your data prior to the end of the retention period – see “your legal rights” below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
o If you want us to establish the data’s accuracy. o Where our use of the data is unlawful but you do not want us to erase it. o Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. o You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. o Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. o Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.
o If you want us to establish the data’s accuracy.
o Where our use of the data is unlawful but you do not want us to erase it.
o Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
o You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
o Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
o Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to understand those who visit our websites, their interests and their preferences with a view to giving them the most relevant user experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties means other companies in the Investoo Group, acting as joint controllers and processors.
External Third Parties means: