Welcome to the Investlingo Ltd’s privacy policy.

Investlingo Ltd (collectively referred to as “we“, “us” or “our“) is committed to protecting and respecting your privacy. This privacy policy applies to anyone visiting or using our website, applications and services, in particular our content creators (collectively referred to as “you” or “your”) as further defined below. It aims to give you information as to how we look after your personal data when you use our website, applications or services, or engage with us by any other means. This privacy policy also tells you about your privacy rights and how the law protects you.

For the purposes of this privacy policy, “content creators” refer to any person contributing articles or other digital content on our application, which will then be available or sold to our customers. This includes without limitation individual and institutional analysts, fund managers, research companies who enjoy sharing their investment insights, expertise and ideas with our worldwide community.

The application is not intended for children and we do not knowingly attempt to solicit or receive data relating to children.

1. Important information and who we are

1.1 Controller
Investlingo Ltd is the “data controller” for the purposes of data protection legislation. We are responsible for your personal information and, by law, we are required to provide you with information about us, about how and why we use your data and about the rights you have over it.

1.2 Changes to this privacy policy

We may review this privacy policy from time to time and we will notify you of any changes by uploading the new version of it on our application. We will send you an e-mail or post an update notice on the application so that you become aware of the updated version of this policy. The “Last updated” date at the top of this policy will also be adjusted accordingly.

You are advised to review this privacy policy periodically for any changes. Changes to this policy are effective when they are posted on our application.

1.3 Your duty to inform us of changes

It is 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.

2. The data we collect about you

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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes name , username or similar identifier, date of birth and gender.
• Contact Data includes residential or business address, email address and telephone numbers.
• Geo-location Data: includes your country location (based on your internet protocol (IP) address).
• Professional or Employment-related Data: includes the name of your company or employer, job title, education information, professional certification (e.g CFA (Chartered Financial Analyst) status) and other biographical information including professional interests and areas of expertise.
• Financial and Transaction Data includes bank account and payment card details to enable payments to and from you when you register as a content creator and details about contributions and other services you have provided to us.
• Technical Data includes 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, and other technology on the devices you use to access the application.
• Social Media Data includes your Website URL, Twitter URL, Linkedin URL and any other publicly available webpage where we may find information about your background, expertise and preferences.
• Profile Dataincludes your username, profile picture and any inferences drawn from any of the information identified above to create a profile reflecting your interests, preferences, characteristics and attitudes.
• Commercial Data includes stocks, ETFs and other securities that are referred to in the articles or other digtial content you provide to us, and that you have (or will have in short period of time) an exposure to.
• Marketing and Communications Dataincludes your preferences in receiving marketing from us and our third parties and your communication preferences.

You acknowledge and agree that it is of the essence of our business that we make available on our application / share with our end-users certain personal information about you so that they can engage with our services and, in particular, have the necessary background information about the authors of the reports that will be acquired through the application. Please see further details in section 5 below.

We may use personal data we collect from or about you to create Aggregated Data that does not specifically identify you. This includes statistical or demographic information for industry and market analysis, our marketing and advertising strategy or other business purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to engage you as Content Creator).

3. How is your personal data collected?
   We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Professional or Employment-related, Financial or Transaction, Profile, Social Media and Commercial Data when you:

• create an account on our website or application;
• enter into a contract with us to provide us with your articles;
• subscribe to our service or publications;
• interact with us by post, phone, e-mail or by any other means;
• request marketing to be sent to you;
• enter a competition, promotion or survey;
• answer our questionnaires;
• give us feedback.

• Automated technologies or interactions. As you interact with our application, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect this data by using cookies, server logs and other similar technologies.
• Third parties or publicly available sources. We may also receive personal data about you from third parties and public sources, such as analytics and search information providers and your social media pages, which will help us maintain and improve the accuracy of the records we hold about you.

4. How we use your personal data
   We will only use your personal data when the law allows us to. Most commonly, we will use (this is, process) your personal data in the following circumstances:

• Necessary for entering into or performing a contract. In order to perform obligations which arise under any contract we are about to enter into or have entered into with you.
• Necessary for the purposes of legitimate interests. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests include the provision of our services to our end-users through the platform, responding to enquiries from you or end-users, optimising our application and the overall user experience, informing you about our services / products and ensuring that our operations are conducted in an appropriate and efficient manner.
• . Necessary for compliance with a legal obligation. We are subject to certain legal requirements which may require us to process your information. We may also be obliged by law to disclose your information to a regulatory body or law enforcement agency.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing
To register you as a service provider/ contributor (e.g. Content Creator)	(a) Identity (b) Contact (c) Geo-location (d) Professional or Employment-related (e) Financial or Transaction (f) Social Media (g) Profile (h) Marketing and Communications	Performance of a contract with you
To interact with you and manage our relationship, which will include: (a) Upload and sell your articles on the platform (b) Manage payments and fees (c) Notify you about changes to our terms or privacy policy (d) Ask you to take a survey or otherwise interact with you for customer service purposes	(a) Identity (b) Contact (c) Professional or Employment-related (d) Financial or Transaction (e) Professional or Employment-related (f) Profile (g) Social Media (h) Commercial (i) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to promote your reports / other services on the application and to keep our records updated)
To administer and protect our business, website and the application (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or sale) (b) Necessary to comply with a legal obligation
To deliver relevant application content and advertisements to our customers and measure or understand the effectiveness of the content and advertising we serve to customers	(a) Identity (b) Contact (c) Financial or Transaction (d) Professional or Employment-related (e) Profile (f) Social Media (g) Marketing and Communications	Necessary for our legitimate interests (to study how customers use our products / services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, application, products/services, marketing, customer relationships and experiences. This may include making suggestions and recommendations to you as to contents that achieve a higher visibility / purchase rate on our application	(a) Identity (b) Contact (e) Professional (f) Profile (g) Social Media	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our application updated and relevant, to develop our business)

