Privacy Policy

1. THIS POLICY

   • 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 team@sharein.com.

2. WHO WE ARE

   • We are ShareIn Ltd, Suite 2, Ground Floor, Orchard Brae House, 30 Queensferry Road, Edinburgh, EH4 2HS. 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).

3. YOUR CONSENT

   • 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.

4. 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.

5. 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.

6. COOKIES

   • Our Website will use the cookies listed in section 6.2 (alpha-numeric text files placed on your computer) to:

     • distinguish you from other users;
     • optimise your browsing experience;
     • make necessary improvements to our Website;
     • recognise and count the number of visitors to our Website and see how they move around the Website during use;
     • recognise you when you return to our Website; and
     • record your visit to our website, including any links you may follow.

   • The following cookies are set to our Website for the listed purposes:

     Cookie	Purpose
     cookiebanner-accepted	Records that the button on the cookie banner has been clicked.

   • Our Website additionally uses Google Analytics, a web analytics service provided by Google, Inc. (Google). Google Analytics uses analytical, performance or targeting cookies to help analyse how you use the Website and compile reports on your activity for us.
   • Any information generated by the cookie about your use of the Website (including your IP address) will be transmitted to, and stored by, Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on your activity for us and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.
   • You may refuse the use of cookies by selecting the appropriate settings via the Cookies settings, however please note that if you do this your ability to use the Website may be restricted. By using the Website, you consent to the processing of data about you by Google in the manner and for the purposes set out above unless you amend the Cookie default setting.
   • Except for essential cookies, all cookies will expire after your session.

7. 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).

8. HOW AND WHY WE DISCLOSE YOUR DATA

   • We disclose your personal data to those third parties listed in section 9 , for the reasons stated. Subject to the rest of part 8 of this policy, we may transfer or disclose your personal data to:

     • any prospective buyer of any part of the relevant business or assets in connection with the sale (in which case, any personal data held by us about you and our Account Holders will be one of the transferred assets);
     • comply with our legal obligations (such as the Police, the Financial ConductAuthority, the Information Commissioner’s Office, etc); or
     • to protect the rights, property, or safety of ShareIn, our users, or others. This includes without limitation exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
   • Our Website links to many third party websites, some of which belong to our clients. Such websites are outside of our control and not covered by this policy. If you access those websites using the links provided, the website operators may collect information from you which will be used by them in accordance with their own privacy policies (if any). These policies may differ from ours, and we cannot accept any responsibility or liability in respect of these.
   • Some data processing in relation to this site may be carried out for us by a third party and in some cases that may mean that the third party will receive your personal information.

9. SECURITY

   • 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.
   • Our databases are hosted within the Cloud by Microsoft Azure; a Cloud hosting solution from servers hosted in Ireland. A copy of their privacy policy is available at https://privacy.microsoft.com/en-gb/privacystatement.
   • 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.

10. YOUR RIGHTS

    • In relation to all of your personal data, you have the following rights to ask us or us (in addition to any rights you may have under the Act or the Regulation):

      • not to process your personal data for marketing purposes;
      • to clarify what data we hold about you, how it was obtained, to whom it has been disclosed and for how long it will be stored;
      • to amend any inaccurate data we hold about you;
      • to delete any of your data (where you no longer think we need to hold it or you think we have obtained it or processed it without your consent at any time); and
      • to only process your personal data in limited circumstances or for limited purposes.
    • If you wish to exercise any of your rights at any time, please contact us on the details contained at the beginning of this policy in the first instance. We will require you to verify your identity to us before we provide any personal data, and reserve the right to ask you to specify the types of personal data to which your request relates.
    • Where you wish to exercise any of your rights, they may be subject to payment of a nominal administration fee (to cover our costs incurred in processing your request) and any clarification we may reasonably require in relation to your request. Such fees may be charged where we consider (acting reasonably) that your request is excessive, unfounded or repetitive.
    • Any data provided to you in accordance with your rights will be in a structured and machine-readable form.