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Initiate Consultancy Limited (“Initiate”, “we”, “us” or “our”) is committed to protecting and respecting your personal information and your privacy.
1. About us
1.1 For the purposes of the Data Protection Act 2018 (the “Act”), the data controller is Initiate Consultancy Limited. We are registered with the Information Commissioner’s Office with registration number: ZA681563
1.2 Initiate Consultancy Limited is a company registered in England and Wales (registration number 11903774), whose registered office is at 18a/20 King Street, Maidenhead, SL6 1DT, UK.
1.3 We will only process personal information in accordance with the Act, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any other applicable privacy laws.
2. Which personal information will we collect?
2.1 We may collect and process any of the following information about you:
2.2 Information you give us. You may give us information about yourself by using the online forms provided on the Website or by corresponding with us by phone, e-mail or otherwise. This includes, without limitation, information you provide when you sign-up and register to use the Website, enter into a deal via the Website, ask a question via the Website, participate in discussion boards or other social media functions on the Website and/or when you report a problem with the Website or our services.
2.3 The information you give us may include:
a) your name;
b) your job title
c) your business address;
d) your telephone number and email address; and
e) your business bank or building society account details and credit or debit card information.
f) your IP Address
2.4 Information we collect about you. Each time you visit the Website we may automatically collect any of the following information:
a) technical information, including the Internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, browser plug-in types and versions, operating system and platform; and
b) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), 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.
2.5 Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on the Website. We work closely with third parties (including, for example, business partners, suppliers of technical and payment processing services, advertising networks, analytics and search information providers and credit reference agencies) and may receive information about you from them.
3. How will your personal information be stored and used?
3.1 We, or third party data processors acting on our behalf, may collect, use and store the personal information listed above for the following reasons:
a) to allow you to access and use the Website and to register for an online account;
b) to provide you with content which is tailored specifically to you;
c) to provide you with the information and services that you request from us;
d) to enable you to make applications to become an investor;
e) to verify your identity in order to prevent and detect¬ money laundering and fraud;
f) to carry out credit reference checks and other regulatory checks;
g) to carry out statistical analysis and market research;
h) for marketing, advertising and promotional purposes;
i) to notify you about changes to our services and to keep you informed about our fees and charges;
j) with your consent only, to contact you (including by email or post) with information about our products and services which either you request, or which we feel will be of interest to you; and
k) with your consent only, to disclose your personal information to carefully selected third parties, so that they might contact you (including by email or post) with information about products and services which may be of interest to you.
3.2 We may also collect details about you as a user of the Website for the purposes of preparing reports or compiling statistics. Such details will be anonymised and you will not be identifiable from the data collected.
4. Disclosure of your personal information
4.1 We may share your personal information with any company that is a member of our group, which means our subsidiaries and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
4.2 Unless you have indicated that you no longer wish us to do so after submitting your details, we will share your personal information with selected third parties, including:
a) our service providers and sub-contractors, including but not limited to card payment and direct debit payment processors, suppliers of technical and support services and companies that assist us in carrying out identification and fraud checks;
b) credit reference agencies for the purpose of assessing your credit score, where this is a condition of us entering into a contract with you;
c) companies that assist us in our marketing, advertising and promotional activities such as Adwords & Bing Paid Media platforms.
d) analytics and search engine providers that assist us in the improvement and optimisation of our site; and
e) members of any marketing group we belong to.
4.4 We may also disclose your personal information to third parties:
a) 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;
b) if Initiate Consultancy Limited or substantially all of its assets are acquired by a third party, in which case personal information held by Initiate Consultancy Limited will be one of the transferred assets;
c) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions or any other agreement; or
d) to protect the rights, property, or safety of Initiate Consultancy Limited, our customers, or other persons. This may include exchanging information with other organisations for the purposes of fraud protection and credit risk reduction.
4.5 Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without your consent. Where you have given your consent for us to share your information, but later change your mind, you should contact us by emailing firstname.lastname@example.org or by post (57 Rathbone Place, London, W1T 1JU) and we will stop doing so.
5. Your rights
5.1 The Act gives you certain rights in relation to personal information held about you. You may contact us by post or email at any time, to request that we:
5.2 update any out of date or incorrect personal information which we are holding about you; or
5.3 provide you with copies of any personal information which we hold about you, subject to a fee specified by law.
5.4 You have the right to ask us to not process your personal information for marketing purposes. We will inform you (before collecting your personal information) if we intend to use your personal information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal information. Alternatively, you can contact us by post or email at any time.
5.5 If you have previously given your consent to the use of your personal information for marketing purposes, you can choose to stop receiving marketing communications which we send to you from time to time by following the unsubscribe instructions included in such communications. Alternatively, you can opt out of such communications at any time by contacting us by post or email.
6. Transfers of personal information
6.1 The personal information that we collect from you may be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA working for us, other members of our group or third-party data processors. Such staff may be engaged in, among other things, the provision of our services to you, the processing of transactions and/or the provision of support services. By providing us with your personal information you acknowledge and consent to any such transfer, storage and processing.
7. Security of data
7.1 All information you provide to us is stored on our secure servers. Payment transactions may be undertaken by third party service providers and will be encrypted using industry standard SSL technology. Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
7.2 We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. Although we make every effort to protect the personal information which you provide to us, the transmission of data over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to the Website and that any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.
8. Third party websites