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InvestAcc Group, formerly Marwyn Acquisition Company II, completed the acquisition of InvestAcc Holdings on 9th October 2024. Learn more.

OUR PRIVACY POLICY

YOUR PRIVACY IS IMPORTANT TO US

We, InvestAcc Group Limited (formerly Marwyn Acquisition Company II Limited) (“we” or “us”), are committed to protecting and respecting your privacy and this policy (Policy) (together with any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us in connection with the services we offer, including our alert service and otherwise by or through this website, (Services). Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This website is not intended for children and we do not knowingly collect personal data relating to children via this website.

We are the controller for your personal data and responsible for this website.

Your personal data are held and processed by us in accordance with applicable data protection laws, including the Data Protection Act 2018 (DPA 2018) and the UK GDPR.

THE TYPES OF PERSONAL DATA WE MAY COLLECT FROM YOU

Personal data means any information about an individual from which that person can be identified. We may collect and process the following personal data about you:

  • Identity Data: including first name, last name and title.
  • Contact Data: including email address.
  • Technical Data: including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
  • Usage Data: including information about how you interact with and use our website and Services.
  • Image Data: including CCTV footage when you visit one of our offices.
  • Marketing and Communications Data: including your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

HOW AND WHEN WE COLLECT YOUR PERSONAL DATA

We collect the majority of the personal data that we process about you directly from you, including when you provide this to us by: 

  • Registering on our website or otherwise contacting us to obtain information relating to us or our Services;
  • Subscribing to our emails or other marketing communications;
  • Contacting us by any means (including via email, telephone, web message, etc.) with questions, queries or complaints.

We may receive personal data about you from third parties that we engage with in order to assist us with providing Services to you, including:

  • Our data analytics providers: we may collect data analytics information from companies that provide us with data analytics services;

HOW WE USE YOUR PEROSNAL DATA

Whenever we process your personal data, we are required by law to have a 'legal basis' for doing so. The legal bases we use to process your personal data will generally be one or more of the following:

  • Contractual necessity: where it is necessary to enable us to comply with our contractual obligations to supply you with the Services you want;
  • Legitimate interests: where it is necessary for our legitimate business interests in administering our relationship with you and running our business effectively. Where 'legitimate interests' is our legal basis for processing your personal data, we will take into account any potential impacts on your rights, freedoms, and interests;
  • Legal compliance: where it is necessary for us to process your personal data to enable us to comply with a legal or regulatory obligation; and/or
  • Consent: where we have asked for and gained your consent to use your information for particular purposes, for example, to send you marketing communications. We will also rely on your explicit consent wherever we need to process your sensitive or special categories of personal data about you.

There are many ways we will need to use your personal data in the context of your relationship with us. We have set out the main purposes in the table below and we have indicated the main applicable legal bases of processing. In some cases, more than one legal basis may apply to our use of your personal data and there may be other specific uses which are linked to or covered by the purposes set out below.

If you would like further information on the specific legal bases which we rely on in relation to any of the processing purposes we have set out below, please contact us using the details set out in the ‘Contact’ section below.

 Purpose for Processing

Types of personal data

Legal Basis

 To carry out our obligations arising from any contracts entered into between you and us, and  to provide you with our Services
  • Identity Data
  • Contact Data
  • Usage Data
  • Contractual Necessity

 To send you service messages about our  Services
  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Legitimate Interests: to contact you whenever we need to and provide you with relevant Service information

 To improve the Services we offer
  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Consent: where personal data are captured by way of cookies or you have positively opted in to sharing personal data for marketing purposes; and/or
  • Legitimate Interests: in relation to personal data we otherwise capture across our business and use to ensure our Services are of the highest quality

 To personalise your experience on our website. For this purpose, we use Cookies and similar  technologies. For more information about how  we use Cookies, please see our Cookie Policy.
  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Marketing and Communications Data
  • Consent: where personal data are captured by way of cookies which require you to positively opted in; and/or
  • Legitimate Interests: in relation to personal data we otherwise capture across our business and use to tailor your experience

 To send you marketing emails about our Services or events that we think may be of interest to you
  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Marketing and Communications Data
  • Consent: where personal data are captured by way of cookies or you have positively opted in to sharing personal data for marketing purposes; and/or
  • Legitimate Interests: where you are an existing investor, we also rely on our legitimate interests to increase engagement

 To improve our marketing communications. For  this purpose, we use Cookies and similar technologies for data analytics purposes. For more information about how we use Cookies,  please see our Cookie Policy.
  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Marketing and Communications Data
  • Consent: where we collect Technical Data via cookies, we do this on the basis of your consent, or in the case of essential cookies, on the basis of our legitimate interests in order to operate this website and ensure its security
  • Legitimate Interests: to offer you the most tailored and bespoke experience

