Please note, that the person completing the registration to the Service must be at least 18 years old and of full legal capacity. If a user gives us information on underaged individuals, they are responsible for acquiring the necessary consents from the guardian of the minor.
“Personal Information”, as used in this policy, shall be understood to fall under the definition of “Personal Data” in accordance with art. 4(1) European General Data Protection Regulation (“GDPR”).
The Personal Information collected and stored by us may be categorised as follows:
We only use your Personal Information for legitimate and otherwise decent purposes. We comply with GDPR as well as applicable national privacy laws.
We engage in using your Personal Information for the following purposes only:
3.1. Offering the service to you
If you register a profile to the Service, we are able to provide you with interesting investment opportunities and other services. Through your user account you can invest, view historical information related to your investments and use shareholder services. Registering and thereby providing some Personal Information to us is mandatory in order for us to be able to identify you and offer you our services.
Furthermore, we collect and use your Personal Information for the purposes of responding to your questions and fulfilling your requests. In addition, we may use your Personal Information to develop the Service and to customize the Service to better address your use of the Service. We may also send you communicative messages on changes to the Service, in accordance with the communication preferences of your choice. Also, we may contact you in case there are problems relating to your investment, such as insufficient identity information or error in your payment. To the extent permitted by applicable legislation, we may also use your Personal Information to enforce an agreement between you and us, to ensure the security and functionality of the Service and to investigate any fraud or other misuse of the Service.
3.2. Offering the service to investment targets
The purpose of the Service is to assist target companies to find and connect with new holders of securities. It is a part of the nature of the Service that the target companies know who their shareholders are and are able to communicate with them, for example send invites to annual general meetings. Your Personal Information is needed also to fulfill this purpose. We share relevant and necessary parts of your Personal Information with the target companies. More information regarding sharing of your Personal Information will follow later in this Policy.
3.3. Complying with our regulatory obligations
We, as a financial service provider, are required to assess whether the Service we offer is appropriate for you. Thus, we need to gather some Personal Information on your education and income level as well as your investment history and knowledge.
According to the legislation regarding the prevention of money laundering and financing of terrorism and frauds, we, as a financial service provider, are required to know our customers. We need to gather Personal Information on you and verify your identity for these purposes. We might also need to contact you for further clarification related to the information you have provided. Furthermore, we’re required to use the Personal Information to check whether you’re subject to economic sanctions or politically exposed.
A part of the information is required due to our responsibility to fulfil our regulatory reporting obligations, such as taxation reports and trade reporting to relevant authorities.
We may further need to use your information to contact you in accordance with GDPR in case your personal information leaks or is misused, or should be updated.
Details on the payments made by you to our customer deposit account and repayments made by us to you are kept for bookkeeping purposes and to ensure compliance with regulations having to do with holding customer funds.
3.4. Targeting automated marketing
3.5. Sending marketing communications according to your selected preferences
Our newsletter is sent out regularly by email, and we also offer other interesting communications to you. By allowing us to send you marketing communications, you get to know the latest news in Invesdor as well as hear from our exciting new target companies. You can affect the kind of communications you receive by modifying your notification preferences on your profile. Reception of marketing communications is always consent-based.
3.6. Analyzing and conducting research
Digital fundraising services like ours are quite new, and thus loads of market and academic studies are conducted around the world. We like to do our part, and thus, we conduct our own research. We’re also quite co-operative with universities conducting research. We may use your Personal Information for these purposes, and also share the Personal Information with universities.
When you register as a user to the Service, Invesdor gathers some Personal Information of you. In the registration phase, you need to submit your email address and country of residence, as well as verify that you’re at least 18-years old and of full legal capacity. Invesdor saves the timing of your registration. The email address acts as your username. If you wish, you can choose to submit more than the required amount of Personal Information by editing the profile created for you.
