We collect and process some of your personal information to allow us to operate as a business, provide you with our services and to meet the legal obligations we have as a regulated financial services firm.

As a fintech company we also use a number of third parties to carry out certain business functions which may require us to share your information with them.

This policy details the personal information we collect and use, how we look after it, and the circumstances in which we may share it with someone else. It also sets out your rights around how we handle your information and lets you know how to contact us if you have any concerns.

Who we are

Incept Technologies Limited (Company Reference number: 11585664). Your privacy and the security of your personal data is extremely important to us and as. This document is our Privacy Notice to you.

If you have any questions about this notice please email us at hello@incept.io

What information we collect

To provide you with our services we collect and use the following information about you at various points during your interactions with us.

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

• Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data (which may include bank account details).
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from 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 this website.
• Profile Data includes your username and password, your transactions, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect your Personal Data about you from publicly available sources for the purposes of completing our anti-money laundering and know-your-client checks that we are required to carry out as a regulated financial services firm.

We also collect, use and share Aggregated Data (such as statistical or demographic data) for any 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.

In the exceptional circumstance that we collect, or you provide us with any special category information (information about your physical and mental health, sexual orientation, racial or ethnic profile, political opinions, philosophical beliefs, trade union membership or biometric data) we will treat it with extra care, and only use and store it if we have a legitimate reason to do so.

We may also collect personal data in the following circumstances:

1. When you contact us:
   1. i) Information you give to us when you get in touch via email or through social media platforms
   2. ii) Information you provide to us when applying for a job or to provide us with your services
2. When you visit our website (www.incept.io) and its sub-domains:
   1. i) Technical information on how you use our website including your IP address, device type and approximate location
3. When a third party we use sends us information:
   1. i) Information we may receive about you from third parties we work with, for example an identity verification service
4. Referrals
   1. i) If you choose to use our referral service to tell a contact about our website, we will ask you for your contacts’ name and email address. You must have consent from your contact to provide this information to us. We will automatically send your contact a one-time email inviting him or her to visit the site. Incept store this information for the sole purpose of sending this one-time email and tracking the success of our referral program. Your contact may contact us at hello@incept.io to request that we remove this information from our database.
5. Product improvements
   1. i) includes usage analytics and customer feedback and surveys
6. Technical
   1. i) Hosting and backend infrastructure
   2. ii) Infrastructure monitoring

• iii) Traffic optimization and distribution

How we use your information

We use your information to:

• Provide you with our core services of stockbroking
• Comply with the law and regulations
• To resolve queries or issues
• Improve our product
• Prevent misuse and fraud
• Market new features or services

We take appropriate security measures to prevent unauthorised access, disclosure, modification or erasure of your personal information.

Our lawful bases for using your information

We only process your information where we have a lawful basis for doing so. We process your information if:

• We have a legitimate interest to do so in order to provide our business services to you and to operate and improve our product, for example storing your email address so you can sign into our app.
• There are obligations arising from any contracts between you and us, for example where you have asked us to buy or sell a share for you.
• We have a duty to comply with any legal or regulatory requirements, for example verifying your identity as part of our anti-money laundering controls or making transaction reports to regulators.
• You have provided us with consent to do so.

When we share your information

Your information is shared with representatives of Incept who require it to run your account, resolve any issues or queries, improve our product and services or contact you about features you may be interested in where we have your consent to do so.

Some of your information is processed by third parties we use to provide elements of our service. We conduct due diligence on these third parties, to make sure your information is handled securely and only allow third parties to process your personal information where it is required for them to carry out their function.

Where we store your information

Your information is processed and stored on servers managed by our hosting providers.

In some circumstances your information may be stored somewhere outside of the European Economic Area (EEA). In these situations, we have contracts in place to ensure information is protected to the same standards as it is in the EEA. If your information is stored in the US we make sure the organisation is part of the Privacy Shield.

How long we keep your information

We store your information for the duration of time required by the purpose under which we collected the information. Information we collect:

• in relation to our legitimate interests of providing you with our services will be kept for as long as you continue to remain a user of our services.
• for the purposes of performing a contract between you and us is kept until the contract has been completed.
• in relation to our legal and regulatory obligations is retained for the duration set out in the legislation we are subject to, which in most cases is 5-7 years following the end of our business relationship with you.

Your rights

You have rights under the law and this policy in relation to your information. If you would like to make any request in relation to these rights then please contact us by email. You have the right to:

• request to access the information we hold about you.
• ask us to update any of your information which is inaccurate or incorrect
• ask us to delete, stop processing or limit our use of your information that we hold – if we have a legal obligation to retain this information, we are unable to delete it until the required retention period has elapsed.

Marketing

We may send you certain direct marketing communications if it is in our legitimate interests to do so for marketing and business development purposes, or you have provided us with your consent to do so.

You can withdraw this consent by contacting us in app or by email.

How to make a complaint

If you would like to make a complaint, then please contact us via email and we will do our best to resolve the issue.

You also have the right to complain about our collection and use of your personal information to the Information Commissioner’s Office (ICO). More information can be found at https://ico.org.uk/make-a-complaint/

Where your data is stored

The data we collect from you may be transferred to and stored somewhere outside the European Economic Area (“EEA”) if we have specific agreements and/or due diligence in place.

In certain circumstances it may also be processed by staff outside the EEA who work for us or a select third party.

Changes to this policy

We continuously review our policies and procedures. We’ll post any changes we make to this policy on this page and let you know about any significant changes via email.