Date last revised: 11th May 2018
Unless otherwise required by law, the Information Commissioner’s Office ( ICO) guidance or best practice, or in order to perform our contract with you, we will only process your personal data in the way we tell you or in the way you ask us to, and we will give it back to you at any time.
- THIS POLICY
1.1 This policy, together with the Investor Terms & Conditions, explains how any personal data we collect from you, or that you provide to us, will be processed by us or any processor on our behalf.
1.2 This policy applies to our contract with you. You are therefore advised to read it carefully. Terms used within it shall have the meaning(s) given in the General Data Protection Regulation (Regulation), as applicable.
1.3 By visiting our website located at https://www.investsure.co (our Website), or by registering for membership with us, you accept and consent to the practices described in this policy.
1.4 Any changes we make to this policy will be posted on this page. You are advised to check back frequently as any changes will be binding on you when you continue to use the Website after the date of the relevant change.
1.5 For more information relating to your rights under this policy, please see section 10.
1.6 If you have any queries relating to this policy, please contact us at firstname.lastname@example.org
- WHO WE ARE
2.1 We are
2.2 We are registered with the ICO to process your personal data and our registration number is ZA148478
2.3 Your data will be held on secure servers and will be processed by staff who work in the UK only
- YOUR CONSENT
3.1 By registering for membership with our platform, using our services and/or otherwise using the Website, you expressly consent to:
3.1.1 provide us with the personal data necessary to allow you to use the Website and allow us to facilitate transactions on your behalf
3.1.2 the processing of your personal data by us, or those specifically listed third parties, in accordance with this policy; and
3.1.3 the transfer of your personal data to those third parties listed in this policy, for the reasons specified.
3.2 You may withdraw your consent under 3.1 at any time. However, where the withdrawal of your consent prevents us verifying your identity or otherwise monitoring who you are, you will be unable to use your membership and transact through our Website OR You may exercise your rights under 3.1 at any time, which includes withdrawing your consent to our processing of your personal data. However, where this withdrawal prevents us from performing our contract with you, we may not be able to provide our goods and services to you.
- WHAT WE COLLECT
4.1 We may collect all or some of the following categories of data from you:
Address (including postcode)
Date of birth
Passport (including passport number)
Driving licence (including driving licence number)
4.3 In addition to the above, we will also provide you with your Membership Details, which includes your username which is either created
- HOW WE COLLECT YOUR DATA
The data listed in section 4 is collected in the following ways:
5.1 By you registering for membership – this is any information you give to us that we request from you when
5.2 Information collected – each time you visit our Website, whether through your home, work or a public network, your own computer or mobile device, we will automatically collect:
5.2.1 technical information – your IP address (used by your computer or device to connect to the internet), and any internet browser type and version details; and
5.2.2 visit-specific information – your URLs, Projects and Properties you viewed or searched for, your clickstream through the Website.
6.1 Our Website will use the cookies listed in section 6.2 (alpha-numeric text files placed on your computer) to:
6.1.1 distinguish you from other users;
6.1.2 optimise your browsing experience;
6.1.3 make necessary improvements to our Website;
6.1.4 recognise and count the number of visitors to our Website and see how they move around the Website during use;
6.1.5 recognise you when you return to our Website; and
6.1.6 record your visit to our website, including any links you may follow.
6.2 The following cookies are set to our Website for the listed purposes:
|Session_ID||Enhances user experience by remembering session history.|
|Joomla_remember_me||Records users authentication session|
|joomla_user_state||Records users authentication
|Google analytics cookie, to track user sessions, page visits and demographic information.|
|cookie-policy||Tracks presentation of the cookie information advice|
6.3 Our Website additionally uses Google Analytics, a web analytics service provided by Google, LLC (Google). Google Analytics uses analytical, performance or targeting cookies to help analyse how you use the Website and compile reports on your activity for us.
