We respectyour concerns about privacy. This Privacy Notice (the “Notice”) applies to personal data we collect in connection with your use of our platform, our websites and our mobile applications (the “Services”). This Notice describes the types of personal data we obtain in connection with your use of the Services, how we use the personal data, and with whom we share it. We also describe the rights you may have and how you may contact us about our privacy practices. We are the data controller in respect of personal data that we collect in connection with your use of the Services or that you otherwise provide to us. Our contact details can be found at the ‘HOW TO CONTACT US’ section at the end of this Notice.
1. HOW WE OBTAIN INFORMATION ABOUT YOU
We collect personal data that you choose to provide to us in connection with your use of the Services, including, but not limited to, your first and last name, physical address, e-mail address, or telephone number, such as when you communicate with us (for example by sending us an email).
Where requested by you, we may acquire personal data about you from third parties, such as custodians. In addition, we may share the personal data between our affiliates. We may also collect personal data in other contexts that we will notify you of at the time.
2. INFORMATION WE OBTAIN
2.1 INFORMATION THAT YOU PROVIDE TO US
Personal data that you provide directly to us will be apparent from the context in which you provide it, for example:
We require certain of your personal data to provide the Services to you. This information is marked with a (*) when we ask you to provide it. If you do not provide any such personal data, you may be unable to proceed with the Service.
2.2 INFORMATION THAT WE COLLECT AUTOMATICALLY
Our web servers may log information such as your operating system type, device identifier, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The web server logs may also record information such as the address of theweb page that referred you to our app or website and the IP address of the device you use to connect to the Internet. They may also log information about your interaction with the Services, such as which pages you visit. We may also collect information from your browser to help us understand and respond to your needs and support requests
2.3 INFORMATION THAT WE OBTAIN FROM THIRD PARTIES
We obtain information from the third parties that you have instructed to send us information.
3. HOW WE USE INFORMATION THAT WE OBTAIN
3.1 INFORMATION THAT YOU PROVIDE TO US
We may use personal data that you provide to us to provide and administer the Services. We use the personal data for these purposes because we have a legitimate business interest in providing the Services to our customers and other interested individuals that is not overridden by your interests, rights and freedoms to protect personal data about you or, if you are acting in an individual capacity, because it is necessary for us to process the personal data to provide the Services to you.
In addition to the uses discussed above, we may also use the personal data you provide to:
We use the personal data for the purposes described above because we have a legitimate interest in operating and improving our business that is not overridden by your interests, rights and freedoms to protect personaldata about you.
We may also use the personal data that you provide to protect against and prevent fraud, claims, and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use personal data for these purposes when it is necessary to protect, exercise or defend our legal rights, or when we are required to do so by law that applies to us.
3.2 INFORMATION THAT WE COLLECT AUTOMATICALLY
We use personal data that we collect automatically through cookies, non-cookie-based tokensand other automated means for purposes such as customizing and enhancing our users’ uses of the Services, collecting statistics about your usage, and understanding the manner in which our visitors browse our websites. We also use the information to help diagnose technical and service problems. We use the personal data for the purposes described above because we have a legitimate interest in operating and improving our Services that is not overridden by your interests, rights and freedoms to protect personal data about you.
3.3 OTHER USES OF INFORMATION
In addition to the uses described above, we may use personal data that you provide to us or that we collect for other purposes. Where that is the case, we will provide an additional privacy notice to you that describes the purposes for which we will use the personal data and our legal basis for doing so.
4. INFORMATION WE SHARE
We do not sell or otherwise disclose personal data that you provide to us or that we collect in connection with your use of the Services, except as described here. We may share personal data you provide to us or that we collect with:
When we share personal data with service providers that perform services on our behalf such as hosting providers and advisers, we enter into legally binding agreements requiring them to use or disclose personal data only as necessary to perform services on our behalf or comply with applicable legal requirements.
In addition, we may disclose personal data about you (a) if we are required or permitted to do so by law orlegal process, for example due to a court order or a request from a law enforcement agency, (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity, or (d) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).
5. HOW LONG WE KEEP INFORMATION
The time period for which we keep personal data depends on the purpose for which we collected it. In all cases we keep it for as long as necessary to fulfil the purposes for which we collected it. We will then delete the personal data, unless we are legally required to retain it or if we need to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes).
Subject to any applicable legal requirements, we typically retain personal data as follows:
Personal data you provide to us through your use of the Services: we keep this information for the duration of our commercial relationship with you and for up to three months thereafter.
Website and mobile application logs: we keep website and mobile application logs, which may contain your personal data, for several months.
6. YOUR RIGHTS AND CHOICES
You may have the following rights in relation to personal data that we hold about you:
To request confirmation of whether we process personal data relating to you
To request that we rectify or update your personal data that is inaccurate, incomplete or outdated.
To request that we erase your personal data in certain circumstances, such as where we collected personal data on the basis of your consent, and you withdraw your consent;
To request that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal data;
Where you have given us consent to process your personal data, to withdraw your consent; and
You may contact us by e-mail or as described in the “HOW TO CONTACT US” section below to exercise your rights described above.
7. UPDATES TO OUR ONLINE PRIVACY NOTICE
We may update this Notice periodically and without prior notice to you to reflect changes in our personal data practices or relevant laws. We will post the updated version and indicate at the top of the notice when it was most recently updated.
8. HOW TO CONTACT US
If you have any questions or comments about this Notice or any issue relating to how we collect, use, or disclose personal data, or if you would like us to update information, we have about you or your preferences, you may contact us:
By e-mail at: In writing at: email@example.com