When you make your first investment, we are required to collect more of your Personal Information. In addition to you submitting you Personal Information, we may also gather it from the Internet and such service providers who offer identity and information services. Further, Invesdor may also collect information from third parties who are independent data controllers for partnership, co-operation and marketing purposes.
The Service and affiliate services may install cookies to collect certain Personal Information and technical information necessary to enable the proper functioning and provision of the Service.
Furthermore, we also collect the following Personal Information regarding your Investments:
In some cases, it may be necessary for us to refund your investment. In these cases, we save Personal Information related to payments from Invesdor to you.
We have a legal obligation to record phone calls if the aim of the call is to result in a transaction. If you give us Personal Information on the phone, please bear in mind that the call and the Personal Information given might be recorded.
We process your Personal Information based on your customer relationship with Invesdor. Some collection and processing of Personal Information is based on your consent (such as sending you marketing communications), some is based on a contractual relationship between you and us, and some we have a legitimate interest towards. The remaining basis is our legal requirements.
When we use legitimate interest as grounds for processing your Personal Information, we always assess whether our legitimate interest is prior to the legal rights granted to you by applicable privacy legislation. If we consider our legitimate interest prior to yours, we may be able to continue processing your Personal Information even if you wish to withdraw your consent.
For the sake of clarity, it is stated that direct marketing to individuals always requires a consent.
In the Ownersportal service meant for administering shareholder lists we act merely as a data processor while the company using the service is the data controller.
Offering the Services to our customers requires sharing Personal Information with third parties. In order for us to be able to transmit your investment to, and for you to become a shareholder in, a target company, we need to share some of your Personal Information with that target company. This may include cookie-based information acquired from our third party service providers.
In your profile, you may choose a username. The user name will be published in the list of investors of an offering you have invested, and it will be visible to other users of the Service. Most of the offerings have a discussion forum where users may ask questions from target companies and Invesdor, and your username will also be visible in conjunction with a comment you have posted on the Investor Forum. If you don’t choose a username, your username will be “anonymous”.
If your Personal Information is shared with a third party, we always ensure they comply with GDPR, and there is a sufficient agreement on data processing in force between the party and us.
Invesdor, as a data controller, is determined to look after your data privacy. In this section we explain data security related policies, data storage, rights of the users of our service and means of getting in touch with us on Personal Information and privacy related matters.
7.1 Storing data
The security of data is in the very core of Invesdor’s business. We apply appropriate technical, organizational and administrative measures to ensure the security of your Personal Information against data breaches, modifying, demolishing, fraud and other malicious behavior.
Your Personal Information is stored in electronic form on the web-based platform of Invesdor, which is physically in at least two separate data centers, located in the EEA-area, at least 50 kilometers apart from each other. The database where the Personal Information is stored is duplicated and operated in a locked and surveilled environment, to which only authorized individuals have access. The Personal Information is stored in an encrypted form.
Please note that despite the security measures taken by Invesdor, the use of the Internet and submission of Personal Information is always associated with risks and no system or measure is completely safe against all possible kinds of attacks. Invesdor recommends that you always use caution when submitting any Personal Information on the Internet.
7.2 Marketing communication preferences
From your profile settings you may affect the kinds of marketing communications we send you. We recommend you review your current settings and modify them according to your preferences.
7.3 Reviewing your personal information
You may at any time review the information you have submitted from your own profile and export the information in xml-form. You may also update your information by editing your profile.
7.4 Deleting your personal information
If you wish to have your Personal Information removed, you may send us a request to email@example.com. Please note, that due to legislation, we are often not allowed to delete your information, and in these situations, we limit the use of your Personal Information in storing it in accordance with the legislation.
7.5 Contacting Invesdor
If you are unsatisfied in our way of using your personal information, please contact us at firstname.lastname@example.org to file an official complaint.
For other questions and comments on our privacy policies, you may contact us through other means as well, for example by using the chat tool on our website.
