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Privacy & Cookie Policy

Privacy & Cookie Policy

StartThat Limited (we/us/our/the Company) is committed to protecting and respecting your privacy.

The Site is not intended for children and we do now knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

The Site is owned and operated by StartThat Limited (08493436 ) of 11 Millcross, Clevedon, England, BS21 5JL (our Company Address).

The Company processes personal data as a Data Controller and Data Processor as defined in the Directive and the General Data Protection Regulation (GDPR). The Company has a Data Protection Officer (“DPO”) who is responsible for matters relating to privacy and data protection. This Data Protection Officer is Oliver Kenyon and they can be reached at the following address: contact@investopen.com. 

The Site contains links to and from the websites of our partner networks, advertisers and affiliates or to websites shared by other users. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

1. Data We Collect About You

We collect and process personal information about you so we can provide our Site and Services to you. It’s important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

The data we collect and process about you is explained in the sections below.

1.1 Data You Give Us

You give us information about you by filling in forms on our Site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use the Site, fill out fields in your profile, fill out our contact form, subscribe to our marketing database, participate in discussion boards or other interactive functions on our Site, enter a competition, promotion or survey and report a problem with the Site.

The information you may give us includes usernames, email address or login details (e.g. password), date of birth, financial and credit card information, location data and behavioural data (e.g. in the ‘about you’ section). We rely upon your explicit consent to use and process the data described above.

1.2 Data We Automatically Collect

Each time you visit or use our Site, we automatically collect the following information:

  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, location, network data, browser plug-in types and versions, languages, operating system and platform;
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Site (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

We use this information as statistical data about your browsing actions and patterns, for system administration, and to evaluate, provide, protect or improve our Services (including by developing new products and services). Because we collect, use and share this information in the aggregate, it does not identify any individual.

We rely upon your explicit consent  to use and process the data described above. 

1.3 Data We Receive From Third Parties

We use third parties such as Facebook, Google and others to collect cacking and pixel data. For more information on how these companies handle your personal data, please refer to their privacy policies. 

We rely upon your explicit consent to use and process the data described above.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

2. How We Use Your Data

We use your data to operate our Site and carry out our Services in the following ways:

  • For the purposes of making you a registered member of the our Site, in order for you to contribute Content to the Site.
  • To administer and manage your account, to provide you with information you request from us, and to carry out any other obligations arising from any contracts entered into between you and us.
  • To ensure that content from our Site is presented in the most effective manner for you and for your device.
  • To allow you to participate in interactive features of our Site and Services when you choose to do so.
  • To respond to communications from you and to provide you with information about our Services, including notifying you about changes to our Site, or Services.
  • To send out newsletters and other marketing alerts and communications.

We also use your data to make our Site and Services better in the following ways:

  • To measure or understand the effectiveness of advertising we serve to you and others, deliver relevant advertising to you and make suggestions and recommendations to you and other users of the Site about goods or services that may interest you or them.
  • To administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
  • As part of our efforts to keep the Site safe and secure, e.g. by conducting analysis required to detect malicious data and understand how this may affect your IT system.

We will not send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under applicable data protection laws. We will only contact you if we have the requisite permission to do so (either on the basis of your consent where we have requested it, or our legitimate interests to provide you with marketing communications where we may lawfully do so). 

We will get your express opt-in consent before we share your personal data with any third parties for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by logging into the Site and checking or unchecking relevant boxes to adjust your marketing preferences. Also, by following the opt-out links on any marketing message sent to you or by contacting us at any time. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please notify us in writing or by email at contact@investopen.com. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, or other transactions.

3. How We Secure Your Data

All of your personal information is protected and we have put in place appropriate physical, electronic, and management procedures to safeguard and secure the data we collect. Your information is stored on secure cloud databases, internal servers, server maintenance, backups, security and on third party softwares. Your information is only accessible by employees who have authorised access rights to such information. All of your payment information is encrypted using SSL technology.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we use strict procedures and the security features described above to try to prevent unauthorised access.

4. How Long We Store Your Data

We only keep your personal information for as long as it’s necessary for our original legitimate purpose for collecting the information and for as long as we have your permission to keep it. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We will delete your personal information when you delete your account by emailing us at contact@investopen.com and requesting your account be deleted. 

5.1 Parties with whom we share your information

Save in the circumstances below, we do not share your data with any third parties.

