Privacy Policy

The term Investment Tribe Ltd or ‘us’ or ‘we’ refers to the Company whose registered office is 25A Thistle Street South West Lane, Edinburgh, EH2 1EW. Our company registration number with companies house is SC626291.

The term ‘you’ or ‘your’ refers to the user or viewer of our website and/or recipient of our services.

This privacy notice sets out the processing practices in relation to personal data which is collected, stored and retained through the use of this Website and any other electronic communications by Investment Tribe Ltd, which is the data controller for that data.

Your right to privacy is important to us.

This privacy notice sets out how Investment Tribe Ltd uses and protects any information that you give us when you use this website or otherwise interact with us.

If you do not agree to the following policy, you may wish to cease viewing/using this Website, and or refrain from submitting your personal data to us. Failing to provide personal data via the website will prevent entering into a contract to use our Investment services.

We may change this notice from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This notice is effective from 1 June 2023.

For the purposes of meeting the UK GDPR and the Data Protection Act 2018 territorial scope requirements, the United Kingdom is identified as the named territory where the processing of personal data takes place.

If you have any requests concerning your personal data or any queries with regard to this notice, please contact Investment Tribe Ltd at dataprotection@investmenttribe.co, our offices : 25A Thistle Street South West Lane, Edinburgh, EH2 1EW, or contact the Chief Compliance Officer at brian.gray@investmenttribe.co.

We are registered with the Information Commissioner’s Office (ICO); our registration number is ZB106072. Information on the Data Protection Act 2018 and the UK General Data Protection Regulation (the UK GDPR) is also available on the Information Commissioner’s website at www.ico.gov.uk.

Under the UK GDPR, your individual rights in relation to your personal data are as follows (you can read more about your rights in detail at : https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/);

the right to be informed about the personal data being processed,
the right of access to the data,
the right to rectification,
the right to erasure,
the right to restrict processing,
the right to data portability (to receive an electronic copy of your personal data),
the right to object to processing of your personal data and
the right not to be subject to automated decision-making. including profiling.

Use of personal data

We collect and process your data for one or more of the following grounds:

To fulfil our contract with you.

We use your personal data as is necessary to provide you with our products and services in line with our overall contract. We process and use your personal data to provide you with a personalised service and the product or service you have requested, to fulfil your other requests, process your order(s), and as otherwise may be necessary to perform or enforce the contract between us.

We are required to do so by law or regulation.

We are required to process and store some of your data in order to fulfil our regulatory obligations. We may capture and share your personal data with organisations that can confirm your identity and provide information necessary to prevent fraud or other financial crimes. We may also be required to share your personal details where requested to by legal or regulatory authorities or the Financial Ombudsman Service.

There is a substantial public interest in doing so.

There is a substantial public interest in the efficient functioning of the UK financial markets which requires those who advise upon, arrange, underwrite or administer a financial instrument to process personal data, including ‘sensitive’ information for example, details about your finances or criminal convictions.

You have provided us with your informed consent.

Where you have given your informed consent, we will process your data in accordance with the permission you have given us and this privacy notice. For example, for the purposes of Direct Marketing. You may withdraw your consent at any time by contacting us at dataprotection@investmenttribe.co.

Our other legitimate interests in using your data

Taking into account your interests, we process your personal data for the following purposes:

To verify your identity and administer your account.

We process and use your personal data to ensure the functionality and security of our products and services, to identify you and the instructions you give us, and to prevent and detect fraud and other misuses.

Development of products and services.

We process and use your personal data to develop our products and/or services. However, for the most part we use only aggregated and statistical information in the development of our products and services, and not data directly identifiable to you. We may also process and use your personal data to personalise our offerings and to provide you with service more relevant to you, for example, to make recommendations and to display customised content and advertising. We may combine personal data collected in connection with your use of a particular product and/or service with other personal data we may hold about you, unless the purpose for which we collected that data is incompatible with amalgamation.

Communicating with you and marketing.

We process and use your personal data to communicate with you, for example, to provide information relating to our products and/or services you are using or to contact you for customer satisfaction queries. We may process and use your personal data for marketing. Marketing purposes may include using your personal data for personalised marketing or research purposes in accordance with applicable laws, for example, to conduct market research and to communicate our products, services or promotions to you via our own or third parties’ electronic or other services. When contacting you for the purpose of marketing, we will take into account any preferences you have expressed to us, including any desire not to receive marketing.

