1. How we treat the information we gather
2. Collecting personal information
1. We may collect, store and use the following kinds of personal information: o Information about your computer and about your visits to and use of our Sites (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
- Information that you provide to us when registering with our Sites (including your email address); o information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);
- information that you provide to us when using the services on our Sites, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use); o information relating to any investments, bond applications or any other transactions that you enter into via our website (including your name, address, telephone number and email address and bank account details for repayment purposes)
- information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication); and o any other personal information that you choose to send to us.
2. Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
3. Using personal information
1. Personal information submitted to us through our Sites will be used for the purposes specified in this policy or on the relevant pages of the website.
2. We may use your personal information to:
- administer our Sites and business;
- enable your use of the services available on our Sites;
- process bond applications and other investment services that you have specifically requested;
- send you email notifications that you have specifically requested;
o send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
o send you marketing communications relating to our which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
o gather anonymous statistical information about our users (where this data will not be able to identify any individual user);
o deal with enquiries and complaints made by or about you relating to our Sites;
o keep our Sites secure and prevent fraud; and o verify compliance with the terms and conditions governing the use of our Sites.
3. If you submit personal information for publication on our Sites, we will publish and otherwise use that information in accordance with the licence you grant to us.
4. We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
4. Disclosing personal information
1. We may disclose your personal information to any of our employees, officers, insurers and professional advisers insofar as reasonably necessary for the purposes set out in this policy.
2. We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
3. We may disclose your personal information:
o to the extent that we are required to do so by law;
o in connection with any on going or prospective legal proceedings;
o in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
o to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
4. Except as provided in this policy, we will not provide your personal information to third parties.
5. International data transfers
1. Personal information that you publish on our Sites or submit for publication on our Sites may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
2. You expressly agree to the transfers of personal information described in this Section 5.
6. Retaining personal information
1. This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
2. Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
3. Without prejudice to Section 6.2, we will usually delete personal data falling within the categories set out below at the date/time set out below: o Bank Account Information and other personal information in relation to any bond investment will be deleted upon maturity of your investment.
4. Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data:
o to the extent that we are required to do so by law;
o if we believe that the documents may be relevant to any on going or prospective legal proceedings;
and o in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
7. Security of personal information
1. We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
2. We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
3. You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
1. We may update this policy from time to time by publishing a new version on our website.
2. You should check this page occasionally to ensure you are happy with any changes to this policy.
9. Your rights
1. You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to: o the payment of a fee (currently fixed at GBP 10);
and o the supply of appropriate evidence of your identity[(for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
2. We may withhold personal information that you request to the extent permitted by law.
3. You may instruct us at any time not to process your personal information for marketing purposes.
4. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes. For a copy of the personal information we hold about you, write to Antonia Symeonidou, email@example.com or Antonia Symeonidou, Cambridge Innovation Hub, 19 Broadway, Grantchester, Cambridge, CB3 9NQ
10. Third party websites
1. Our Sites include hyperlinks to, and details of, third party websites.
2. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
11. Updating information
1. Please let us know if the personal information that we hold about you needs to be corrected or updated.