Our Privacy Policy/Notice

 

Last updated: [22] May 2020 What’s new?

 

 

Your personal data and privacy matters

 

Personal data means any information about an individual from which that person can be identified.

 

Your personal data and privacy is important to us.

 

We are committed to safeguarding your personal data and protecting your privacy.

 

 

This privacy policy explains how we achieve that by describing:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

  1. How this privacy policy is structured

 

We have set out this privacy policy in a layered format, so that you can click through to the specific areas listed above individually rather than having to scroll through them.

 

When you click on the hyperlinked sections listed above, you will first be shown an “at-a-glance” short notice, which sets out the key information relating to that section.  You will be able to expand that section further to reveal more detailed information.

 

Alternatively, you can download a pdf version of the full text of the privacy policy here.

 

 

  1. How this privacy policy applies to you

 

This privacy policy applies to:

 

 

 

 

This privacy policy does not apply to your relationship with your wealth manager(s), venture capital firm, investor, family office and / or broker (in this privacy policy, all are referred to as "firms") or any investee company ("companies") and therefore does not replace any privacy policy that it/they have issued to you.

 

Any notices or statements relating to data, data protection, fair processing and/or privacy that we may issue at the time of collecting personal data about you will supplement this privacy policy.  They are not intended to override it.

 

We may change this privacy policy from time to time to reflect changes in the law and/or our personal data handling activities and data protection practices.

 

We encourage you to check this privacy policy for changes whenever you visit our website or the Floww platform, as we may not always notify you of the 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.

 

 

  1. Who we are

 

We are FOMTech Limited of 123 Victoria Street London SW1 6DE. 

 

We are the owner and operator of the Floww platform and the data controller of your personal data where we use your personal data for our own business purposes, which we have explained further below.

 

There are instances of collection and handling of your personal data that we carry out for and on behalf of firms.  We have made it clear below when this applies.  In these instances, we are the data processor of your personal data for and on behalf of the firm as the data controller.

 

We will refer to ourselves in this privacy notice in the first person, e.g. “we”, “us” and “our”.

 

 

 

 

 

  1. How to get hold of us

 

If you have any data related queries or questions about this privacy notice, including any requests to exercise your legal rights relating to your personal data or to make a complaint about how your personal data is being handled, please contact us using the details below:

 

 

 

 

 

 

 

 

  1. Who is involved in our collection, handling and use of your personal data?

 

 

 

A description of the type of third party service providers that we currently use and what we use them for is set out in Appendix 1.  We will update this from time to time.  If you would like to receive a list of the third party providers that we use in relation to your personal data, please contact us.

 

 

 

 

  1. What personal data about you do we collect?

 

Personal data means any information about an individual from which that person can be identified. It does not include data where the person is no longer identifiable (anonymous data).

 

We will collect, use, store, share and transfer the different kinds of personal data and associated information about you which we have grouped together below.

 

We refer generically to that personal data and associated information in this privacy policy as “personal data”:

 

 

 

 

 

 

 

We also collect, handle, use and share:

 

 

 

We do not collect any Special Categories of Personal Data about you, which 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.

 

We do not intentionally collect personal data relating to children.

 

 

 

 

  1. Where do we source your personal data from and how?

 

We use different methods to collect personal data from and about you, including through:

 

 

 

 

 

 

  1. Whether you have to provide the information that we have requested from you

 

If you don’t want us to collect any personal data from you, please do not use our website or the Floww platform. 

 

We collect the same types of personal data from all users of our website and the Floww platform and so cannot filter what we collect from individual users.

 

You can, however, ask us not to carry out any automated decision-making in relation to you by contacting us at any time.

 

 

  1. What do we do with your personal data?

 

We will only use your personal data when the law allows us to.  Most commonly, we will use your personal data in the following circumstances:

 

 

 

We set out below the personal data handling activities that we carry out in respect of your personal data.  We have set out in Section 12 what our data protection personality (i.e. data controller or data processor) in respect of such activities and our legal justification for doing so:

 

 

 

The majority of our marketing communications will be made via and within the Floww platform.  That said, depending on the contact preferences you select, we may also communicate with you by post, telephone, SMS, email or other electronic means such as via social and digital media.

 

We will provide you with information, products or services that you request from us or which we feel may interest you.

 

We may use your Usage Data to help ensure that this messaging is personalised and relevant to you;

 

 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.  If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly;

 

 

You will receive promotional communications from us if you have:

 

 

 

and, in each case, you have not opted out of receiving that promotion;

 

 

For example, we may do this using your Usage Data to decide whether to let you know about a venture, investment or transaction and to determine the risk of doing so. 