Any email marketing messages we send are in accordance with the UK GDPR and the Privacy and Electronic Communication Regulations (PECRs). We provide you with an easy method to manage your preferences/the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences.

Profiling

We may process and use your personal data for profiling for such purposes as targeted direct marketing and improvement of our products or services. We may also create aggregated and statistical information based on your personal data. Profiling includes automated processing of your personal data for evaluating, analysing or predicting your personal preferences or interests in order to, for example, send you marketing messages concerning products or services suitable for you.

Tracking remuneration due to us or our partners.

We use your personal data to ensure that we receive the remuneration or commission due to us from, or payable by us to, any third-party product providers or distributors.

Insurance.

We process personal data as required to enable us to periodically obtain insurance cover for our business and to notify and process claims with our insurers.

Business continuity.

In the event of an interruption or cessation of our business, we need to ensure that we can implement our business continuity procedures (for example, we may need to rebuild our IT systems) or wind down planning to protect your interests. This may involve a transfer of your personal data to a third party (see below).

Automated decisions

We sometimes use systems to make automated decisions about you or your business. This helps us to make sure our decisions are quick, fair, efficient and correct, based on the information we have about you. Automated decisions can have an impact on the products, services or features we may offer you now or in the future. They are based on personal information that we have or that we are allowed to collect from others.

The types of automated decision we make are listed below:

Opening accounts

When you open an account with us, we check that the product or service is relevant and appropriate for you, based on what we know. We also check that you or your business meet the conditions needed to open the account. This may include checking age, residency, nationality, political exposure, financial position, criminal background, knowledge. It may mean we cannot offer you the account you want.

Tailoring products, services, offers and marketing

We are required to determine your investor categorisation, our assessment of this is as dictated by the Financial Conduct Authority. The category you fall into will determine which products and services we are permitted to offer you.

We may also place you in customer segment groups with similar customers. We use these to study and learn about our customers’ needs, and to make decisions based on what we learn. This helps us to design products, services and offers for different customer segments, and to manage our relationships with them.

We also use customer segments from outside companies we work with – such as social networks – by asking them for groups of people who are similar to you, or have interests that are like yours in some ways. These companies help us look for new customers who may be interested in products, services or offers that our existing customers are interested in.

This helps us tailor the marketing that individuals receive or are shown on our own and other websites and mobile apps, including social media. It also helps us to design products, services and offers for different customer segments, and to manage our relationships with them.

Detecting fraud

We use your personal information to help decide if your personal or business accounts may be being used for fraud or money-laundering. We may detect that an account is being used in ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual for you or your business. If we think there is a risk of fraud, we may stop activity on the accounts or refuse access to them.

Your rights

You can object to an automated decision we have made, and ask that a person reviews it.

If you want to know more about this and your other rights, please see the section on ‘What are your rights?’, below.

How do we secure your personal data?

We have robust procedures in place within our business;

to protect data against accidental loss,
to prevent unauthorised access, use, destruction or disclosure,
to ensure business continuity and disaster recovery where required,
to restrict access to personal information,
to conduct privacy impact assessments in accordance with the law and our business policies,
to train staff and contractors on data security, and
to manage third party risks, through use of contracts and security reviews

How long do we keep personal data?

We will keep your personal data only for so long as it is reasonable for us to do so, depending upon the nature of the data and our processing, and the grounds upon which we collected it. In general, we will delete redundant account information within 14 days of our relationship ending. However, we are obliged to keep certain records of our relationship to comply with the FCA’s and other regulatory rules, in which case we will instead restrict access through our archiving processes. Subject to any actual or potential legal claim or regulatory investigation, the maximum time that we envisage retaining any of your information is seven years, after which time it will be destroyed.

Information we use for marketing purposes will be kept by us until you notify us that you no longer wish to receive this information. If you do notify us that you no longer wish to receive marketing information, we will keep an encrypted version of your contact information to ensure we respect your wishes.

Other websites

Our website may contain links to other websites which are outside the control of Investment Tribe Ltd and are not covered by this privacy notice. If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their privacy notice which may be different to the privacy notice of Investment Tribe Ltd. You should exercise caution and look at the privacy notice applicable to the website in question.

Transfers of your personal data

We may transfer your personal data to the third parties noted below, or as required by law.

Material service providers.

