Huddlestock | A financial network for the information age

Privacy Policy

About Us

This is the privacy policy for Huddlestock Limited, a company registered in England and Wales under company number 10059912 (from now on "we", "our" or "us"). Our registered office is at Office 39.12 On Level 39, One Canada Square, London, E14 5AB. For the purposes of the General Data Protection Regulation (GDPR), we are the data controller of the personal data processed in connection with this privacy policy.

Our ICO registration number is 00044690701.

We are committed to protecting your privacy and the security of the personal data we hold and process on your behalf. This Privacy Policy explains how we collect information, what we use the information for, our legal basis for doing so, and what controls you have.

This Privacy Policy applies to all personal information we gather or use in connection with your relationship with us as a customer or potential customer. This includes when you use our website, www.huddlestock.com (from now on referred to as our "Website"), our mobile apps (including our iPhone and Android apps) (from now on referred to as our "Mobile Apps"), services provided by us or others acting on our behalf, and when you interact with us. We will only use your personal information in accordance with this Privacy Policy.

We reserve the right to change this privacy policy from time to time by changing it on this website. This privacy policy was last updated on 23/05/18.

What personal information do we process?

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

Information we receive from others

We may also receive information about you from third parties, including:

We use this information in order to comply with our legal obligations and to provide our products and services to you.

What we do with your data?

We use your personal data for the following purposes:

Providing our services to you

We need to process certain personal information in order to provide our services to you, which includes our service allowing industry experts to share investment ideas with Huddlestock users and other services delivered via our Website and mobile apps. We will also need to collect and process KYC information in order to comply with our legal obligations.

Contacting you about our services

If you have given us your contact information as part of a sign-up process, we may use these details to get in touch with you about the services we offer such as by following up on an incomplete registration process or to email you details of opportunities you may be interested in. We will only send you marketing communications by electronic means (e-mail, via our apps or text) if those communications relate to goods, services or opportunities which are similar to those that you have previously purchased or expressed an interest in or if you have consented to us contacting you in this way (see below). We will also need to collect and process KYC information in order to comply with our legal obligations.

During your account set-up process you will be able to opt out of receiving marketing communications from us and/or third parties. You can change your marketing preferences at any time by contacting us at contact@huddlestock.com if you are an investor or vendorhelp@huddlestock.com if you are a strategy vendor.

Improving our services

We may use your personal data to analyse how you are using the Huddlestock service and to gain insights into how we can improve our products and services.

Customer Support and account administration

We may use your personal data to provide you with customer support or to investigate complaints or concerns about your account.

Providing information to third parties for marketing purposes and for related products and services

In certain circumstances we may ask for your consent to share your personal data with explicitly identified third parties so that they can contact you for marketing purposes or provide you with their own products or services. We will only do so if you have given us your explicit consent to share your personal information in this way, which can be given via a pop-up screen on the Website or Mobile apps. You can withdraw your consent at any time by writing to us at contact@huddlestock.com if you are an investor or vendorhelp@huddlestock.com if you are a strategy vendor.

Do we share personal information with anyone else?

We may disclose personal information we collect or receive to the following third parties:

What is our lawful basis for processing your personal data?

Under Article 6 of the EU General Data Protection Regulation (GDPR) we are required to tell you about the legal basis under which we collect and process your data.

We will only collect and process your personal data in accordance with one of the below lawful bases:

Data storage and international transfers

We take the security of your data very seriously, and all of your personal data will be kept according to strict safeguards and in compliance with the GDPR. Your data will be stored on cloud servers within the EEA and we will only store your data outside the EEA in the event that the jurisdiction in question has been assessed as compliant with the GDPR.

Automated decision making

When you enter in details of your interests and other suitability details, our automated matching system may use this data to sort and limit the investment ideas you see on our Website and mobile apps. This does not affect your legal rights.

You can object to automated decision making using your data by writing to us at contact@huddlestock.com if you are an investor or vendorhelp@huddlestock.com if you are a strategy vendor. Please note that this may limit the functionality of our service as a result.

Your rights

You have the right to be informed over what personal data we hold and how we are using it. This information is contained within this privacy notice.

If you have consented to particular uses of your personal data, you have the right to withdraw this consent at any time.

You have the right to “portability” of your personal data that we have collected with your consent or in performance of a contract that is used in automated decision-making. This means that you can request copies of all the personal data we hold for this purpose in a structured, commonly used, and machine readable form, and we will supply this to you free of charge on request. We will respond to these requests within one month, unless the request is particularly complex, in which case we will inform you of how long it will take as soon as possible.

You have the right to request a copy of the personal data we hold under the GDPR by making a “subject access request” to us in writing. We will comply with all valid subject access requests within 30 days, unless the request is particularly complex; in this case we will contact you within 30 days with further information. You will not be charged for making a subject access request request unless we reasonably deem this to be a manifestly unfounded or excessive request, in which instance you will be charged a reasonable fee based on the administrative costs of providing the information.

If some of the personal data we hold is inaccurate or incomplete, you can request that we rectify our records by writing to us. We will comply with all requests within 30 days unless the request is particularly complex; in this case we will contact you within 30 days with further information.

Where we are using your personal data in accordance with our legitimate interests, you can object to further use of your data. This objection should be based on grounds relating to your particular situation. If you object, we will stop using your personal data in this way immediately, unless there are compelling legitimate grounds for processing your personal data which override your interests, rights and freedoms (such as requests by law enforcement) or we need to process your data for the establishment, exercise or defence of legal claims. You may always object to further use of your data for direct marketing purposes by clicking the “unsubscribe” button within marketing emails or by contacting us by writing to us at contact@huddlestock.com if you are an investor or vendorhelp@huddlestock.com if you are a strategy vendor.

You have the right to request erasure of the personal data we hold by contacting us. Please note that it is not always possible for us to comply with a request for erasure; for example, if we have collected data from you in performance of a contract, we cannot normally comply with a request for erasure unless we no longer have an active contract with you and the data is more than six years old.

You have the right to restrict the processing of your personal data in certain circumstances, such as when you object to us using your data in accordance with our legitimate interests or when you contest the accuracy of the data we hold on you.

You can exercise any of your rights by contacting us via the details at the bottom of this page. Please note that we may need to verify your identity before complying with any of the above requests.

How long we will keep your data for

We will only keep your personal data for as long as is necessary. This means that we will retain your personal data for as long as we have an active contract or business relationship with you, and after this, we will only keep your data for as long as is necessary for the purposes which it is stored.

What happens if you don’t provide us with the information we need

As outlined above, some of the personal data you provide to us will be used in order to enter into a contract with you and to comply with our legal obligations.

Should you not provide us with the data we require to offer our service or request that we erase the personal data we hold, it is likely that we will not be able to deliver our services to you.

Cookies

Cookies are small files placed on your device when you visit our Website. We use cookies to recognise you and your preferences, improve the performance of our Website and to create statistical data.

Cookies generally fall into one of the following categories:

Our Website uses all of the above types of cookies.

Some of our cookies remain on your device between your browsing sessions.

You can disable our cookies by changing the settings on your browser but doing so might mean you are unable to use certain features of our Website.

Complaints and contacting us

If you feel that we have not been complying with our obligations on data protection law or you wish to assert one of your rights, please contact us without delay in writing to us at contact@huddlestock.com if you are an investor or vendorhelp@huddlestock.com if you are a strategy vendor.

Should you be dissatisfied with our response or wish to complain to the relevant supervisory authority, you can do so by contacting the Information Commissioner’s Office (ICO). Contact details for the ICO can be found on this webpage.

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