Privacy policy

Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

When we refer to “we”, “us” and “our”; we are referring to Plotify Financial (UK) Limited. We are a company registered in England and Wales under company number 11208691 and have our registered office at C/O Browne Jacobson LLP 15th Floor, 6 Bevis Marks, Bury Court, London, United Kingdom, EC3A 7BA.

We take your privacy very seriously and are committed to protecting and respecting your privacy. We are subject to data protection laws applicable in the United Kingdom and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

01 - Personal information we may collect about you

We may collect and use the following personal information about you:

  • identity data including your title, name, date of birth, nationality and other details collected by us to verify your identity (e.g. a copy of your passport and/or drivers licence);

  • contact details including your business and personal address, email address, and telephone numbers;

  • profile details including your account number and log-in information such as your username and passwords;

  • transaction data including details of your the properties you have invested in and other financial transactions with us;

  • technical data including your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website or app;

  • communications data including details of your communications such as by email, live chat with us, consents or permissions you give us and/or your preferences in receiving marketing from us and other third parties;

  • usage data including information about your visits to our website/app and how you use our website, app or our products and services (e.g. the length of time spent browsing certain pages; and

  • anti-money laundering information as a result of money laundering regulations, we may need to verify the source of the funds which you are investing with us. We may therefore collect from you as evidence - a copy of your bank statements, payslip or completion statement from a house sale.

This personal information is required to inform you about the products and services we can provide to you. If you do not provide personal information we ask for, it may delay or prevent us from providing our products and services to you.

02 - How your personal information is collected

We collect most of this personal information directly from you face to face or via our website (including live chat) and app or by telephone, text, email or paper based application. However, we may also collect personal information:

  • Our ‘KYC’ service provider;

  • Our payment service provider;

  • Credit reference agencies;

  • Financial advisers;

  • Companies that introduce you to us;

  • from publicly accessible sources, (e.g. the Internet); and

  • from cookies on our website — for more information on our use of cookies, please see our Cookies Policy.

03 - How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so. In order to use your personal information, we rely on the following legal bases:

(i) processing is necessary for us to be able to provide our products and services to you;

(ii) processing is necessary to comply with our legal or regulatory obligations;

(iii) processing is necessary for the purposes of legitimate business interests pursued by us; or

(iv) you have consented to the processing of the personal information.

We collect and process your personal information in order to:

  • provide our products and services to you;

  • manage our relationship with you including reporting on transaction activity and managing your investment and/or property portfolio;

  • conduct checks to identify you and verify your identity;

  • update our customer records;

  • prevent unauthorised access and modification to our systems;

  • develop our products and services;

  • undertake screening for financial and other sanctions or embargoes;

  • comply with our legal and regulatory obligations; and

  • undertake marketing and advertising activities.

Where we rely on your consent to process your personal information you may withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

04 - What marketing activities do we carry out?

  • We may use your personal information to form a view and provide information that we think may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

  • We can only use your personal information to send you marketing messages if we either have you consent or a legitimate interest.

  • We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

  • You can ask us or third parties to stop sending you marketing messages at any time by clicking on the unsubscribe link that appears in all our communications.

  • Where you opt out of receiving these marketing messages, you will still receive other communications from us relating to setting up your account, transactional information about your investments, or information about changes to your existing products and services.

05 - Who we share your personal information with

We routinely share personal information with:

  • companies within the Plotify Financial group;

  • our service providers including out payments provider and other third parties we use to help deliver our products and services to you or who help us run our business (e.g. marketing agencies or IT and communications service providers);

  • our insurers, brokers and auditors;

  • credit reference agencies and fraud prevention agencies; and

  • third parties where that is necessary to meet our legal obligations, including and competent regulatory, governmental or law enforcement authority.

  • We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they may only use your personal information to provide services to us and to you.

We may also need to share some personal information with other parties where such disclosure is necessary in our legitimate interests, such as potential buyers of some or all of our business or assets or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share or sell your personal information with any other third party.

06 - How long your personal information will be kept

We will keep your personal information while we are providing our product and services to you. Thereafter, we will keep your personal information for as long as is necessary:

  • to respond to any questions, complaints or claims made by you or on your behalf;

  • to show that we treated you fairly; and

  • as required by law and/or relevant regulations.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. Further details on this are available on request using the contact details set out in section 12 below.

We review our retention policy regularly. When it is no longer necessary to retain your personal information, we will delete or anonymise it.

07 - Transferring your personal information out of the EEA

To deliver our products and services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), for example:

  • with our group companies located outside of the EEA;

  • with our service providers located outside the EEA; or

  • if you are based outside the EEA.

These transfers are subject to special rules under European and UK data protection law. We will ensure that the transfer of your personal information outside of the EEA complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

08 - Your rights

You have the following rights, which you can exercise free of charge:

Access

The right to be provided with a copy of your personal information (the right of access)

Rectification

The right to require us to correct any mistakes in your personal information

To be forgotten

The right to require us to delete your personal information—in certain situations

Restriction of processing
Data portability

The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data

The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object
  • at any time to your personal information being processed for direct marketing (including profiling);

  • in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests

The right to object:

Not to be subject to automated individual decision-making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

In certain cases, we may not be able to comply with your request for reasons such as our obligations to comply with any legal or regulatory requirements. In the event that we cannot comply with your request, we will also response and let you know why.

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

  • email us at security@plotify.co.uk; and

  • let us have enough information to identify you including your full name, address and client account number.

  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and

  • let us know what right you want to exercise and the information to which your request relates.

09 - Children's data

Our website, application, products and services are not directed to children under 18 and we do not knowingly collect any personal information directly from children under 18. If you believe that we processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us using the information provided under the “How to Contact Us” section below.

10 - Keeping your personal information secure

We will store your personal information on secure servers located in the EU.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website or app and any transmission is at your own risk (e.g. if you access the internet via an unsecure network.

Once we have received your personal information, we have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

11 - Operating Globally

To facilitate our global operations, we may transfer, store, and process your information within our family of companies, partners, and service providers based in Europe, India, Asia and North and South America.  Laws in these countries may differ from the laws applicable to your country of residence.

Do Not Track Signals: Our website and application currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we will do so in this Privacy Policy.

California & Vermont Residents: We will not share information we collect about you with our affiliates or third parties (both financial and non-financial), except as required or permitted by your state’s law.

California Privacy Rights: If you are a California resident, you may to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed your personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. See the “How to Contact Us” section for where to send such requests. We do not share personal information with third parties for our own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent.

12 - How to complain

We hope that we can resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at www.ico.org.uk/concerns or telephone: 0303 123 1113.

13 - Changes to this privacy policy

This privacy notice was published on October 1st, 2018 and last updated on September 24, 2019.

We may change this privacy notice from time to time—when we do we˚ will inform you via an online message accessible via your client account.

14 - How to contact us

If you have any questions about this privacy policy or the information we hold about you, please contact us at:

Our contact details

Please contact us via email at security@plotify.co.uk