PRIVACY POLICY


Welcome to Globacap’s privacy policy.   This privacy policy aims to give you information on how we collect and process your personal data including through your use of our website or any of our products or services.  It also includes our Cookie Policy.

We are committed to protecting and respecting your privacy and personal data, and to complying with our legal obligations.


When we refer to our “website” we mean https://globacap.com including the investment, administration and management platform available through the website or any of its sub-domains or pages. References to “we”, “our” or “us” is to Globacap Limited, operating under the name of Globacap.

1.  THE DATA WE COLLECT ABOUT YOU

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as set out below, together with some examples of each type of data.

Globacap will be the ‘data controller’ of this personal data that it collects and processes.

Identity Data

  • Identity information such as first name, maiden name, last name, username or similar identifier
  • Other information such as marital status, title, date of birth and gender
  • Onboarding information such as identification documents (for example, your passport or driving licence number), copies of any documents you have provided for identification or onboarding purposes
  • Visual information such as ID photos or other images of you, for instance for ID verification or onboarding

Contact Data

  • Address information such as registered address, contact address, billing address
  • Contact information such as email address, telephone numbers, or similar

Financial Data

  • Bank account and payment card details
  • Other financial addresses or information such as those relating to digital assets
  • Investment details, such as details about investments you may make (including those not filled or subsequently cancelled) through the platform, assets you may hold that are recorded in the platform, or payment or deposit information
  • Details about your interactions with investments or opportunities on the platform

Transaction Data

  • details about payments to and from you and other details of products and services you use
  • information relating to transactions such as date, time, amount, currencies, exchange rate, beneficiary details, sender’s and receiver’s name and registration information, the payment method used, and so forth
  • information relating to your investments or transactions in those investments
  • information relating to transfers in/out of your accounts or relating to you or your account

Technical Data

  • information about how you access our website including internet protocol (IP) address, your login data, and other data which may include trackers or cookies
  • information about the devices or browsers that you use to access our website including browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on or identifying information about the devices you use to access this website

Profile Data

  • information relating to your account, including username and password, holdings, investments, orders, and other activity, including your preferences and other settings
  • information as part of any investor classification, including for regulatory purposes), titles or qualifications you may hold, offices that you may hold, professional experience, investment experience, and so forth
  • your interests, preferences, feedback and survey responses, and records of any discussions or interactions we may have had with you
  • your preferences in receiving marketing from us and our third parties and your communication preferences

Usage Data

  • information about how you use or interact with our website, products and services or companies that utilise our platform or services
  • information about your visits to the website and historic visits, including the links you have clicked on, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling and clicks), and methods used to browse away from the page
  • information about how you interact with specific pages for instance specific deal pages for specific investments

‘Sensitive’ Data

We do not routinely collect any ‘sensitive’ information about you, such as about your race or ethnicity, religious or philosophical beliefs, health, sexual orientation, political opinions, and so on. Nor do we collect any information about criminal convictions and offences other than for the purposes of employee screening where permitted.  If you do give us ‘sensitive’ information we will only use this information strictly in accordance with the law.

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

 

2.  HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you. These include:

Interactions with us. You or persons acting on your behalf may give us your data including if you or they:

  • apply for our products or services;
  • create and/or set-up an account on our website;
  • onboard to our platform or create or amend your profile or fill in any investor questionnaires;
  • utilise any functionality of our website or platform;
  • be involved in or interact with any companies utilising our platform;
  • use or interact with our website; this may include automatic collection of data about your equipment, browsing actions and patterns, and similar. We utilise cookies and similar technologies. Please see our cookie policy at paragraph 6 for further details
  • subscribe to our service or publications including our newsletter, or enter into a survey;
  • request marketing to be sent to you;
  • communicate with us.

Our clients. Clients or customers of our products may provide your personal data to us.  An example could be where we administer the share register of a company, that company may provide us with your personal data (e.g. your name, address, and/or bank details).

Third parties or publicly available sources. We will receive personal data about you from various third parties such as credit-reference agencies, fraud-prevention agencies, analytics providers, and partners who help us to provide our services. We may also obtain data from publicly available sources such as Companies House or electoral registers.

 

3.  WHAT IF YOU DO NOT PROVIDE DATA TO US?

Where we need to collect personal data and you fail to provide that data when requested, we may not be able to provide services to you or perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In some circumstances we may have to cancel a product or service you have with us or cease providing a service we were providing to 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 your personal data in the following circumstances:

  • To provide our services or perform a contract we are about to enter into or have entered into with you.
  • 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. This may include performing our services and marketing our products and services or those available on our website.
  • Track, analyse and improve the services we give you and other customers.
  • Where we need to comply with a legal obligation. For example to comply with our regulatory obligations (such as know-your-client and anti-money-laundering obligations), and to try and prevent illegal activities such as money-laundering and fraud.

