What type of information we collect
We collect two types of data and information from our users.
The first type of information is un-identified and non-identifiable information pertaining to a user(s), which may be made available or gathered via the User’s use of the Services (“Non-personal Information”). We are not aware of the identity of the User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.), in order to enhance the functionality of our Services.
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). The Personal information we collect through our Services includes information which is submitted directly by the user, such as: phone number; full name; e-mail address; home address; identification number; signature; social security number; passport number; copy of the user’s identity card and passport; bank account number; payment means; and other financial information that we may need in order to provide our Services (e.g. details regarding your annual income, experience in investments, etc.).
We may also collect Personal Information from your device (e.g. geolocation data, IP address) and information on your activity on the Services (e.g. pages viewed, online browsing, clicks, actions, etc.).
If we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
How we collect information
There are two main methods we may use to collect information:
- We collect information through your use of the Services. In other words, when you are using our Services, we are aware of it and may gather the information relating to such usage, either independently or through the help of third-party services as detailed below.
- We collect information which you provide us voluntarily. For example, we collect Personal Information which you provide when you register and use the Services. In addition, you may also share with us email addresses of your friends or acquaintances in order to notify them about an investment that may interest them.
How we use the information we collect
In addition to the purposes listed above, the Personal Information we collect is used for the following purposes:
- To set up your account and to provide our Services;
- To identify and authenticate your access to certain features of the Services;
- To communicate with you in order to keep you informed of our latest updates and to provide you information with regard to investments that may interest you.
- To perform a research or to conduct anonymous analytics in order to improve and customize our Services to your needs and interests;
- To support and troubleshoot our Services, to respond to your queries and communicate with you;
- To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.
With whom we share the information we collect
We may transfer or disclose Personal Information to our subsidiaries, affiliated companies, subcontractors or such other trusted third party service providers or partners, who are located in different jurisdictions across the world, for the purpose of: (a) storing or processing such information on our behalf (e.g. on cloud computing services) or to assist us with our business operations, to authenticate your access and to provide and improve our Services; (b) performing research, technical diagnostics, analytics or statistical purposes; (c) e-mail marketing, in accordance with our marketing policy (see below under ”Marketing”).
We may also disclose to our registered users Personal Information relating to other users, who joined the Services following their recommendations (i.e. through the “sharing with a friend” feature). The Personal Information which is being disclosed in such event may include the user’s full name, past and current investments, email address, etc.
We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.
Third party collection of information
Our policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via our Services (e.g. by clicking on a link to any other website or location) or via other sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them.