We may share your personal data:

  • If the third party is a member of our group (which means any subsidiaries or ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).
  • 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.
  • If the Company or substantially all of its assets are acquired by a third party, in which case personal data will be one of the transferred assets and the purchaser will be permitted to use the data for the purposes for which it was originally collected by us.
  • If we’re under a duty to disclose or share your personal data in order to comply with any legal obligation, enforce or apply our Terms & Conditions and other agreements, or to protect the rights, property, or safety of the Company, our customers, or others (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

5.2 Parties with whom you may choose to share your information

You may choose to share any information, or other content that you voluntarily submit to the Site either on public forums and public areas of the Site or within private messages . Such data will become available and viewable by other users as controlled by any applicable privacy settings that you define. To change your privacy settings on the Site, login to your account and go to www.investopen.com/account/preferences. Once you have shared your content or made it public, that content may be re-shared by others.

If you choose to connect to social media networks from the our Site or post any of your content on our Site  to those networks, then in accordance with your social media privacy settings, the personal information that you post, transmit, or otherwise make available on the social media platform may be viewed and/or used by other users of those networks and we have no control over such viewing and use and cannot prevent further use of such information by third parties. When you interact with us through social media networks, you acknowledge that we may access your information that is held by that account, solely in accordance with your social media privacy settings. Any links to social media are not under our control and remain solely your responsibility. You acknowledge that any information posted via social media through our Site , or any third party you allow to access your content, is done entirely at your own risk and that by posting to a public platform you make that information visible to third-parties who can use that information at their discretion.

You may review, modify, update, correct or remove any personal data you have submitted to the Site at any time. If you remove information that you posted to the Site , copies may remain viewable in cached and archived pages of the Site, or if other users or third party APIs have copied or saved that information. 

Always think carefully before disclosing personal data or other information to other users or otherwise posting personal data on the Site. It’s important that you’re aware that any data you choose to disclose on the Site may then be viewed and even used by other users (in accordance with your settings and this Privacy Policy). We do not control the contents of communications made between users (although you can make a complaint about another user by contacting us using the information provided in the Contact section below).

You must respect the privacy of others and you must not disclose any personal details about other people including your family, friends, acquaintances, or other persons that may be misleading or cause them harm or offence. It is your responsibility to obtain their prior express permission in respect of any submission of their data at any time. 

6. International Transfers

The data that we collect from you is transferred to, and stored at, a destination outside the European Economic Area (EEA). By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated as securely as it would be within the EEA and under the GDPR. Such steps may include our entering into contracts with any third parties we engage and the use of Commission-approved Model Contractual Clauses. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

You can obtain more details of the protection given to your personal data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us as described in the Contact paragraph below.

7. Your Rights

7.1 Lawful Bases

We will ensure that your personal data is processed lawfully, fairly, and transparently and that it will only be processed if at least one of the following bases applies:

  • You have given your clear consent to the processing of your personal data for a specific purpose.
  • Processing is necessary for the performance of a contract to which you are a party (or for us to take steps at your request prior to entering into a contract with you).
  • Processing is necessary for our compliance with the law.
  • Processing is necessary to protect someone’s life.
  • Processing is necessary for us to perform a task in the public interest or in the exercise of official authority and the task/function has a clear basis in law.
  • Processing is necessary for our legitimate interests or the legitimate interests of a third party, except where there is a good reason to protect your personal data which overrides those legitimate interests, such as allowing us to effectively and efficiently manage and administer the operation of our business, maintaining compliance with internal policies and procedures, monitoring the use of our copyrighted materials, offering optimal, up-to-date security and obtaining further knowledge of current threats to network security in order to update our security.

7.2 Data Subject Rights

Under the GDPR, you have the right to:

  • Withdraw your consent to the processing of your personal data at any time.  Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so (such as to comply with a legal obligation).
  • Be informed of what data we hold and the purpose for processing the data, as a whole or in parts.
  • Be forgotten and, in some circumstances, have your data erased by ourselves and our affiliates (although this is not an absolute right and there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it).
  • Correct or supplement any information we hold about you that is incorrect or incomplete.
  • Restrict processing of the information we hold about you (for example, so that inaccuracies may be corrected—but again, there may be circumstances where you ask us to restrict processing of your personal data but we are legally entitled to refuse that request).
  • Object to the processing of your data.
  • Obtain your data in a portable manner and reuse the information we hold about you.
  • Challenge any data we use for the purposes of automated decision-making and profiling (in certain circumstances—as above, there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request).
  • Complain to a supervisory authority (e.g. the Information Commissioner’s Office (ICO) in the UK) if  you think any of your rights have been infringed by us. (We would, however, appreciate the chance to address your concerns, so please contact us prior to taking this step).