 To allow you to update and manage your contact and marketing preferences
  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Marketing and Communications Data
  • Consent: where personal data are captured by way of cookies or you have positively opted in to sharing personal data for marketing purposes; and/or
  • Legitimate Interests: otherwise where we process your personal data to ensure that you have control over your own contact and marketing preferences

 To respond to any enquiries and/or complaints
  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Image Data
  • Marketing and Communications Data
  • Legitimate Interests: to manage our relationship with you and ensure that we are able to support you with any queries or complaints

 To update our records
  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Image Data
  • Marketing and Communications Data
  • Legitimate Interests: to ensure that we have accurate and up to date information.

 To administer and protect our business and this website, including to prevent or detect fraud or abuses of our website and safeguarding your personal data
  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Legal Compliance: where the activity is to ensure we meet our legal obligations and prevent or detect fraud;
  • Contractual Necessity: where we process personal data to ensure appropriate steps are taken to meet the terms in our contract with you, including payment of taxes or otherwise; and/or
  • Legitimate Interests: otherwise to protect our business and investors

 To protect our investors, offices, assets and   partners from crime. For this purpose, we use CCTV. Wherever we use CCTV for this purpose, we will provide appropriate signage to inform you that this is the case.
  • Image Data
  • Legal Compliance: as applicable where we have a legal duty to meet; or
  • Legitimate Interests: where we otherwise process personal data to ensure the security of our premises, our staff and our investors

 To develop, test, maintain and improve our systems and website
  • Technical Data
  • Usage Data
  • Legitimate Interests: to ensure that our systems and website are secure and reliable

 To comply with our legal obligations (where applicable) to share personal data with law enforcement and/or government bodies
  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Image Data
  • Legal Compliance: as applicable where we have a legal duty to meet

 To enable our third-party service providers to carry out technical or other functions on our behalf
  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Image Data
  • Marketing and Communications Data
  • Legitimate Interests: to ensure that our Services are appropriate and (where applicable) delivered in a timely fashion

 To anonymise and aggregate your personal data for our own data analytics purposes
  • Technical Data
  • Legitimate Interests: to allow us to make improvements to our Services

Consent

Where consent is our legal basis for processing your personal data, you can withdraw your consent at any time, and we will then stop any future processing for that purpose. If you wish to withdraw your consent, then please contact us using the details set out in the ‘Contact’ section at the end of this Policy. 

If you choose not to share your personal data with us, or refuse certain contact permissions, we may be unable to provide some of the Services you've asked for.

Legitimate Interests

Where required under applicable data protection laws, we have determined, acting reasonably and considering the circumstances, that we are able to rely on legitimate interests as the lawful basis on which to process your personal data in certain circumstances (as set out in the table above). 

We have reached this decision by carrying out a balancing exercise to make sure our legitimate interest is not overridden by your privacy rights as an individual, and we consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests as: 

  • we process your personal data only so far as is necessary for such purpose; and 
  • it can be reasonably expected for us to process your personal data in this way.

MARKETING AND YOUR RIGHTS

If you are an existing investor or you have consented to receiving marketing communications by email, we may send you information on any events or news about our Services that we believe may be of interest to you. You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your personal data) if we intend to use your personal data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by refusing your consent at the time of collection, at any time by using the ‘unsubscribe’ link in any marketing email we send you, or at any time by contacting us using the details set out in the ‘Contact’ section at the end of this Policy.

Our website may, from time to time, contain links to and from the websites of our members, advertisers and affiliates. 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.

DISCLOSURE OF YOUR INFORMATION

We sometimes share your personal data with third parties so that they can assist us in providing Services to you. These third parties will only process your personal data on our specific instructions, and we remain responsible for ensuring that your personal data are protected and processed lawfully by anyone that we share it with. Some examples of these third parties are set out as follows:

  • Technology partners involved in the operation and support of our website and business systems, including Google Analytics;

In some specific circumstances, we may also share your personal data with third parties who process it for their own purposes. Those third parties will have their own legal obligations to protect your personal data, and you will have legal rights that you can enforce directly against them. Some examples of these third parties are set out as follows:

  • The police and other law enforcement agencies, for the purpose of preventing and detecting fraud (including fraudulent transactions) and criminal activity;
  • Government bodies or other regulatory bodies, where requested or if we consider that it is reasonably required, so that they can carry out their legal functions;
  • Insurers or other organisations, where a claim is made or could be made against us. For example, we may send CCTV footage and information contained in our accident logs to our insurers; 
  • Our professional advisors, including without limitation tax, legal, insurance, or other corporate advisors who provide professional services to us; and
  • HMRC or other tax bodies or agencies as necessary to comply with our legal and regulatory obligations.

