PLEASE READ THIS POLICY CAREFULLY BEFORE USING ANY OF THE SERVICES DISPLAYED ON OUR WEBSITE
Share In Ltd (we/us/our) are committed to protecting and respecting your personal data and your privacy. We recognise that your personal data is your property and that you have loaned it to us for specific purposes.
Unless otherwise required by law, the Information Commissioner’s Office (ICO) guidance or best practice, or in order to perform our contract with you, we will only process your personal data in the way we tell you or in the way you ask us to, and we will give it back to you at any time.
- This policy explains how any personal data we collect from you, or that you provide to us, will be processed by us or any processor on our behalf.
- Terms used within this policy shall have the meaning(s) given in the Data Protection Act 2018 (Act) and/or the General Data Protection Regulation (Regulation), as applicable
- By visiting our website located at https://www.sharein.com (our Website), you accept and consent to the practices described in this policy.
- Any changes we make to this policy will be posted on this page. You are advised to check back frequently as any changes will be binding on you when you continue to use the Website after the date of the relevant change.
- For more information relating to your rights under this policy, please see section 10.
- If you have any queries relating to this policy, please contact us at [email protected].
WHO WE ARE
- We are Share In Ltd, 5th Floor, 125 Princes Street, Edinburgh, EH2 4AD. We operate the Website and we are the data controller for the purposes of the Act and the Regulation.
- We are registered with the ICO to process your personal data and our registration number is ZA029742.
- Your data will be held by us on our secure servers located in the Republic of Ireland, but will be processed by our staff who work in the UK All of our staff receive data protection training on joining our team, which is updated at regular intervals thereafter (as appropriate to their role).
- By using the Website, you expressly consent to:
- provide us with the personal data necessary to allow you to use the Website;
- the processing of your personal data by us, or those specifically listed third parties, in accordance with this policy; and
- the transfer of your personal data to those third parties listed in this policy, for the reasons specified.
- You may withdraw your consent under 3.1 at any time. However, where the withdrawal of your consent prevents us from verifying your identity or otherwise monitoring who you are, we will be unable to provide you with the services you have requested, or to provide you with news and information about our services.
WHAT WE COLLECT
- We collect the following categories of data from you:
|Full name||Address (including postcode)||Date of birth||Email address|
|National Insurance number||Telephone number||IP addresses||Passport or driving licence (including passport/ driving licence number)|
- Where you make an Investment with one of our clients, you will be additionally required to provide your passport and any associated personal data contained on that document will be retained by us or our nominated payment gateway (from time to time).
- In addition to the above, we will also provide you with your Account Details, which includes your username which is either created by, or assigned to, you. The Account Details should be remembered by you, but will be stored by us in case you forget them.
HOW WE COLLECT YOUR DATA
The data listed in section 4 is collected in the following ways:
- By you registering for an Account with one of our clients – this is any information you give to our client that they request from you when signing-up for an Account.
Information collected – each time you visit our Website, whether through your home, work or a public network, your own computer or mobile device, ShareIn will automatically collect:
- technical information – your IP address (used by your computer or device to connect to the internet), and any internet browser type and version details; and
- visit-specific information – your URLs, Projects and Properties you viewed or searched for, your clickstream through the Website.
- Received from third parties – we work closely with our clients. Where you make an investment through one of their platforms, their personal data will be visible to some of our staff for platform administration and support purposes. More detail on what data we receive should be contained on their privacy policies.
- Each time you visit our Website, there is the functionality for you to request that we contact you.
WHAT WE DO WITH YOUR DATA
- Your data is primarily necessary to help us provide our services to you. We offer software that assists with your crowdfunding ventures, issuing of bonds and peer-to-peer lending. We also provide financial regulatory services as your appointed representative in dealings with the Financial Conduct Authority, and ISA management services.
Additionally, we will use all of your data you provide us 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; or
- changes to our Website or our services.
We use any data we collect about you (as a result of your visit to our Website) to:
- personalise and improve our services (including the Website and its security);
- deal with your inquiries and requests;
- administer and monitor traffic and behaviours on our Website for analysis, testing, research, statistical and survey purposes;
- ensure that any part of our Website (including any Content) is presented in the most effective manner for you and your computer or device, and to make improvements (where necessary); and
- keep our Website safe and secure.
- Where we change our services, or any applicable terms and conditions, we will contact you.
- Any data we obtain about you from third parties are used for the purposes of verifying your eligibility to submit an application and to make an investment through one of the clients displayed on our Website, and are acquired only to the extent we are unable to do so as a result of the information you provide to us.
- Once collected, we may retain your data for up to six years following the date of your last Investment or the date you close your Account (whichever is the later). This is to enable us to refer back to any transactions or records you are involved in (should we be required to do so).
HOW AND WHY WE DISCLOSE YOUR DATA
- We have put in place appropriate technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection laws. All data on our systems and databases is encrypted.
- Each member of staff has unique log-in details and authentication software requires these to access the systems. Staff have access to personal data only for the purposes of performing their roles, and all staff receive appropriate training (on joining and at regular intervals thereafter) commensurate to their role and the personal data they have access to.
- We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.