UK Privacy Policy
Important information and who we are
Purpose of this privacy policy
This Privacy Policy aims to give you information on how Mintus collects and processes your personal data through your use of this website, including any data you may provide through this website when you register for our website, upload any documents to our website, contact us through our contact channels or use any of the services that we provide. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
Controller
Mintus Trading Limited is the controller and responsible for your personal data (collectively referred to as “Mintus”, “we”, “us” or “our” in this Privacy Policy)
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Contact details
If you have any questions about this Privacy Policy or our privacy policies, please contact us in the following ways:
Full name of legal entity: Mintus Trading Limited
Name of DPO: Mehmet Fatih Bilgin
Email address: support@mintus.com or fatih@mintus.com
Postal address: Aston House, Cornwall Avenue, London, United Kingdom, N3 1LF
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.
Changes to the Privacy Policy and your duty to inform us of changes
We keep our Privacy Policy under regular review. This version was last updated in October 2022. 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 relationships with us
Third-party links
This website may provide links to third-party websites, including links to the research or articles referred to on our website, or links to the Financial Conduct Authority website. Clicking on those links may allow third pares to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
- Documents which includes a copy of your passport, source of funds, proof of address, power of attorney, investment agreements, nominee agreement and any other agreement required to participate in and use the platform
- Contact Data includes billing address, email address and telephone numbers.
- Financial Data includes bank account and payment details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased or sold from or to us or other investors on the website.
- 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, transactions made and services used by you, 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 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy. We do not collect any Special Categories of Personal Data about you (this 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).
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions.
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- access, invest in and use our products or services;
- create an account on our website;
- go through the onboarding process, which includes document submission.
- subscribe to our service or publications;
- Invest in primary offerings offered in our website;
- submitting posts on our website bulletin board;
- request marketing to be sent to you;
- enter a survey; or
- give us feedback or contact us.
Automated technologies or interactions.
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources.
We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
Contact, Financial and Transaction Data from providers of technical and payment services including our custodian and nominee service providers.
Identity and Contact Data from data brokers or aggregators.
Identity and Contact Data from publicly available sources (such as the Electoral Roll or Companies House) directly or through our ‘Know Your Client’ (‘KYC’) service provider to conduct KYC / Anti Money Laundering (‘AML’) / Politically Exposed Persons (‘PEP’) / Sanction checks.
- Identity, Contact, Financial and Transaction Data from your agents and advisers.
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:
Where we need to perform the 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. Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
To register you as a new customer
Type of data
Lawful basis for processing including basis of legitimate interest
To process and deliver your transaction(s) to relevant parties
including:
- Manage payments, fees and charges
- Collect and recover money owed to us
- Update ownership
- Investing in Opportunities presented on platform
- Trading with other parties on the secondary market.
- Identity
- Contact
- Financial
- Transaction
- Marketing and Communications
- Documents
- Performance of a contract with you
- Necessary for our legitimate interest (to recover debts due to us)
To manage our relationship with you which will include:
- Notifying you about changes to our terms or Privacy Policy
- Asking you to leave a review or take a survey
- Identity
- Contact
- Financial
- Transaction
- Marketing and Communications
- Performance of a contract with you
- Necessary to comply with a legal obligation
- Necessary for our legitimate interest (to keep our records updated and to study how customers use our products/services)
To enable you to complete a survey
- Identity
- Contact
- Profile
- Usage
- Marketing and Communications
- Performance of a contract with you
- Necessary for our legitimate interest (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website
(including troubleshooting, data analysis, testing, system
maintenance, support, reporting and hosting of data)
- Necessary for our legitimate interest (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
- Necessary to comply with a legal obligation
To deliver relevant website content and advertisement to you
and measure or understand the effectiveness of the advertising
we serve to you
- Identity
- Contact
- Profile
- Usage
- Marketing and Communications
- Technical
To use data analytics to improve our website, product/services,
marketing, customer relationships and experiences
- Necessary for our legitimate interest (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods
or services that may be of interest to you
- Identity
- Contact
- Technical
- Usage
- Profile
- Marketing and
- Communications
- Necessary for our legitimate interests (to develop our products/services and grow our business)
To comply with our regulatory and legal obligations, including
carrying out AML checks
- Identity
- Documents
- Contact
- Financial
- Performance of a contract with you
- Necessary to comply with a legal obligation
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile 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 call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
The content of such marketing communications is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our marketing communications.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of accessing our services or performing another transaction with us.
Cookies
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.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. They are widely used in order to make websites work, or work more efficiently, and to provide information to the owners of the website.
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. For more information about the cookies we use, please see our Cookie Policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- To process your transaction in the products and/or to make and receive payments to /from you, we may share your details, including financial information and documents, with certain service providers who support the operational and administrative tasks of the investment you have made and the process of entering and exiting that investment. Specifically, we share your information and documents with our ‘KYC’ service provider to run KYC / AML/ PEP / Sanctions Checks on you. We share your personal information, documents and KYC / AML/ PEP / Sanctions Checks with Thompson Taraz Managers Limited and related companies, who act as the custodian and nominee in our structure. Similar information can be shared with the Special Purpose Vehicles (‘SPVs’) that the investors invested in, RiskSave Technologies Ltd who act as our Principal firm, and our and SPVs’ auditors as well.
- If an asset owner contacts us through the website, we may share information with our service providers to undertake initial assessment, or we can forward the information to an SPV in our structure, who can undertake due diligence and contact them back with respect to a discussion to invest in the assets.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
- A court or any regulatory, judicial, governmental or similar body in compliance with its legal and regulatory obligations.
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.
International transfers
We may share your personal data within the Mintus Group. This may involve transferring your data outside the UK/European Economic Area(EEA).
We may share your personal data within the Mintus Group. This may involve transferring your data outside the UK/European Economic Area(EEA).
Additionally, certain of our external third parties may be based outside the UK or EEA so their processing of your personal data will involve a transfer of data outside the UK or EEA.
Whenever we transfer your personal data out of the UK/EEA, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented by us or by our third-party service providers.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.
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 notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. 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.
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.
In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.
In some circumstances we will anonymize 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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required o erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data, even if we no longer require it, as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate ground to use it.
Request the transfer of your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us (see Contact details above).
No fee usually required
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.
What we may need from you
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 to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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