 

You can ask us not to carry out this automated decision-making by contacting us at any time;

 

 

Using Anonymised Data and in order to optimise distribution channels, we will keep track of what types of users are interested in the different ventures, investments, transactions and assets on offer on the Floww platform; and

 

 

We’ll do this where the law requires it, to comply with regulation, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes.  This information will be shared only for the purposes described above.

 

 

 

  1. Other use related information

 

 

 

 

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.

 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

  1. Who do we share your personal data with?

 

We may share your personal data with the following entities for the purposes set out in Section 12 and as set out in Appendix 1:

 

 

 

 

 

 

 

 

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, which includes this privacy policy.

 

  1. What are the legal grounds for our collection, handling, use and sharing of your personal data?

 

 

COLLECTION, HANDLING + USAGE

 

 

Purpose/Activity

 

 

 

Type of personal data

 

 

Data controller/data processor

 

Legal basis for collection, handling and usage – CONTROLLER ONLY

 

Marketing purposes

 

 

·        Identity Data

·        Usage Data

·        Marketing Data

 

 

Data controller

 

Your consent

 

Cookies

 

 

·        Technical Data

 

Data controller

 

Your consent

 

Promotional offers

 

 

·        Identity Data

·        Contact Data

·        Technical Data

·        Usage Data

 

 

Data controller

 

Legitimate interests

 

Automated decision-making

 

 

·        Usage Data

 

Data controller

 

Legitimate interests

 

Tracking activities

 

 

·        Identity Data

·        Usage Data

 

 

Data processor

 

N/A

 

Monitoring purposes

 

 

·        Identity Data

·        Contact Data

·        Technical Data

·        Usage Data

·        Marketing Data

 

 

 

Compliance with a legal obligation of us

Data sharing purposes

·        Identity Data

·        Contact Data

 

Data controller

Legitimate interests

 

SHARING

 

 

Entity with whom personal data is shared

 

 

What personal data is shared

 

Purpose of sharing

 

Legal basis for sharing

 

Firms

 

·        Identity Data

·        Usage Data

 

 

To fulfil data processor duties

 

 

For and on behalf of the firm as the data controller

 

Other Floww platform users

·        Identity Data

·        Contact Data

 

To inform and facilitate investment opportunities

Legitimate interests

 

 

  1. Where do we send your personal data to for storage or other specific purposes?

 

We’re based in the UK and will not transfer your personal data outside the EEA other than in accordance with the law.  We will send your personal data for processing to our partner in the Philippines. 

 

If we do so we’ll make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply.

 

We will provide you with details of the safeguards that we have implemented, if you would like to know what they are.

 

 

  1. How will we look after your personal data?

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an authorised 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 supervisory authority where we are legal required to do so.

 

 

 

  1. How long will we keep your personal data for?

 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

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 handle your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

We will carry out a review of all the personal data that we hold and make the determination detailed above every 2 calendar years.

 

In some circumstances, you can ask us to delete your personal data.  Please see the Right of erasure below for further information.

 

We will keep and use Anonymised Data indefinitely without further notice to you.

 

 

  1. What are your legal rights in respect of your personal data that we handle?

 

We set out below a list of the legal rights that all individuals have under data protection laws in relation to our handling of your personal data.  They don’t apply in all circumstances:

 

 

 

 

 

 

 

 

 

 

 

 

 

Procedure to exercise your legal rights

 

 

In this instance, we’ll explain first whether or not the right you wish to exercise applies and whether we are the data controller in that respect. 

 

If we are not the data controller, we will direct you to the appropriate entity that is. 

 

If we are the data controller and the right you wish to exercise applies, we will facilitate your request in accordance with the procedure below.

 

 

 

 

 

  1. Your FAQs answered

 

Who can I ask about this policy? – to ask us anything in relation to this privacy policy or any personal data that we may hold, please simply please contact us.

 

Can I see what data you hold about me? – if you want to be informed about your personal data that we hold, to have access to it or wish for it to be changed in any way, moved or deleted, please follow the Procedure to exercise your legal rights above.

 

What should you do if your personal data changes? – you should tell us by contacting us, so that we can update our records.

 

Do you have to provide your personal data to us? – we’re unable to provide you with our products or services if you do not provide certain information to us. In cases where providing some personal information is optional, we’ll make this clear.

 

Do we do any monitoring of your personal data? – monitoring refers to: listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person (face to face) meetings and other communications.

 

We may monitor where permitted by law and we’ll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.

 

 

 

 


 

Appendix 1 - Third party service providers