We may transfer your personal data to the following third parties who provide us with a material service:

We may transfer your personal data to third parties who process personal data on our behalf to enable the efficient technical and logistical provision of our services. These service providers may, for instance, supply us with cloud data storage, data security services, customer relationship management software, and other support services. We may substitute a technical or logistical service provider from time to time. Such parties are generally not permitted to use your personal data for any other purposes than that for which your personal data was collected, and we require them to act consistently with applicable laws and this Privacy notice as well as to use appropriate security measures to protect your personal data.

Event-driven transfers.

We may transfer your personal data to third parties in certain events where it is necessary to protect your, or our, legitimate interests. This includes the cessation, sale or transfer of our business, civil or criminal legal, or regulatory, proceedings or insurance claims.

What are your rights?

You have the right to request information on and access to the personal data we hold about you.

You also have the right to request that we correct or delete any incomplete, incorrect, unnecessary or outdated personal data we hold about you. However, we cannot delete personal data that is necessary for compliance with our binding legal or regulatory obligations or if the personal data must be retained according to applicable laws, or is required for the exercise or defence of a legal or regulatory claim.

In case you consider your personal data collected by us to be inaccurate but you do not wish your personal data to be deleted, if we have used your personal data unlawfully or you have objected to the processing and the existence of legitimate grounds for processing is still under consideration, you may request restriction of processing of your personal data.

You may also at any time object to your personal data being processed for direct marketing purposes, sending promotional materials, profiling, or for the performance of market research. Where your personal data is processed based on your consent, you have the right to withdraw your consent for such processing at any time.

You can object to an automated decision we have made, and ask that a person reviews it.

In case you wish to make use of your rights mentioned above, you may, as appropriate and in accordance with applicable laws, exercise such rights by contacting us through the contact points referred in the marketing materials or below in this notice. In some cases, especially if you wish us to delete or cease the processing of your personal data, this may also mean that we may not be able to continue to provide the services to you.

Please note that we may need to identify you and to ask for additional information in order to be able to fulfil your requests. Please also note that applicable law may contain restrictions and other provisions that relate to your above rights.

Subject access rights

You have a right to a copy of and details of the personal data held about you. To obtain a copy of the personal data Investment Tribe Ltd holds about you, please write to us at 25A Thistle Street South West Lane, Edinburgh, EH2 1EW. No charge will normally be made by Investment Tribe Ltd for providing this information. If your request is considered to be repetitive, wholly unfounded and/or excessive, we are entitled to charge a reasonable administration fee.

Use of cookies

A cookie is a small piece of code, sent from a website to a user’s internet browser, which allows that website to track the user’s previous activity when they return to that website. This allows us to provide you with the experience that you expect from us and lets us continually improve our service.

When you first access the website you receive the option to enable all Cookies or only ‘Necessary’ Cookies – these are the ‘Strictly necessary cookies’ described here.

The types of cookies we may use are:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website. or make use of e-billing services.

Analytical/performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

We do not have any control over the use of cookies by third parties, including our partners and affiliates. To manage cookies from third party websites, you will need to visit their site to adjust your settings.

If you want more information about how cookies operate, or how to manage them, please visit About Cookies at http://www.aboutcookies.org.uk/ .

Use of this website is subject to our terms of use (investmenttribe.co/termsofuse).

Visiting our premises

When you visit one of our premises, we may record your name in our signing-in register. Your image may be captured by our CCTV cameras. Notices are available where the cameras are in operation.

Refer to our CCTV Policy for further information.

If you are a business contact

We may collect your business contact details such as your name, business address and business e-mail and your company’s bank account details. If you are a sole trader this may be your personal details which will be treated in accordance with this notice. As part of our due diligence regarding which suppliers we enter into contract with for regulatory activity, we may run background checks including

If you apply for a job with us

We will ask for your contact details, previous employment history and qualifications.

We may require you to undergo a background check and share the results with us.

We may collect details of ethnicity and disability – for equalities monitoring and so that we can make any appropriate adjustments to accommodate you through the recruitment process.

Keeping in touch with us

The accuracy of the personal data we hold is important to us. Please help us keep our records updated by telling us about any changes to your personal and/or contact details by updating your profile details via your dashboard, or emailing dataprotection@investmenttribe.co.

Any questions about this notice should be sent, in the first instance, to dataprotection@investmenttribe.co or at our registered office 25A Thistle Street South West Lane, Edinburgh, EH2 1EW: