28TH FEBRUARY 2016
By “personal information” we mean all information that identifies or may identify you.
Please note that personal information we collect from you may be transferred to and stored in destinations outside the European Economic Area ("EEA") and may be processed by staff operating outside the EEA. Countries outside the EEA (such as the United States of America) may not offer the same levels of data protection as the United Kingdom. By submitting your personal information you agree to this transfer, storage and processing. If you have any questions or comments about this, please contact us at firstname.lastname@example.org
We are committed to protecting and respecting your privacy. We collect, store and use personal information in accordance with the Data Protection Act 1998 (the "DPA") and all other relevant legislation and regulations. For the purposes of the DPA, we are the data controller of any personal data we process about you.
3. HOW WE COLLECT AND RECEIVE PERSONAL INFORMATION
We may collect and/or receive personal information from you when you:
- fill in forms on our Website, including when you register, create or modify an online or in-app account with us;
- communicate with us, such as by mail, telephone, in writing or through our website or social media;
- use or access our Website; or
- respond to surveys or questionnaires we ask you to complete.
We may also collect your personal information from publicly available information such as information on third party websites or from our business partners.
4. WHAT PERSONAL INFORMATION?
The types of personal information we receive, store and use may include:
- your title, name, gender, address, telephone numbers, email address and date of birth;
- your Intro Crowd account information (including your Intro Crowd username and password);
- 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; and
- information regarding your personal or professional interests, demographics, experiences with our products, and contact preferences in order to provide you with further services or information about our products and services.
5. 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 collect, store and process your personal information for the following reasons:
- to provide our products and services to you;
- 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 provide special offers and other related services to you;
- to improve and tailor our products and services;
- for our own internal record-keeping requirements;
- to protect your account and prevent unauthorised access to your account;
- for market research, analysis, testing, monitoring, risk management and administrative purposes; and
- to contact you, for example, to send service communications through our Website, email or any other medium such as to notify you to check your dashboard when financial transfers have been made on your behalf.
6. DO WE SHARE PERSONAL INFORMATION WITH ANYONE ELSE?
We may disclose personal information we collect or receive:
- to you or those 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 and our legal and professional advisors;
- to any third party which acts, from time to time, as Intro Crowd's principal for the purposes of regulation and authorisation under the Financial Conduct Authority;
- to any third party which acts, from time to time, as the depositary or custodian for any money which you deposit using the Website, or as custodian and holds the legal title to any share or instrument which you may invest in using the Website;
- to any third party which acts, from time to time, as the payments processor for transactions carried out on or through the Website;
- to third parties in connection with a proposed or actual financing, securitization, insuring, merger, restructure, sale, acquisition, assignment or other disposal of all or 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 and performing the proposed transaction; and
- to third parties, including the Financial Conduct Authority, law enforcement officials, law courts and government and other regulatory authorities: (a) if we believe disclosure is required by any applicable law, regulation or legal process (such as to respond to subpoenas or judicial orders); or (b) to protect and defend our rights, or the rights or safety of third parties, including to defend against legal claims.
7. MARKETING COMMUNICATIONS
We will only send you marketing communications by electronic means (e-mail or text) if those communications relates to goods, services or opportunities which are similar to those that you have previously purchased or expressed an interest in or if you have consented to us contacting you in this way. We will only permit third parties to send you marketing communications by electronic means if you have consented to this.
During your Intro Crowd account set-up process you will be able to opt out of receiving marketing communications from us and/or third parties. You can change your marketing preferences at any time by contacting us at email@example.com
8. STATISTICAL INFORMATION
We may aggregate information about you with information about other users of our Website to create statistical data about users. This is statistical data that does not identify you and we may distribute any such aggregate information to third parties we work with.
9. THIRD PARTY LINKS
10. 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 processed by staff operating outside the EEA. Countries outside the EEA (such as the United States of America) may not offer the same levels of data protection as the United Kingdom. By submitting your personal information you agree to this transfer, storage and processing. If you have any questions or comments about this, please contact us at firstname.lastname@example.org
We will take all steps reasonably necessary to keep your data secure. 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.
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.
11. ACCESS TO INFORMATION
You have a right under the DPA to access information we hold about you by contacting us at email@example.com, we will not charge you to access this information.
Cookies generally fall into one of the following categories:
- strictly necessary cookies which are cookies that are essential to allow you to use a website and its features;
- performance cookies which 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; and
- 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 targeting or advertising cookies.
Some of our cookies remain on your device between your browsing sessions.
Most web browsers automatically accept cookies. You can configure your web browser to accept or reject cookies, or to notify you when a cookie is set on your computer (check the 'Help' menu of your browser to learn how to change your cookie preferences). 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.
13. 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 firstname.lastname@example.org