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Internal Third Parties:
  • Other companies in the Investlingo’s Group, including our Japanese subsidiary who will manage the online marketplace with our customers in Japan.
• External Third Parties:

Our Service Providers:

• Amazon Web Services (Cloud)
• MailerLite (Newsletter)
• Google Analytics (Tracking)
• Klaviyo (Automated marketing)
• Stripe (Payment processor)
• Google ads (Ads)
• Linkedin (Ads)
• Twitter (Ads)

Our Customers:

• In the case of Content Creators, we make available certain personal data about you on our application in order to provide our services (and promote your articles and other digital content) to our customers. This includes basic information, such as your name, the name of your company or employer), your email-address, social media pages, profile information, CFA status, biographical information. We will only share your information so long as it is necessary to enable the provision of our services and improve our customers’ experience.

In the context of a business restructuring:

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Your personal data may be transferred to, and processed in, countriesother than the country where you are resident. Specifically, our application servers are located in Japan, where our group company is also based. In particular, please note that the European Union recognizes Japan as a territory that provides adequate protection for personal information that is received from the EEA and UK.
We also use third party service providers and partners that operate worldwide, and so, the processing of your personal data by them may also involve its transfer to outside the country in which you are resident.
Whenever we transfer your personal data to other locations, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data as determined by the European Commision.
• Where we use certain service providers, we may use specific contracts approved for use in the EEA (such as Standard Contractual Clauses) which give personal data the same protection it has therein.

7. Data security
   We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:

• Right to access, correct or request deletion – you may be able to do some of this in your Investlingo’s account or by contacting us.Note, however, that we may not always be able to comply with your request of deletion for specific legal reasons – for example, where we are legally obligated to keep the information or if it is impossible or unproportionate for us to delete the data. In this case, we won’t delete it but we will only keep it for as long as it is needed and we have time limits on our data systems.
• Right to object, or ask us to restrict processing– you have the right to object to processingwhere we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you feel such processing impacts on your fundamental rights and freedoms. In certain circumstances, you may also have the right to ask us to suspend the processing of your data, such as: (i) If you want us to establish the data accuracy; (ii) where our use of the data is unlawful but you do not want us to delete it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Right to request portability – you have the right to ask us to transfer the personal data we hold about you, in a structured, commonly used, machine-readable format. Note this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to withdraw consent – you can withdraw your consent at any time If you previously gave us consent for processing your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

Right to complain – you have the right to complain to your local data protection authority.  For more information, please contact your local data protection authority. 
If you wish to exercise any of the rights set out above, please contact us on the contact details set out below.
If you are a California resident, please refer to the “Additional Information for California Residents” section at the end of this Policy for more information about the requests you may make under the California Consumer Privacy Act.

No fee usually required

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

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

10. Contact details
If you have any comments or questions about this privacy policy, or if you want to exercise your rights, please contact us at info@investlingo.com. We will address any issueto the best of our abilities as soon as possible, and respond to requests within the time required under applicable law.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Additional Information if you are a California Resident

If you are a California resident, the following information also applies to you and supplements the information contained in this privacy policy.

Information We Collect and Sources of Information

In the past 12 months, we have collected the information described in the section “The Data we Collect about You” above, which also includes categories of sources from which we have collected that personal information.   We collect this information for the business and commercial purposes described in the “Purposes for which we will use your personal data” section above. We share this information with the categories of third parties described in the “Disclosure of Your Personal Data” section above. Investlingo Ltd does not sell the personal data we collect (and will not sell it without providing you with a right to opt-out).

California Privacy Rights

If you are a California resident, you have the following consumer privacy rights:

• Right to Know: You have the right to request that we disclose to you the personal information we have collected, used, disclosed and sold over the past 12 months, and information about our data practices.      
• Right to request deletion: You can request that we delete personal information about you.  Although you may request deletion, we are allowed, under California law, to keep certain personal information. 
• Right to Opt-Out of “Sale” of personal information: You can opt out of the “sale” of your personal information to “third parties” by contacting us (as those terms are defined in the CCPA).       
• Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights. 

California law also permits you to request certain information regarding the disclosure of your personal information by us and our related companies to third parties for the third parties’ direct marketing purposes. We do not disclose your personal information to third parties for their own direct marketing purposes.

California users may make a request pursuant to their rights under the CCPA by contacting us at the e-mail address info@investlingo.com. We will verify your request using the personal data available to us, including email address. You can also designate an authorized agent to exercise these rights on your behalf.