- In this policy,
- the words “you” and “your” mean both you and any entity or firm you’re authorised to represent;
- the word “customer” means a third party customer of InvestorHub.
- As a company, we are dedicated to safeguarding the personal data of our customers and employees. In accordance with this commitment, where applicable, we comply with the principles of
- the UK Data Protection Act 2018 (UK-GDPR);
- the EU General Data Protection Regulation 2016/679 (GDPR); and
- the California Consumer Privacy Act of 2018, AB 375 (CCPA).
when collecting, utilising, and handling personal data. This includes adherence to principles of legality, fairness, and transparency; limiting data collection to specific purposes; minimising the amount of data collected; ensuring accuracy; limiting data storage; maintaining integrity and confidentiality; and being accountable for data protection.
- We recognise the importance of protecting the privacy of personal information. We employ strict policies and security measures to protect the information you provide us.
- We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
Information That We Collect
- We only collect information on behalf of our customers or to improve our products.
- We collect information in the following ways:
- Information you give to us directly. This includes:
- Information about you. This might include your name, email, holder identification number, any representative participant identification number, contact information, address, telephone number, images, photographs, social media profile links, and profile information such as age, gender, location, physical features or any other information you intentionally provide on the InvestorHub platform;
- Financial information. This includes information required to facilitate the purchase of securities offer by our Customer, including your financial and investment decisions, your investor or member status, your investment qualifications and any special regulatory or legal exemptions to which you are entitled or subject;
- Platforms interactions. This includes structured and unstructured interactions you submit to us, including any answers to questions or surveys that we send to you, any public or private messages that you send to our Customers or other users, any “likes” or other sentiment indicator actions you interact with, or any other information which you submit to us on our platform.
- Information we collect through your use of our services. This includes:
- information collected by our server, from or about the computers, phones, or other devices where you access our services, including the internet protocol (IP) address used to connect your computer to the Internet, operating system, browser and platform, the average time you spend on InvestorHub, the pages of InvestorHub you have visited, your use of InvestorHub, your language settings and time zone and your device fingerprint;
- cookies and other similar identifiers, which we send to your computer’s browser for session identification purposes.
- Information from our customers. We receive information provided to us by our customers, including:
- Information about your interactions with our customers, including user identifiers, your status as a member of our customer, the number of securities you hold with respect to our customer, any information about your past, present or future interest in our customer’s securities, and other descriptions about you that they provide to us;
- Information about you, including, your full name, your address, your email address, your telephone number, your email, your holder identification number, any representative participant identification number, and other contact information.
- Information from third parties at your request. If you choose to authenticate with InvestorHub using a social media account, we may receive your email address, your full name and your social media profile picture, unique user identifiers, social media profile links, and personal profile information such as age, gender, location, interests and physical features.
Purposes and Use
- We may use, or disclose to third parties, the information you give to us directly and the information we receive from third parties for the following purposes:
- to provide public facing websites and online communications platforms on behalf of our Customers;
- to assist our Customers to identify their shareholders and collect contact information for the purpose of delivering investor relations services;
- to assist our Customers in the conduct investor relations activities;
- provide, maintain, protect and improve our services for the benefit of our customers, to develop new services, and to protect our services and our customers;
- keep a record of your communications with us to help solve any issues or disputes that might arise;
- help verify accounts and activity, and to promote safety and security on and off of our services, such as by investigating suspicious activity or violations of our terms or policies;
- comply with the law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
- We may use the information we collect through your use of our services to:
- measure the use of InvestorHub and to administer and improve InvestorHub. We interpret this statistical data in our continuing effort to improve InvestorHub and your user experience.
- gather information on which web pages are visited and how often, to make InvestorHub more user friendly, and to give you a better experience when you return to InvestorHub.
- We may combine the information you give to us directly with the information we collect through your use of our service, our customers or from third parties.
- In delivering our products or collecting and using your personal information, we may be required to disclose some of your personal information to third party organisations, including external service providers; our legal, accounting, financial or other professional advisors; and regulatory or government authorities as required by law.
GDPR Data Subject Rights
- The GDPR and the UK-GDPR provide certain rights for residents of the European Economic Area and United Kingdom of Great Britain and Northern Ireland. Data Subject rights under these regimes include the following:
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
- Deletion: You can request that we erase some or all of your Personal Data from our systems.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. However, if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
- If you are subject to the GDPR or the UK-GDPR, you are entitled to exercise these rights, and any other rights arising from the UK-GDPR or GDPR by contacting us at email@example.com.
- The CCPA provides certain rights regarding how personal data is collected and used with respect to residents of California, United States of America. Rights under the CCPA include the following
- the right to request that we disclose our collection and use of your personal information during the past 12 months, specifically:
- Categories of personal information collected;
- Sourced of personal information collected;
- Our business purpose for collecting (or selling) that personal information;
- Categories of third parties with whom we share your personal information;
- Categories of personal information sold or disclosed to third parties.
- the right to request a copy of the personal information collected prior to your request in the past 12 months;
- the right to request deletion of that information (with exceptions noted by law);
- the right to request that your personal information not be sold to third parties, if applicable; and
- the right not to be discriminated against because you exercised these rights.
If you are subject to the CCPA, you are entitled to exercise these rights, and any other rights arising from the CCPA by contacting us at firstname.lastname@example.org.
- In addition to these statutory rights, you are entitled to request access to and correction of all personal data you provide us, or to remove your name from our records at any time by contacting us at email@example.com.
Data Security and Retention
- We use a number of security measures to protect the information you provide to us. We protect your personal information by:
- restricting internal and external access to your personal information; and
- maintaining our technology systems to prevent unauthorised computer access; and
- securely destroying your personal information when your personal information is no longer needed.
- We use industry standard encryption technology to transmit all user information.
Cross Border Data Flows
- You can submit your request for disclosure, copies or deletions of your personal information to InvestorHub by contacting us (or contact us with your questions regarding our collection, use and sharing of your personal information): firstname.lastname@example.org
- To contact our Data Protection Officer:
Attn: Data Protection Officer
- Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is:
Instant EU GDPR Representative Ltd.
Adam Brogden email@example.com
INSTANT EU GDPR REPRESENTATIVE LTD
12A Lower Main Street, Lucan Co. Dublin
K78 X5P8 Ireland