Personal information means information about you which is personally identifiable, including your name, address, telephone number, email address, sentiment data or the choice of instruments you may add to the interactive investment game.
ARE WE REGISTERED?
We have notified the Information Commissioner's Office that We are a data controller and are registered on the Data Protection Register under registration number ZA061953.
WHAT PERSONAL INFORMATION DO WE COLLECT?
We may collect and process the following information about you:
- any personal information you provide to us when you create an account, including details supplied by but not limited to Facebook, Twitter, Google, Instagram or LinkedIn or email, if you use the social login function, to use some or all of the invstr Services;
- any personal information you provide when using the invstr Services (including all behavioural and activity data generated through your activity with respect to the invstr Services), for example our messaging facilities and behavioural data generated through your participation in our interactive investment games;
- details of transactions you carry out via our App or Website, including any payment or billing information you provide to us through the App or Website;
- if you contact us, We may keep a record of that correspondence;
- where you agree to an error report being sent to us, any information contained in that error report, for example an error report contains details of the error and other potentially relevant information collected from your device (for example: operating system version, drivers, etc);
- details of your use of the invstr Service, the resources you access, which may include IP addresses, ISP, clickstream data, viewed and exit pages and date or time stamps;
- details about the devices you may use to access the invstr Services, which may include the device’s unique identifiers, operating system, browser type and network information; and personal information posted by other users through the messaging and chat functionalities of the App and Website; and
- geo-location data solely for the purpose of tailoring the layout and information on the App and Website to be most appropriate to the jurisdiction in which you are located.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We may use your personal information in the following ways:
- to store and retrieve your account data, so that your preferences and customisations can be remembered as well as your achievements and progress in our interactive investment games;
- to help us improve the invstr Services;
- to help us protect against attacks to the invstr Services;
- to help us fix problems with the invstr Services;
- to ensure that content from the invstr Services is presented in the most effective manner for you and for your device;
- to provide you with information about the invstr Services, but We will not send you marketing information if you have asked us not to (see description of newsletter below);
- to allow you to participate in interactive features of the invstr Services (including our interactive investment games);
- to notify you about changes to the invstr Services;
- to send you emails, unless you have asked us not to at the time you provide your email address. You can unsubscribe from our emails at any time by following the unsubscribe link at the bottom of each message, or by contacting us using the contact details provided at the end of this policy;
- to send you our newsletter, unless you have asked us not to at the time you provide your email address. You can unsubscribe from our newsletters at any time by following the unsubscribe link at the bottom of each newsletter, or by contacting us using the contact details provided at the end of this policy; and
- to process any transactions you make via the invstr Services and to monitor, prevent and detect fraud.
WILL WE SHARE YOUR PERSONAL INFORMATION?
We may disclose your personal information to third parties for the following purposes:
- Games promotions: We may use your name in any publicity material should you win a Game competition, in accordance with current UK data protection legislation. Notwithstanding, we will not disclose such information without your prior consent.
- Service providers: We contract with service providers who perform certain functions on our behalf. Examples include service providers who send our newsletter on our behalf, or automated email marketing services. Their access is limited only to the personal information needed to perform the functions carried out on our behalf, and only for the purpose of performing those functions.
- Exchanges: We source market data from financial exchanges. We might be under an obligation to provide the exchanges with your details in order for them to verify usage of the market data supplied by them.
- Research Providers: We source research reports and commentaries from various research providers. We might provide your details to those providers on an aggregated and anonymised basis.
- Payment processors: If you conduct a transaction via the invstr Services, We may need to share certain personal information with third party payment processors in order to process your payment.
- Money Transfer and eDebit Card. Should We be required to transfer monies to You, for instance for winning a game competition prize, We will be required to process the transfer in accordance with the third party money transfer services requirements, including corroboration of the name and account details to which monies will be remitted.
- Order Management. If you carry out an investment transaction through the Trading Service, We may need to share limited personal information with the third party order management services and, or your broker in order to on-pass order messages. Notwithstanding, the actual execution and therefore security log-in and detailed personal information is securely carried out only between You and your broker dealer.
- if We (or any one of our group companies) are bought or sold, or our assets (or the assets of any of our group companies) are bought, sold or consolidated, in which case We may disclose your personal information to the prospective seller or buyer of such business or assets;
- if We share or sell anonymised data on an aggregated basis to third parties (in each case so that it is not capable of identifying you) for the purpose of providing an indication of prevailing market sentiment; and
- if We are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to comply with or enforce our terms and conditions at www.invstr.com/app/tac.html and other agreements We have with you; or to protect the rights, property, or safety of invstr Limited, our group companies, our customers, or others.
DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA?
Through your account settings, you can choose to keep some of your personal information private. We shall use our best efforts to process your personal information in accordance with your account settings but please do note, however, that it may not be possible to make certain information private.
Our messaging facilities may include: private chat, public chat, public posts to the social feed, quick comment and comment forums and other ways of communicating with other users of the invstr Services.
If you choose to use any messaging facility which We provide, your messages may be visible to other users of the invstr Services, and may be shared externally. By posting messages via messaging facilities, you are consenting to your message being published on the invstr Services and you acknowledge and agree that it may be visible to the public. For your safety, We recommend that you do not post any personal information using our messaging facilities, and do not post any information which you do not wish to be shared, seen or used by others. Our messaging facilities may not be encrypted, so do not use them to make available any sensitive or private information. Our messaging facilities are intended only for chatting about the invstr Services. We may store content, information and data sent via our messaging facilities.
COOKIES AND OTHER TRACKING TECHNOLOGIES
These cookies are not required for site functionality. Additionally, third-party widgets such as Twitter, Facebook, Google+ and YouTube may install cookies, depending on their configuration.
We use Crashlytics to monitor your in-app sessions for service performance purposes.
Facebook & Twitter Conversion Tracking Cookies
We use a technology called Facebook Conversion Tracking. This allows us to track those visitors who have been referred through a Facebook page, application or advertisement and then visited the Website within a 30 day period.
We will share information regarding your visit to the Website with Facebook but this will not include any information specific to your application or other personal information. Facebook will use this information to monitor, on our behalf, the effectiveness of our advertising and applications.
The information we share with Facebook will only be used in accordance with Facebook’s data use policy atwww.facebook.com/about/privacy. Facebook Conversion Tracking may also enable us and our partners to serve ads on and off Facebook.
We use a support tool called Localytics to analyse your in-app behaviour for advertising and marketing purposes.
You should refer to your browser or device's help material to learn what controls you can often use to remove or block cookies or other similar technologies or block or remove other data stored on your computer or device (such as by using the various settings in your browser). If you do this, it may affect your ability to use this Website and the App as well as other websites and apps.
ACCESS TO AND CORRECTING YOUR PERSONAL INFORMATION
- to find out more about how your data will be used, or to make a complaint, please contact us using the details provided at the end of this policy;
- you have the right to request a copy of the personal information that We hold about you. If you would like a copy of some or all of the personal information We hold about you, you can contact Us using the contact details provided at the end of this policy. We may make a charge of £10 for this;
- We want to make sure that your information is accurate and up to date. You may update your personal data through the ‘settings’ screen in the "Me" section of the App or Website or you may ask Us to correct or remove personal information you think is inaccurate by contacting Us using the contact details provided at the end of this policy;
If you have any questions, complaints or comments about Us or our services then please contact Us by email using firstname.lastname@example.org, in writing by post to 26 St James's St, London SW1A 1HA, or by fax on +44-20 3053 1574.