Last updated on 07 Nov, 2024.
At invuno, we understand that confidentiality and security of the personal
information (“Personal Information”) that you share with us is important. invuno is committed to protecting the privacy of Personal Information, including Personal Information related to individuals who may be
clients, employees, agents, job applicants. By opening an account at invuno or by utilizing the products, services and applications available through invuno, you have consented to the collection, use and disclosure of your Personal Information in accordance with this privacy policy (“Privacy Policy” or “Policy”). We encourage you to read this Privacy Policy carefully.
This Policy is based on the privacy and data protection principles common to the
countries in which we operate. This Policy is intended to summarize invuno’s data
protection practices generally and to advise our clients, prospective clients, job
applicants, website visitors, app users and other third parties about invuno’s privacy policies that may be applicable to them.
This Policy is specifically addressed to those who provide Personal Information to invuno or who visit or use invuno’s website, investing app on Android and iOS platforms, and social media channels.
Who is responsible for your Personal Information?
invuno is responsible for the Personal Information that we may collect.
How do we collect your Personal Information and what Personal Information do
we collect?
invuno collects Personal Information from you. This may include, among other things,
information:
– provided during the invuno account application process (for example, your name, email address);
– provided when you apply for an employment opportunity with us (for example,
your name, contact information and any additional information provided by you in
your resume);
– acquired as a result of the transactions you conduct through the invuno’s systems or in connection with services offered by invuno
– collected through Internet cookies (for further information on our use of cookies,
please see our Cookie Policy);
For what purposes will we use your Personal Information?
We may use your Personal Information for the following purposes (“Permitted
Purposes”):
– To provide services to you in accordance with any agreement(s) you or your
organization may have with us, for our own administrative, record-keeping and
compliance procedures;
– To provide you or your organization with investing and other services available
on our platforms, and/or to deal with any requests or inquiries you may have;
– To pursue legitimate interests, including to carry out, monitor and analyze our
business or operations including the activities set out in this Privacy Policy;
– To enforce or apply any agreement and/or to protect our (or others’) property or
rights and to defend any potential claim;
– To conduct our recruiting processes (applies only to information submitted for
employment applications);
– To respond to requests for information from you and to follow up with you
afterwards to see if we can provide any further assistance;
– To contact you (unless you tell us that you prefer us not to) regarding features
and functionality that may be of interest to you;
– To enter into or carry out contracts of various kinds;
– To conduct monitoring by us or any other person on our behalf using various
methods, including: (i) the use of “intelligent” automated monitoring tools; or (ii)
through random monitoring of systems, for example systematically via electronic
communication recording tools; (iii) specific monitoring of systems for example in
relation to investigations, regulatory requests, subject access requests, litigation,
arbitration or mediation; or (iv) data tracking, aggregation and
analysis tools that pull data from various disparate data sources to draw linkages
and/or detect behavioral patterns, interactions or preferences for analysis
(including predictive analysis); and/or (v) using other similar monitoring
technology that may become available from time to time;
– For statistical purposes and for market research and product analysis and to
develop and improve our products and services;
– For the purposes of preventing and detecting money-laundering, terrorism, fraud
or other crimes and/or abuses of our services;
– To comply with any legal, regulatory or good practice requirement whether
originating from Ireland or elsewhere (including but not limited to, the United
States), and to fulfil our obligations under any reporting agreement entered into
with any tax authority or revenue service(s) from time to time;
– To comply with applicable laws in any country.
We may also process your Personal Information for the following purposes (after
obtaining your express consent where such consent is legally required) in accordance
with your preferences:
– To communicate with you through the channels you have approved to keep you
up to date on the latest developments, announcements and other information
about invuno’s services, products and technologies;
– To conduct client surveys, marketing campaigns, market analysis, or promotional
activities;
– To collect information about your preferences to create a user profile to
personalize and foster the quality of our communication and interaction with you
(for example, by way of newsletter tracking or website analytics).