6.4 Any information generated by the cookie about your use of the Website (including your IP address) will be transmitted
6.7 Except for essential cookies, all cookies will expire after your session.
- WHAT WE DO WITH YOUR DATA
7.1 Your data is primarily necessary to verify who you are when accessing your Account and to ensure you meet our eligibility requirements in order to submit an Application for funding
7.2 Additionally, we will use all of your data you provide us to notify you about:
7.2.1 similar Projects or Properties listed on our Website that are similar to those you have already
7.2.2 changes to our Website or our services.
7.3 We use any data we collect about you (as a result of your visit to our Website) to:
7.3.1 personalise and improve our services (including the Website and its security);
7.3.2 deal with your inquiries and requests;
7.3.3 administer and monitor traffic and behaviours on our Website for analysis, testing, research, statistical and survey purposes;
7.3.4 ensure that any part of our Website (including any Content) is presented in the most effective manner for you and your computer or device, and to make improvements (where necessary); and
7.3.5 keep our Website safe and secure.
7.4 Where we change our services, or any applicable terms and conditions, we will contact you.
7.5 Any data we obtain about you from third parties are used for the purposes of verifying your eligibility for funding through our
7.6 Once collected, we may retain your data for up to six years following the date of your last transaction or the date you close your Account (whichever is the later). This is to enable us to refer back to any transactions or records you are involved in (should we be required to do so).
- HOW AND WHY WE DISCLOSE YOUR DATA
8.1 Subject to the rest of part 8 of this policy, we will only disclose your personal data to the following third parties for the following purposes:
8.1.1 the relevant Investee Company – in connection with your Investment, details of which will be stated on your Application;
8.1.2 our approved transaction email provider, in order for us to be able to send emails to you (NB only your email address is passed to the provider.
8.2 In addition to the transfers contemplated by part 8.1, we may transfer or disclose your personal data to:
8.2.1 any prospective buyer of any part of the relevant business or assets in connection with the sale (in which case, any personal data held by us about you and our Account Holders will be one of the transferred assets);
8.2.2 comply with any legal obligation (such as where stated at clause 6.5 of the Investor Terms and Conditions);
8.2.3 enforce or apply any part of our Investor Terms and Conditions generally; or
8.2.4 protect our rights or our property, or those of our other Account Holders.
8.3 Any websites which are linked from the Website are outside of our control and not covered by this policy. If you access those websites using the links provided, the website operators may collect information from you which will be used by them in accordance with their own privacy policies (if any). These policies may differ from ours, and we cannot accept any responsibility or liability in respect of these.
9.1 We have put in place appropriate technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable Data Protection Laws.
9.2 Each member of staff has unique log-in details and authentication software requires these to access the systems. Staff have access to personal data only for the purposes of performing their roles.
9.3 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.
- YOUR RIGHTS
10.1 In relation to all of your personal data, you have the following rights to ask us or us (in addition to any rights you may have under the Act or the Regulation):
10.1.1 not to process your personal data for marketing purposes;
10.1.2 to clarify what data we hold about you, how it was obtained, to whom it has been disclosed and for how long it will be stored;
10.1.3 to amend any inaccurate data we hold about you;
10.1.4 to delete any of your data (where you no longer think we need to hold it or you think we or ShareIn have obtained it or processed it without your consent at any time); and
10.1.5 to only process your personal data in limited circumstances or for limited purposes.
10.2 If you wish to exercise any of your rights at any time, please contact us on the details contained at the beginning of this policy in the first instance. We will require you to verify your identity to us before we provide any personal data, and reserve the right to ask you to specify the types of personal data to which your request relates.
10.3 Where you wish to exercise any of your rights, they may be subject to payment of a nominal administration fee (to cover our costs incurred in processing your request) and any clarification we may reasonably require in relation to your request. Such fees may be charged where we consider (acting reasonably) that your request is excessive, unfounded or repetitive.
10.4 Any data provided to you in accordance with your rights will be in a structured and machine-readable form.