THE TYPE OF INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
- Information that you provide by filling in forms or registering to use our site (including the information described in greater detail under “Specific Information Collected from Investors” below). We may supplement the information you provide us with information we receive from third parties.
- If you contact us, we may keep a record of that correspondence, including (but not limited to) recordings of relevant telephone conversations.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of transactions you carry out through our site.
- Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access.
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
SPECIFIC INFORMATION COLLECTED FROM INVESTORS
If you wish to make an investment via the Platform, information we will collect from you will include:
- Current and previous contact details including name, address, telephone numbers (including any landline, mobile or fax numbers)
- Other demographic information and information relating to your employment or business
- Details required for payments, including details of bank accounts, credit cards used to make payments for investments.
- Your passwords, memorable words and other security details
- Information or certification from you which we request to establish whether you have sufficient knowledge and experience to invest via our site (which may include details as to your income or assets)
- Other information we may require for the purposes of money laundering identification
- Specific information which may be required by Jarvis Investment Management Limited in providing the execution, settlement and custody service in accordance with the Investors’ Agreement which may include details of your personal or tax position
- Correspondence between you and us by e-mail, post and fax
- Any Content you upload to our site and any comments you make via Interactive Services provided via our site
- Details of your activities or transactions on our site.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
- To comply with our legal and regulatory obligations, including under Handbook of Rules and Guidance of the Financial Conduct Authority (“FCA” and “FCA Rules”) – this may include assessing the answers to any questions we ask you if you are a potential investor.
- To ensure that content from our site is presented in the most effective manner for you and for your computer.
- To confirm your identity in order to create your account and ensure that you are eligible to use the services provided on our site. This includes conducting any anti-money laundering checks or anti-fraud checks where we believe these are required for legal or regulatory reasons.
- To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
- To carry out our obligations arising from any contracts entered into between you and us.
- To allow you to participate in interactive features of our service, when you choose to do so.
- To notify you about changes to our site.
We may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by e-mail, post or telephone.
If you are an existing user, we will only contact you by electronic means (e-mail or SMS) with information about services similar to those which were the subject of a previous transaction with you.
If you are a new user, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please email us at email@example.com
Unless you expressly agree, we will not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may disclose your personal information to third parties:
- To the extent that we consider it necessary to do so, we may disclose your personal information to Jarvis
- In the case of other third party service providers, we may do so solely in the course of their provision of services to us
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets
- If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our users will be one of the transferred assets
USE OF BULLETIN BOARD
We offer the opportunity for an Investor to sell their Bonds through a bulletin board that is available on the Platform.
Should the Seller receive an Offer to Buy, and wish to proceed with the transaction, they will need to contact the Buyer to confirm the transaction. The Seller and the Buyer can only use the data that they receive for the purposes of the transaction and not for any other purpose.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our secure servers. Any financial transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
In the case of communications by email you should note that, as emails are not encrypted (and may therefore be intercepted by third parties) and as the identity of the sender cannot be confirmed, you must NOT provide your security details by email and should avoid providing any personal data to us by email.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that some of these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
ACCESS TO INFORMATION
The Data Protection Act 1998 gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.