Privacy Policy

Finatext (“we”, “us”, “our”, “the Company”) is committed to protecting and respecting your privacy.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed, stored and disclosed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.getpipster.com (the “Site”) or using the Pipster mobile application (the “App”) or using any services offered through or associated with our Site or App (the “Services”), you are deemed to have accepted and consented to the practices described in this policy.

The Site and App are owned and operated by FINATEXT UK LTD (Company No. 10527715) of registered address 145 City Road, London, England, EC1V 1AZ, United Kingdom (our “Company Address”). Finatext processes personal data as a Data Controller, as defined in the Directive and the General Data Protection Regulation (“GDPR”). Our Data Protection Officer (“DPO”), who is responsible for matters relating to privacy and data protection, is Sushant Chalipat and he can be reached at sushant.chalipat@finatext.com.

The Site contains links to and from the websites of our partner networks, advertisers and affiliates or to websites shared by other users. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

1. Data We Collect About You


We collect and process personal information so we can provide our Services to you. It’s important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

The data we collect and process about you is explained in the sections below.

1.1 Data You Give Us

You give us information about you by filling in forms on our Site or App or by corresponding with us by phone, e-mail or otherwise. When you register to use an App, we collect your name, email address and login details via our registration form (or, if you choose to log in with Google or Facebook, we collect that information from your social account), and other personal details required for the appropriate verification of your identity and trading experience. We also collect your name and email address if you sign up for our marketing emails. If you choose to upload a photo, we store this image to use as your avatar for your profile and community discussion channels. We also collect behavioural data about your use of the Site or App, and financial transaction data when you conduct any trades within an App.

The information you provide in the course of signing up for and using an App is necessary for our legitimate interests and for us to fulfill our contractual obligation to provide our Services to you, and we rely on these as lawful bases to use and process the data. We ask for your explicit consent to use your information for our marketing emails.

1.2 Data We Automatically Collect

 

Each time you visit or use our Site, we automatically collect the following information:

  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, location, network data, browser plug-in types and versions, languages, operating system and platform; and
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Site (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

We use this information as statistical data about your browsing actions and patterns, for system administration, and to evaluate, provide, protect or improve our Services (including by developing new products and services). Because we collect, use and share this information in the aggregate, it does not identify any individual.

1.3 Data We Receive From Third Parties


We receive basic information about you (like your name and email address) from Google or Facebook if you choose to register for an App with a social profile. Zendesk operates our chat support feature and provides us information from your chats. Any payments you make are processed by Safecharge, and they share your payment information with us. We receive behavioural data about you (i.e. how you interact with our Site or App) from tools like Adjust, Firebase, Google Analytics and Google Tag Manager. If you make trades via one of our App, we receive financial information from BrokerIQ and STAR Financial Systems. We also receive information about you if you use other websites operated by us or our group (meaning any subsidiaries or ultimate holding company and its subsidiaries) or the other services we (or they) provide. For more information on how these companies handle your personal data, please refer to their privacy policies.

The information you provide when you register to use our App is necessary for us to fulfill our contractual obligations to provide our Services to you. Collecting behavioural data is our legitimate interest, and we rely on this as a legal basis to use and process the information.

2. How We Use Your Data

We use your data to carry out our Site, App and Services in the following ways:

 

  • To administer and manage your account, to provide you with information you request from us, and to carry out any other obligations arising from any contracts entered into between you and us.
  • To ensure that content from our Site and App is presented in the most effective manner for you and for your device.
  • To allow you to participate in interactive features of our Site or App when you choose to do so.
  • To respond to communications from you and to provide you with information about our Services, including notifying you about changes to our Site, App or Services.

We also use your data to make our Site, App and Services better in the following ways:

  • To administer the Site and App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
  • As part of our efforts to keep the Site and App safe and secure, e.g. by conducting analysis required to detect malicious data and understand how this may affect your IT system.

We will not send you any unsolicited marketing messages or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under applicable data protection laws. If you are an existing customer, we will only contact you by electronic means with information about services similar to those which were the subject of a previous enquiry by you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have expressly consented to this.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please notify us in writing or by email at the email address below.

3. How We Secure Your Data


All of your personal information is protected and we have put in place appropriate physical, electronic, and management procedures to safeguard and secure the data we collect. Your information is stored on secure cloud databases, internal servers, and on third party softwares. Security measures that we take include, but not limited to, using API gateways, cloudfront, RDS with encryption, SSL as a default for all connection, VPC for private network and connection between microservices, restricting IP and token access of operations and support team, and limiting data access to only authorised members.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site or App; any transmission is at your own risk. Once we have received your information, we use strict procedures and the security features described above to try to prevent unauthorised access.

4. How Long We Store Your Data

We only keep your personal information for as long as it’s necessary for our legitimate purpose for collecting it, or for as long as we’re legally required to keep it. Because we’re subject to financial regulations, we’re required to keep much of the information you provide for a minimum of 5 years. To learn more about our obligations to keep your information, please contact us at the email address provided below.

5. Disclosure to Third Parties

5.1 Parties with whom we share your information

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. As we mentioned above, we use Google and Facebook (to allow you to log in with profiles you have with them), Zendesk (for our chat support feature), Safecharge (to process payment information), Adjust, Firebase, Google Analytics and Google Tag Manager (to collect information about how you interact with our Site or App, and BrokerIQ and STAR Financial Systems (to help us manage your trades and financial transactions). These third parties have access to data we share with their platforms.

