Your privacy is very important to us and we want to be as transparent as possible regarding how we use, store and share your information. We respect your right to privacy and will only process personal information you provide to us in accordance with the UK Data Protection Act 1998, the General Data Protection Regulation (GDPR) (EU) 2016/679, and other applicable privacy laws.
- The information we collect about you
- How we use that information
- How we store that information
- How we share that information
- Your rights with respect to that information
- Other important privacy matters
If you have any questions about how we collect, store and use personal information, or if you have any other privacy-related questions, please contact us.
The information we collect about you
We collect information about you when you provide it to us, and we automatically collect information about you when you use and browse through our website and engage with our platform (whether directly or via a third party).
Information you provide:
Account information: We collect your personal information when you register with us. When you access and browse this website (including when you submit personal information to us through data entry fields on the website), we may collect such identification details as we require, including your name, date of birth, gender, postal address, phone number and e-mail address.
Investor relations: If you choose to submit information to our support team, for example regarding a problem you are experiencing with the website, or if you speak to one of our representatives directly, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
Surveys & promotions: We may also collect other content that you submit to our website or through social media. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys or promotions.
Information we collect from your engagement with our platform:
Your use of the platform: We track certain information about you when you visit and interact with our website and services. This information includes the features you use on the website, the links you click on, and the emails you open which we send through our customer relationship management software providers.
Connection information: We collect information about the type of device you are accessing the website on, such as a computer, phone, tablet, or other devices. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location. How much of this information we collect depends on the type and settings of the device you use to access the website.
Cookies: Cookies are files that we can transfer to your web browser so that we can recognise it. Some cookies are necessary (i.e. without it, we cannot operate the platform or website) or provide functionality (i.e. to recognise you when you return to our website or platform). Others allow us to understand and save your preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We and our partners use technology such as cookies on our site to personalise content and ads, provide social media features, and analyse our traffic. Those third parties include:
- AdRoll, Inc (see also https://www.adrollgroup.com/privacy)
How we use that information
If you are an individual in the European Economic Area, we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on how you use our platform and website. This means we collect and use your information only where: (1) we need it to perform our contract with you, including to provide support and to protect the security of the platform; (2) there is a legitimate interest for using it (which is not overridden by your data protection interests), such as for security purposes, research & development, marketing and promoting our offerings to you, and to protect our legal rights and interests; (3) you give us your consent to do so for a specific purpose; or (4) we need to process your data to comply with a legal obligation.
Where we are using your information because we or a third party have a legitimate interest to do so, you have the right to object to that use (though, in some cases, this may mean no longer using our platform).
We (or third party data processors acting on our behalf) may collect, store and use your personal information listed above for the below listed purposes:
- Access: To make our website available to you, and authenticate you when you log-in
- Keeping in touch with you: Where you have opted-in to receiving such communications, to contact you (including by SMS and e-mail) with potential investments and services which we think may interest you, for example, we would like to notify you when a new investment opportunity is launched on our platform, inform you about promotions we are offering to our members, share our regular market insights, inform you about new features and to request your responses to surveys
- Investor relations: To respond to your queries, to respond to requests for assistance, to resolve technical issues you may encounter, to analyse information about such issues, and to repair and improve the platform
- Security: To verify activity, to monitor suspicious or fraudulent activity and to identify violations of our policies
- Legal purposes: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory and audit functions. We may also disclose your personal information where we are required to do so by applicable law, by a governmental body or by a law enforcement agency
- Research & development: For compiling aggregate statistics, monitor activity patterns, and understand most effective communication types, in all cases including through the use of data analytical tools (which may feature profile building), in order for us to understand how members interact with our platform, and for us to develop and improve our platform in a manner most useful to you. We may convert your information into statistical or aggregated data which cannot be used to identify you.
- Your consent: Where you have provided your consent to our use of the information for a specified purpose not listed above. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place.
How we store that information
We use data service providers to host the information we collect, and we use technical measures to secure your data. Whilst we take appropriate technical and organisational measures to safeguard the personal information that you provide to us, no transmission over the Internet can ever be guaranteed to be secure. Consequently, please note that we cannot guarantee the security of any personal information that you transfer over the Internet to us.
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymise your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
How we share that information
When you use the website and our platform, we share certain of your personal information (subject to applicable data protection laws) with certain third parties, for the purpose of being able to deliver our website and platform to you.
- Affiliates: Global Alternatives Operations Limited and its affiliated group companies.
- Service providers: We work with third-party service providers (being data processors) in order for us to deliver, develop and maintain the website, the platform and vital infrastructure to you. The services include underlying platform infrastructure, website development and maintenance, customer relationship management software providers, marketing platform providers and other services. If such a service provider needs to access information about you to perform services on our behalf, they do so under contract with us.
- Compliance and security: in exceptional circumstances we may need to share your information with courts, regulators and government bodies, and we may also need to share the information with other third parties if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, (b) enforce our agreements, policies and terms and conditions, (c) protect the security or integrity of our platform and website, (d) protect Global Alternatives Operations Limited, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information.
- With your consent: we may share your information with third parties when you give us consent to do so. Note that we will never sell or rent your personal information to any other third party unless you have consented to this. If you do consent but later change your mind, you may contact us and we will cease any such activity.
- Business restructuring: If a third party acquires all (or substantially all) of our business and/or assets, or if we have a merger or re-organisation, we may disclose your personal information to that third party in connection with the acquisition.
Your rights with respect to that information
You have the following rights:
- to ask us to provide you with copies of personal information that we hold about you at any time, subject to any fee specified by law;
- to ask us to update and correct any out-of-date or incorrect personal information that we hold about you free of charge;
- to opt out of any marketing communications that we (or any third party to whom we have disclosed your personal information with your consent) may send you;
- to be informed about the processing of your personal information;
- to object to the processing of your personal information (noting that this may mean that you are unable to use our platform and us being unable to provide any further services to you);
- to restrict the processing of your personal information (noting that this may mean that you are unable to use our platform and us being unable to provide any further services to you);
- to have your personal information erased or the ‘right to be forgotten’ (noting that this may mean that you are unable to use our platform and us being unable to provide any further services to you);
- to request access to your personal information and information about how we process it; and
- to move, copy or transfer your personal information (known as ‘data portability’).
If you are a resident of the European Economic Area and believe we maintain your personal information within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to the UK Information Commissioner’s Office. It has enforcement powers and can investigate compliance with data protection law in the UK.
Other important privacy matters
We do not and will not knowingly collect information from any unsupervised child under the age of 18. If you are under the age of 18, you will not be onboarded or otherwise allowed to engage with any of our platforms.