You may exercise your rights above by contacting us using the contact details below and we will comply with your request unless we have a lawful reason not to do so. You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 

You have the right to ask us not to process your personal data for marketing purposes. We will get your express opt-in consent before we use your data for such purposes or share your personal data with any third parties for such purposes, but you can exercise your right to prevent such processing by contacting us at the Company Address, via email at contact@investopen.com, or by unsubscribing using the links contained in the marketing emails.

You may revoke your consent for us to use your personal data as described in this Privacy Policy at any time by emailing us at  contact@investopen.com , and we will delete your data from our systems. To enforce any of the above rights, please contact us at our Company Address or via email at  contact@investopen.com .

We will notify you and any applicable regulator of a breach of your personal data when we are legally required to do so. 

Cookies

A cookie is a small file of letters and numbers that we store on your browser. Cookies contain information that is transferred to your computer's hard drive (or the hard drive of another relevant device). We use cookies to distinguish you from other users on the Site, to tailor your experience to your preferences, and to help us improve the Site.

Some of the cookies we use are essential for the Site to operate. If you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our Site. 

Before any non-essential cookies are placed on your device, you will be shown a pop-up message requesting your consent to setting those cookies. By default, most internet browsers accept cookies, but you can choose to enable or disable some or all cookies via the settings on your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. For further details, please consult the help menu in your internet browser.

We use the following cookies:

  • Strictly necessary cookies. These cookies are required to save your session and to carry out other activities that are strictly necessary for the operation of the Site. They include, by way of general example, cookies that enable you to log into secure areas of the Site, use a shopping cart, or make use of e-billing services.  These cookies are session cookies, which means they’re temporary and will expire when you close your browser.
  • Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors move around the Site when they’re using it.  These cookies help us improve the way the Site works by, for example, ensuring that users are finding what they’re looking for easily.
  • Functionality cookies. These cookies are used to recognise you when you return to the Site. They enable us to personalise our content for you, greet you by name and remember your preferences.
  • Targeting cookies. These cookies record your visit to the Site, the pages you visit, and the links you follow.  We use this information to make the Site and the advertising displayed on it more relevant to your interests. We also share this information with third parties for the same purpose.
  • Social Media cookies. These cookies work together with social media plug-ins. For example, when we embed photos, video and other content from social media websites, the embedded pages contain cookies from these websites. Similarly, if you choose to share our content on social media, a cookie may be set by the service you have chosen to share content through.
  • Third Party cookies. We use third party cookies on the Site for advertising, anonymously tracking which users are visiting the site and some are set by content embedded into some pages such as YouTube and other media providers. Please note that we do not control cookies placed by third parties and our Site does not block them. Please check the relevant third-party website for more information about these cookies.
  • Registration Registration and maintaining your preferences. This includes ensuring that you can stay logged in and keeping the site in the language or appearance that you requested.
  • Advertising cookies. (possibly third-party). If this site displays advertising, cookies may be set by the advertisers to determine who has viewed an ad or similar things. These cookies may be set by third parties, in which case this site has no ability to read or write these cookies.
  • Other third-party cookies. For things like Facebook or Twitter sharing. These cookies will generally be set by the third-party independently, so this site will have no ability to access them.

These are the main cookies we set during normal operation of the software.

  • xf_session
    • Stores the current ID of your session.
  • xf_user
    • Stores a key, unique to you, which allows us to keep you logged in to the software as you navigate from page to page.

You have the right to opt out of social media cookies and third-party cookies and to object to automated profiling. To enforce either of these rights please contact us at contact@investopen.com.

Changes To Our Privacy & Cookie Policies

Any changes we may make to our Privacy & Cookie Policies in the future will be posted on this page and, where appropriate, notified to you by email. You will be deemed to have accepted the terms of the updated Privacy & Cookie Policies on your first use of the Site following the alterations. Please check back frequently to see any updates or changes to our Privacy & Cookie Policies.

Contact

Questions, comments and requests regarding this Privacy & Cookie Policy are welcomed and should be addressed to our Company Address or to our email at contact@investopen.com .

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