The only other circumstances under which we would share your personal data are:

 

  • If the third party is a member of our group (which means any subsidiaries or ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).
  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If the Company or substantially all of its assets are acquired by a third party, in which case personal data will be one of the transferred assets and the purchaser will be permitted to use the data for the purposes for which it was originally collected by us.
  • If we’re under a duty to disclose or share your personal data in order to comply with any legal obligation, enforce or apply our Terms & Conditions and other agreements, or to protect the rights, property, or safety of the Company, our customers, or others (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

5.2 Parties with whom you may choose to share your information

You may choose to share any information, photographs or other content that you voluntarily submit to the Site or App either on public forums and public areas of the Site or App. Such data will become available and viewable by other users as controlled by any applicable privacy settings that you define in your profile. Once you have shared your content or made it public, that content may be re-shared by others.

If you choose to connect to social media networks from the our Site or App or post any of your content on our Site or App to those networks, then in accordance with your social media privacy settings, the personal information that you post, transmit, or otherwise make available on the social media platform may be viewed and/or used by other users of those networks. We have no control over such viewing and use and cannot prevent further use of such information by third parties. When you interact with us through social media networks, you acknowledge that we may access your information that is held by that account, solely in accordance with your social media privacy settings. Any links to social media are not under our control and remain solely your responsibility. You acknowledge that any information posted via social media through our Site or App, or any third party you allow to access your content, is done entirely at your own risk and that by posting to a public platform you make that information visible to third-parties who can use that information at their discretion.

You may review, modify, update, correct or remove any personal data you have submitted to the Site or App at any time. If you remove information that you posted to the Site or App, copies may remain viewable in cached and archived pages of the Site or App, or if other users or third party APIs have copied or saved that information.

Always think carefully before disclosing personal data or other information to other users or otherwise posting personal data on the Site or App. It’s important that you’re aware that any data you choose to disclose on the Site or App may then be viewed and even used by other users (in accordance with your settings and this Privacy Policy). We do not control the contents of communications made between users (although you can make a complaint about another user by contacting us using the information provided in the Contact section below).

You must respect the privacy of others and you must not disclose any personal details about other people including your family, friends, acquaintances, or other persons that may be misleading or cause them harm or offence. It is your responsibility to obtain their prior express permission in respect of any submission of their data at any time.

  1. International Transfers

The data that we collect from you is transferred to, and stored at, destinations outside the European Economic Area (EEA). By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated as securely as it would be within the EEA and under the GDPR. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

You can obtain more details of the protection given to your personal data when it is transferred outside Europe by contacting us using the email address provided below.

  1. Your Rights

7.1 Lawful Bases

We will ensure that your personal data is processed lawfully, fairly, and transparently and that it will only be processed if at least one of the following bases applies:

  • You have given your clear consent to the processing of your personal data for a specific purpose.
  • Processing is necessary for the performance of a contract to which you are a party (or for us to take steps at your request prior to entering into a contract with you).
  • Processing is necessary for our compliance with the law.
  • Processing is necessary to protect someone’s life.
  • Processing is necessary for us to perform a task in the public interest or in the exercise of official authority and the task/function has a clear basis in law.
  • Processing is necessary for our legitimate interests or the legitimate interests of a third party, except where there is a good reason to protect your personal data which overrides those legitimate interests, such as allowing us to effectively and efficiently manage and administer the operation of our business, maintaining compliance with internal policies and procedures, monitoring the use of our copyrighted materials, offering optimal, up-to-date security and obtaining further knowledge of current threats to network security in order to update our security.

7.2 Data Subject Rights

Under the GDPR, you have the right to:

  • Withdraw your consent to the processing of your personal data at any time.  Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so (such as to comply with a legal obligation).
  • Be informed of what data we hold and the purpose for processing the data, as a whole or in parts.
  • Be forgotten and, in some circumstances, have your data erased by ourselves and our affiliates (although this is not an absolute right and there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it).
  • Correct or supplement any information we hold about you that is incorrect or incomplete.
  • Restrict processing of the information we hold about you (for example, so that inaccuracies may be corrected—but again, there may be circumstances where you ask us to restrict processing of your personal data but we are legally entitled to refuse that request).
  • Object to the processing of your data.
  • Obtain your data in a portable manner and reuse the information we hold about you.
  • Challenge any data we use for the purposes of automated decision-making and profiling (in certain circumstances—as above, there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request).
  • Complain to a supervisory authority (e.g. the Information Commissioner’s Office (ICO) in the UK) if  you think any of your rights have been infringed by us. (We would, however, appreciate the chance to address your concerns, so please contact us prior to taking this step).

You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

You have the right to ask us not to process your personal data for marketing purposes. We will get your express opt-in consent before we use your data for such purposes or share your personal data with any third parties for such purposes, but you can exercise your right to prevent such processing by contacting us at the Company Address, via email at the email address provided below, or by unsubscribing using the links contained in the marketing emails.

You may revoke your consent for us to use your personal data as described in this Privacy Policy at any time by emailing us at the email address provided below and we will delete your data from our systems. To enforce any of the above rights, please contact us at our Company Address or via email at the email address provided below.

We will notify you and any applicable regulator of a breach of your personal data when we are legally required to do so.