Please note, that the messages sent to Invesdor's email addresses and the messages sent via the chat tool on our website may be transmitted through an unsecured connection. Please always submit your personal information by uploading it directly on the platform instead of sending it to us via email.
You have the right to affect our use of your Personal Information. Below we have listed your rights and how to exercise them.
8.1. Right to examine your Personal Information
You have the right at any time to inspect Personal Information submitted to the Service by you.
Occasionally, Personal Information might be gathered for the purpose of investigating money laundering and financing of terrorism. According to legislation, we are not permitted to let you know, when we are investigating these matters nore disclose other information related to the investigation. Thus, it might be that we possess information you are not entitled to examine. There may also be other legitimate restrictions we need to follow. In addition, protecting our trade secrets and other users’ Personal Information may limit the information we can show you.
8.2. Right to correct your Personal Information
You have the right to have any incorrect, incomplete, outdated or unnecessary Personal Information removed or updated, and Invesdor may also without notice itself correct or remove any incorrect, incomplete, outdated or unnecessary Personal Information. Please note, that the Personal Information you have given us in conjunction with a transaction in the Service may not be changed without input from our side.
8.3. Right to prohibit us from using your Personal Information
You may at any time prohibit Invesdor from using your Personal Information. If you do not give us the right to process your Personal Information, we are unfortunately unable to offer our Service to you. Notwithstanding the previous, you may deny us from using your Personal Information for direct marketing purposes, and still use the Service.
In case your Personal Information is needed to fulfill our legal obligations, it might be that we cannot seize using your information despite you requesting it. In these cases, we’ll stop further use of the Personal Information, and only use it for this legal purpose as well as store it for the required time.
8.4. Right to be forgotten
In case you have not used the Service to do financial transactions, you have the right to be forgotten. If investments through the user account have been made, we are obliged by law to preserve your Personal Information for the minimum of 5 years of ending the customer relationship with you, and thus we are often unable to remove your information even if you so demand.
8.5. Right to limit our usage of your Personal Information
If you deny our right to use your Personal Information, if the Personal Information we have registered is incorrect or if you consider our data processing policies unlawful, you may limit our use of your Personal Information to storing only. In case you do not have the right to be forgotten, you may still ask us to limit the use of your Personal Information to preserving the information only. If you choose to do so, we will seize from using the Personal Information for any other purposes, excluding situations when we have the legal obligation to do so. We may also use your Personal Information to enforce an agreement with you.
You may always limit the use of your Personal Information for direct marketing purposes.
8.6. Right to transfer your Personal Information
You have the right to acquire your Personal Information in a machine-readable format (xml) and transfer it to another service provider. Please note that Invesdor is not responsible for the exported Personal Information after you have successfully exported it.
8.7. How to exercise your rights
By visiting the Personal Information page of your user account in our Service, you can examine the given Personal Information, export the information as an xml-file and make updates and modifications when necessary. If you need to modify the Personal Information you have submitted in relation to a transaction you have made through the Service, you need to contact us.
If you wish to modify your communications settings, this can also be done through your user account settings.
If you need assistance or wish to contact us to discuss informally, you may use our regular communication channels, such as the chat tool on our website.
For any official complaint or other notice, please contact Invesdor at email@example.com and detail your request. Invesdor will process your request without undue delay, in compliance with the time schedule set in applicable legislation.
We store your Personal Information for as long as we need it for the purpose it has been gathered for, or for as long as applicable legislation so requires. If you wish your Personal Information to be removed, you may contact us.
The data controller of the Personal Information that you submit to Invesdor or that Invesdor otherwise collects in or in connection with the Service is: Invesdor Ltd. (Business ID: 2468896-2), a limited liability company duly established under the laws of Finland, having its principal place of business at Salomonkatu 17 A, 00100 Helsinki, Finland.
In matters relating to your privacy and any Personal Information submitted to or collected by Invesdor, please contact Invesdor by sending email to the address firstname.lastname@example.org.