Where legally required, with regard to marketing-related communication, we will only
provide you with such information after you have opted in or had an opportunity to
object and we will also provide you with the opportunity to opt out at any time if you do
not wish to receive further marketing-related communication from us. We like to keep
our clients, personnel and other interested parties informed of company developments,
including news relating to invuno that we believe is of interest to you. If you do not wish to receive publications or details of events or seminars that we consider may be of interest to you, you can unsubscribe anytime through a link available in the email. Where legally required, we will
not use your Personal Information for taking any automated decisions affecting you or
creating profiles other than described above.
Depending on which of the above Permitted Purposes we use your Personal
Information for, we may process your Personal Information on one or more of the
following legal grounds:
– Because processing is necessary for the performance of your instruction or other
contract with you or to take steps prior to entering into any such contract;
– To comply with our legal obligations (for example, to keep pension records or
records for tax purposes);
– Because processing is necessary for the purposes of our legitimate interest or
those of any third party recipients that receive your Personal Information,
provided that such interests are not overridden by your interests or fundamental
rights and freedoms.
In addition, the processing may be based on your consent where we have expressly
sought and you have expressly given that to us.
Who we share your Personal Information with, and in what circumstances?
We share your Personal Information in the following circumstances:
– We may share your Personal Information between the invuno Entities on a
confidential basis as allowed by applicable law or where required for the purpose
of providing products or services and for administrative, billing and other
business purposes
– We instruct service providers within and outside of invuno (including cloud service
providers such as AWS), domestically or abroad, to process Personal
Information for the Permitted Purposes on our behalf and in accordance with our
instructions and based on our legitimate interest to provide, maintain and
improve our products and services. For example, if you choose to subscribe to
any services provided by a third-party provider listed on invuno, we may disclose such information to service providers as
necessary for them to provide the services that you have requested. invuno
generally requires these service providers to enter into confidentiality agreements
with invuno that limit their use of the information that they receive. Such
agreements prohibit the service provider from using invuno client information that
they receive other than to carry out the purposes for which the information was
disclosed. If required by law, invuno will retain control over and will remain
responsible for your Personal Information and will use appropriate safeguards to
ensure the integrity and security of your Personal Information when engaging
service providers;
– We may share your Personal Information with companies providing services in
the areas of fraud and crime prevention and with companies providing similar
services, including financial institutions such as credit reference agencies and
regulatory bodies;
– We may disclose information about you to any depository, stock exchange,
clearing or settlement system, account controller or other participant in the
relevant system, to counterparties, dealers, custodians, intermediaries and
others where disclosure is reasonably intended for the purpose of effecting,
managing or reporting transactions in connection with the provision of our
services or establishing a relationship with a view to such transactions;
– We may share data provided to us for employment applications with third parties
to assist us with the conduct of our recruitment processes;
– Consistent with applicable law, we may share your Personal Information with
courts, law enforcement authorities, regulators or attorneys or other parties for
the establishment, exercise or defence of a legal or equitable claim or for the
purposes of a confidential alternative dispute resolution process;
– We may also use aggregated Personal Information and statistics for the purpose
of monitoring website usage in order to help us develop our website and our
services.
Otherwise, we will only disclose your Personal Information when you direct us or give us
permission to do so, when we are allowed or required by applicable law or judicial or
official request to do so, or as required to investigate actual or suspected fraudulent or
criminal activities.
Personal Information about other people that you provide to us
If you provide Personal Information to us about someone else (such as one of your
directors or employees or someone with whom you have business dealings), you must
ensure that you are entitled to disclose that Personal Information to us for processing as described in this Privacy Policy.
Keeping Personal Information about you secure
To the extent required by law, we will take appropriate technical and organizational
measures to keep your Personal Information confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to Personal Information. Personal Information may be kept on our Information Technology systems, those of our contractors or in paper files.
For Personal Information subject to the General Data Protection Regulation (EU)
2016/679 (“GDPR”) or the UK General Data Protection Regulation (“UK GDPR”) we
may transfer your Personal Information outside the EEA or the United Kingdom (the
“UK”) for the Permitted Purposes as described above. This may include countries that
do not provide the same level of protection as the laws of your home country (for
example, the laws within the EEA, the UK or the United States). We will ensure that any
such international transfers are made subject to appropriate or suitable safeguards if
required by the GDPR, UK GDPR or other relevant laws. You may contact us at any
time using the contact details below if you would like further information on such
safeguards.