 

5.  MARKETING

You will receive marketing communications from us if you have requested information from us, signed-up for our newsletter, created an account on our website, or otherwise have provided your information or data to us and you have not opted out of receiving that marketing.

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we include this in marketing).

Communications that are required by law or that we are making on behalf of third parties (for instance a communication to you as a shareholder of a company who utilises our platform) are not considered “marketing” for these purposes.  Any opt-out (see below) will not affect or restrict our ability to send those types of communications to you.

We will get your express opt-in consent before we share your personal data with any third party for their own marketing purposes (other than marketing agencies or consultants working for us to market our products or services).

You can ask us or third parties to stop sending you marketing at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will only apply to receipt of marketing messages and will not apply to personal data provided to us as a result of a product or service that we provide to you or other interactions with our website.

 

6.  COOKIE POLICY

This paragraph of this Privacy Policy is our Cookie Policy.

A cookie is a small file of letters and numbers that we store on your browser or on your computer if you agree. Cookies contain information that is transferred to your computer’s memory.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

Some cookies are essential and are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website and keep you logged in as you navigate through our website. We also use other cookies which we consider necessary may include cookies that whilst not essential make our website work or improve the functionality of our website. We may also use analytics and targeting cookies.

Analytics and targeting cookies are cookies that record your visit to our website, the pages you have visited and the links you have followed. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily and to improve our products and services. We will use this information to inform our website, product and marketing decisions. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services, or third party websites or services) may also use cookies. We have no control over these cookies.

You are able to block cookies.  This could include activating the setting on your browser that allows you to refuse the setting of all or some cookies. You may also be able to utilise third party plugins or extensions to block or restrict certain cookies. However, if you use your browser settings or an application to block all cookies (including essential cookies) you may not be able to access all or parts of our site, and it may impair your experience.

 

7.  DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data as permitted by this policy or by law, including with

  • Anyone who works for us or for our group when they need it to do their job.
  • To our group companies as needed to perform services we or they are providing to you
  • Any organisation which supports any of our services you use, when they need it to offer those services, for instance: credit reference agencies, analytical, Know Your Customer (KYC) and cyber security service providers, and customer ‘interface’ providers
  • Companies that do advertising for us (but we won’t share identifiable personal data with third parties for their own direct marketing unless you give us permission, and you can opt out any time).
  • Legal, regulatory, tax and other authorities, where requested or required.
  • Our banking and custodial partners, for instance to comply with their own KYC / anti-money-laundering requirements, or to identify assets as belonging to or being held for you.
  • Anyone who you give us explicit permission to share it with.
  • To enforce our Terms and Conditions or to carry out your instructions or comply with our other agreements in place with you (for instance in connection with your investments).
  • We’ll also share it to comply with the law or to protect the rights or safety of us or others.

We might transfer and store the data we collect from you somewhere outside the European Economic Area (‘EEA’). People who work for us or our suppliers outside the EEA might also process your data. We may share data with organisations and countries that The European Commission say have adequate data protection, or with whom we’ve agreed standard data protection clauses with.

 

8.  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 comply notify you and any applicable regulator of a breach where we are legally required to do so.

 

9.  DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for or to comply with our legal obligations.

Where you are a client, we will keep your data for as long as you are a client and for six (6) years after that to comply with our legal obligations (including regulatory, tax, accounting or reporting requirements) (or such longer period as may be required by law). 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.

In other circumstances, 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.  Our standard retention period is six years. Details of retention periods for different aspects of your personal data are available on request.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

 

10.  YOUR LEGAL RIGHTS

You have a right among other things to:

  • To be informed how we use your personal information and we do this through this Privacy Policy.
  • Access the personal data we hold about you, or to get a copy of it.
  • Ask us to correct inaccurate data.
  • Ask us to delete, ‘block’ or suppress your data, though for legal reasons we might not always be able to do it, and there are other limitations to this right.
  • Object to us using your data for direct marketing and certain other purposes
  • Withdraw any consent you’ve previously given us going forwards. Note, it will have been lawful for us to use the personal information up to the point you withdrew your permission

Please note that there may be circumstances where we are entitled to refuse your requests, for instance where we have a legal obligation to retain information.

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.

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.

 

11.  QUESTIONS

If you have any questions about this privacy policy, including any concerns relating to your personal information or requests to exercise your legal rights, please contact us by email at [email protected].

 

12.  COMPLAINTS  

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.

We’re registered with the Information Commissioner’s Office (ICO) under number ZA559999.

 

13.  CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review and it may be updated from time to time. This version was last updated in November 2019.

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.