If we sell, transfer or merge parts of our business or our assets, or if we buy or acquire any business or assets, we may share the personal data held by us with the prospective buyer or seller of such business or assets. If substantially all of our assets are acquired by a third party (or subject to a reorganisation within our corporate group), personal data held by us will be one of the transferred assets.

We use Google Analytics on our website (Google Privacy Policy). This means that we may use cookies to collect online identifiers about your use of our website, including Technical Data, which we may use for the purpose of better understanding our investors and your use of our website. Google may transfer the personal data collected by it on our behalf outside of the United Kingdom. See here for further information on Google Analytics. 

If you would like further information about any of the third parties with whom we share your personal data, please contact us using the details set out in the ‘Contact’ section below.

COOKIES

Cookie is a general term often use to describe a number of technologies. Cookies are small text files that are stored on your computer or other device by any websites that you visit. Web beacons and pixels are tiny invisible images placed within email messages which tell us if you have opened an email and how you interreacted with it. For the purpose of this Policy and our Cookie Policy, we refer to all of these technologies as "cookies".

We may collect information about your computer or other device, including where available your IP address, operating system and browser type, for system administration, to improve the structure and content of our website, to make our website easier to use, to support the provision of information and functionality to you, as well as to provide us with information about how our website is used so that we can make sure it is as up to date, relevant and error free as we can and to report aggregate information to regulators and our members as requested and appropriate (this is statistical data about our users’ browsing actions and patterns, it does not identify any individual).

We also use cookies to try to ensure that our emails and electronic marketing messages which we send to you reflect the interests of our investors and website users. 

Further information about how our website use cookies can be found in our Cookie Policy.

HOW AND WHERE WE STORE YOUR PERSONAL DATA

The personal data that we collect from you will not be transferred to, and stored at, a destination outside the UK.

All information (including personal data) you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet (including email) 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; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

PERSONAL DATA RETENTION

We have a retention policy which means we do not keep information we hold about you for longer than necessary unless we there is a legal obligation to do so.

YOUR LEGAL RIGHTS

You have the following rights in relation to the personal data that we hold about you:

  • The right to request access to your personal data (commonly known as a “data subject access request”). This enables you to request a copy of the personal data we hold about you and to check we are processing it lawfully.
  • The right to request correction of the personal data we hold about you. This enables you to request that we correct any incomplete or inaccurate personal data that we hold about you.
  • The right to request erasure of your personal data in some circumstances. This enables you to request that we erase your personal data where there is no good reason for us continuing to process it.
  • The right to object to us processing your personal data. This enables you to object to us processing your personal data where we are relying on our legitimate interest as a legal basis for processing, or where we are using your personal data for direct marketing purposes.
  • The right to restrict our processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain circumstances.
  • The right to data portability. In certain circumstances this enables you to request that we provide you, or a third party, with a copy of the personal data that you provided to us in a structured, commonly used, machine-readable format.
  • The right to stop us using your personal data for direct marketing purposes. This can be by a specific channel or all marketing channels.
  • The right to request that we review any decision made solely on the basis of automatic processing of your personal data. This right applies where no person was involved either in the processing, nor in reviewing the outcome of the processing which led to the decision.
  • The right to withdraw your consent. As detailed above, wherever you have given us your consent for any of our processing purposes, you have the right to withdraw that consent at any time. 

How to exercise any of your rights

Further information about your rights in the UK can be found on the Information Commissioner's Office (ICO) website here: https://ico.org.uk/

For more information on your legal rights, or if you would like to exercise any of them, please contact us using the details set out in the ‘Contact’ section at the end of this Policy.

To protect the confidentiality of your personal data, we will ask you questions in order to verify your identity before proceeding with any requests to exercise your rights.

MAKING A COMPLAINT

If for any reason you are not satisfied with our response, you can make a complaint to the ICO at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113

CHANGES TO THIS POLICY

We may update this Policy from time to time at our sole discretion. Any changes we may make to this Policy in the future will be posted on our website and we encourage you to review this Policy periodically. If you continue to use the Services after we change this Policy, then you accept all such changes.

CONTACT

If you have any questions, comments or requests regarding this Policy, or if you or if you would like to exercise any of your legal rights, please contact us by email at: info@investaccgroup.com





Last updated: 09 October 2024

InvestAcc Group Limited, 11 Buckingham Street, London, WC2N 6DF