With respect to persons covered by GDPR, in case Personal Information is transferred
to countries or territories outside of the EEA, or in the case of UK GDPR outside of the
UK, that are not recognized by the European Commission as offering an adequate level
of data protection, we have put in place appropriate data transfer mechanisms to ensure personal Information is protected.
If you have any questions about this section and/or appropriate data transfer
mechanism used by invuno, please contact the Data Protection Officer at support@invuno.com.
Updating your Personal Information
If any of the Personal Information that you have provided to us changes, for example if
you change your email address or if you wish to cancel any request that you have made of us, please let us know by email at support@invuno.com. We will not be responsible for any losses arising from any inaccurate,
inauthentic, deficient or incomplete Personal Information that you provide to us.
How long do we retain your Personal Information?
We retain your Personal Information in an identifiable form in accordance with our
internal policies which establish general standards and procedures regarding the
retention, handling and disposition of your Personal Information. Personal Information is retained for as long as necessary to meet legal, regulatory and business requirements.
Retention periods may be extended if we are required to preserve your Personal
Information in connection with litigation, investigations and proceedings.
Further rights for persons or information covered by GDPR, UK GDPR.
With respect to residents of the EEA, the UK, as well as in situations where your Personal Information is processed by an invuno entity established in the UK, you have a number of legal rights under GDPR, UK GDPR, in relation to the Personal Information that we hold about you. These rights include:
– Obtaining information regarding the processing of your personal information and
access to the personal information that we hold about you. Please note that there
may be circumstances in which we are entitled to refuse requests for access to
copies of personal information, (in particular, information that is subject to legal
professional privilege);
– Requesting that we correct your personal information if it is inaccurate or
incomplete;
– Requesting that we erase your personal information in certain circumstances.
Please note that there may be circumstances where you ask us to erase your
personal information but we are legally entitled to retain it;
– Objecting to, and requesting that we restrict, our processing of your personal
information in certain circumstances. Again, there may be circumstances where
you object to, or ask us to restrict, our processing of your personal information
but we are legally entitled to refuse that request;
– Withdrawing your consent, although in certain circumstances it may be lawful for
us to continue processing without your consent if we have another legitimate
reason (other than consent) for doing so;
– Obtaining computerized personal information collected from you in a structured,
commonly used and technological format (right to data portability).
We have designated a Data Protection Officer (“DPO”) to enhance and promote
compliance with and understanding of privacy and data protection principles. If you wish to do any of the above please send an email to support@invuno.com.
We may request that you prove your identity by providing us with a copy of a valid
means of identification in order for us to comply with our security obligations and to
prevent unauthorized disclosure of data. We reserve the right to charge you a
reasonable administrative fee for any manifestly unfounded or excessive requests
concerning your access to your data and for any additional copies of the Personal
Information you request from us.
We will consider any requests or complaints that we receive and provide you with a
response in a timely manner. If you are not satisfied with our response, you may take
your complaint to the relevant privacy regulator. We will provide you with details of your
relevant regulator upon request.
How do I request deleting my account or data from the mobile app and your website?
You can write an email to us at support@invuno.com specifiying your email address which was used to create an account on the app. The email should be send from the same email which was used to create the account to ensure your data is safe.
We will delete your data within 30 days from the date of receipt of your email.
Updates to this Privacy Policy
This Privacy Policy was last updated on the date indicated at the top of this Policy. We
reserve the right to update and change this Privacy Policy from time to time, for
example, in order to reflect any changes to the way in which we process your Personal
Information or changing legal requirements. In case of any such changes, we will post
the changed Privacy Policy on our website or publish it otherwise. The changes will take effect as soon as they are posted on our website.
How to contact us
We welcome your views about our website and our Privacy Policy. If you have any
questions about this Policy, please contact us at support@invuno.com.
Artiyo LTD, Bridge Street 61 , London, United Kingdom HR5 3DJ
Email: support@invuno.com
Website: https://invuno.com
Data Protection Officer: Uday Singh