STATEMENT OF INTENT
This Privacy, Cookie and Data Use Policy of Share In Ltd (hereinafter referred to as “ShareIn”, “we” or “us”) explains how and why we collect personal information about you, what our policy on cookies is and how we can use your information.
We are committed to responsible management of personal information in accordance with the Data Protection Act 1998 and the Privacy and Electronic Communications (EC Directive) Regulations 2003. Please note that the registration number of Share In Ltd on the UK Data Protection Register is ZA029742 (see http://www.ico.gov.uk).
COLLECTION OF PERSONAL INFORMATION
In order to receive certain information and to use certain services on this site you may be asked to provide personal information about yourself such as your name, address, email address, date of birth, investment preferences and copies of information such as your passport page and other proof of ID. When you provide this information to us you consent to our use of that information in accordance with the terms of this Privacy, Cookie and Data Use Policy.
This information will be used (i) to provide you with the services that you have requested, (ii) to provide you with news and information about our services of the investee companies which are listed on this site, and (iii) generally in accordance with the uses permitted by this Privacy, Cookie and Data Use Policy.
If you no longer want to receive certain information from us then just let us know by email and we will either stop sending it or have to de-register you from all or part of this site (depending on the information concerned).
STORAGE OF PERSONAL INFORMATION
We will keep your personal information for as long as we need it to provide our services to you. If you make an investment in a company which is listed on this site then we will hold your personal information for a period of 7 years from the date of your last investment so that we can comply with our legal obligations.
We will try to keep personal information which we hold about you up to date, but if you think that we are holding information which is inaccurate or you are otherwise unhappy about our use of your personal information then please send us an email to let us know.
All information you provide to us or our third party suppliers (eg GoCardless) is stored on secure servers. Any payment 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 this site, you are responsible for keeping this password confidential. Please do not share this 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 this 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 (although as is the norm no guarantees can be given).
USE OF AND SHARING OF INFORMATION
We will not sell the personal information that we collect from you. We use the personal information which we collect from you to help us provide our services to you. Some data processing in relation to this site may be carried out for us by a third party (eg by GoCardless or by our solicitors etc.) and in some cases that may mean that the third party will receive your personal information. Furthermore as part of you making an investment in a company which is listed on this site then the investee company and our solicitors will be passed your personal information as well as copies of your ID documents to enable the investee company to issue shares to you and to generally comply with the law and perform ID checks of its own.
We use information held about you in the following ways:
- To ensure that content from our site is presented in the most effective manner for you and for your computer;
- 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 and generally to assist with the facilitation (by use of a platform but not by giving investment advice) and completion of the investments which users of this site wish to make in companies which are listed on this site;
- To allow you to participate in interactive features of our service, when you choose to do so; and/or
- To notify you about changes to our service.
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:
- 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 (although this will be done under obligations of confidentiality);
- If the shares of ShareIn or substantially all of its assets are acquired by a third party, in which case personal data held by it about its users, investors and investee companies will be one of the transferred assets (although again this will be done under obligations of confidentiality);
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (eg in the UK to the Police, the Financial Conduct Authority, the Information Commissioner etc..);
- In order to protect the rights, property, or safety of ShareIn, our users, or others. This includes without limitation exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Apart from this we will not share or transfer any personal information with any other third party unless we are required to do so by law.
Please note that we may from the information which you supply to us provide our advertisers and/or other third parties with aggregate information about our users which does not contain any personal identifiers (for example, we may inform them that 200 men aged under 40 have clicked on their advertisement on any given day or have chosen certain investment preferences). This non-personalised information may be sold by us. We may also use such aggregate information to help such advertisers/other third parties reach the kind of audience they want to target (for example, men in SW1). 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.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of this site. They include, for example, cookies that enable you to log into secure areas of this site, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around this site when they are using it. This helps us to improve the way this site works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to this site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to this site, the pages you have visited and the links you have followed. We will use this information to make this site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose in accordance with the statements set out above.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of this site.
This site logs your Internet Protocol (I.P.) address. All computers that are linked to the Internet have an I.P. number. An I.P. address does not provide identifiable personal information.
ACCESS TO INFORMATION
You are entitled under the Data Protection Act 1998 to a copy of the personal information that we hold about you if you apply to us in writing. We may make a small charge of £10 for dealing with any such request. Please write to us at:The Directors
Share In Ltd
125 Princes Street
This site provides links to other websites. Our Privacy, Cookie and Data Use Policy applies only to this site and we are not responsible for the privacy and/or data capture and use practices of third party sites.
CHANGES TO OUR PRIVACY, COOKIE AND DATA USE POLICY
Any changes we may make to our Privacy, Cookie and Data Use Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.
Questions, comments and requests regarding this Privacy, Cookie and Data Use Policy are welcomed and should be addressed to firstname.lastname@example.org.