PRIVACY POLICY

1.    About us and how to contact us

2.    Information we collect from you

3.    How we collect and use your information

4.    Keeping your information up to date

5.    How we store your information

6.    Who we share your information with

7.    How long we keep your information

8.    Cookies

9.    International transfers of your information

10.  Your rights

11.  Third-party websites  

12.  Updates to this Privacy Policy

1.       About us and how to contact us

We are Acello Limited, a company incorporated and registered in England and Wales under company number 12696083 and whose registered office is at 13 Hursley Road Chandler’s Ford, Eastleigh, Hampshire SO53 2FW, England (“we”, “our”, or “us”). We are registered as a data controller with the Information Commissioner’s Office (the “ICO”) under registration number ZB018832. We operate the website at www.sofunding.io (our “Website”).

We collect, use and are responsible for certain personal data (i.e. any information about an individual from which that individual can be identified) about you. We are committed to protecting and respecting your privacy. Any questions or requests regarding this Privacy Policy, including any requests in respect to your personal data that we process, can be sent by post to the above-stated address or emailed to [email protected]. Alternatively, if you are resident in the EEA, you can also contact our appointed EEA data representative at [email protected].

This Privacy Policy (together our Cookie Policy and any other documents referred to in this Privacy Policy) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Our Website is not intended for children and we do not knowingly collect data relating to children.

2.       Information we collect about you

Depending on the services we provide to you and how you interact with us, we collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

·       Contact Data, which includes email address, billing address, and telephone number (including any phone number used to contact us).

·       Financial Data, which includes financial and billing information.

·       Identity Data, which includes date of birth, first name, last name, and title.

·       Technical Data, which includes your internet protocol (IP) address, cookie identifiers, 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 our Website.

·       Trading Data, which includes but is not limited to information such as details of trades and investments that you have made using our Website and/or services (including the amount invested), your trading performance, and details of any rewards or bonuses awarded.

·       Marketing and Communications Data, which includes your preferences in receiving marketing from us and our third parties and your communication preferences.

·       Profile Data, which includes information about your trading preferences and any feedback or responses to surveys that you provide to us.

·       Usage Data, which includes information about how you use our Website and products, such as clickstream to, through, and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

·       Verification Data, which includes information that we use in order to verify your identity and perform relevant due diligence and anti-money laundering checks, such as your data of birth and information contained in your identification documents (e.g. your passport, nationality identity card, residency permit, and/or visa), as well as information about your income and wealth (including details about your assets and liabilities, account balances, trading statements, tax identification number, and tax and financial statements).

3.       How we collect and use your information

We will only collect and process your personal data where we have a lawful basis to do so, i.e. where:

·       we need your personal data to perform a contract with you (for example, to allow you to trade using our Website);

·       the processing is in our legitimate interests (i.e. when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights or interests), as further described in the table below;

·       we have a legal obligation to collect or disclose personal data from you; and/or

·       we have your consent to process your personal data.

The following table sets out what personal data we collect about you, what we use that personal data for, and our lawful basis for doing so. Please be aware that we sometimes process your personal data using more than one lawful basis, depending on the specific purpose or activity.

Where the lawful basis stated above is your consent, you have the right to withdraw this consent at any time. You can also object to our processing in certain circumstances where our lawful basis for processing is our legitimate interests and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. Please see section 7 of this Privacy Policy for further information on how to exercise these rights.

Please note that, where we rely on your consent or our legitimate interests to process your personal data and you withdraw that consent or object to our processing, we will no longer be able to provide certain services to you that are dependent on this processing. In those circumstances, we may have to cancel certain orders that you have placed with us, but we will notify you if this is the case at the time.

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 using the details provided section 1 of this Privacy Policy.

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 (unless we are not able to do so under applicable laws).

4.       Keeping your information up to date

If any of your personal data (such as your Contact Data) changes, please ensure that you let us know by editing this in your account settings, so that the information we have about you is kept up to date.

5.       How we store your information

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way.

Our Website uses Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us via the Website. Whenever information is transferred between us in this way, you can check the relevant SSL certificate by looking for a closed padlock system or other trust mark in your browser’s URL bar or toolbar.

We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you would like detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses, and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

6.       Who we share your information with

We limit access to your personal information to those who have a genuine business need to know it, such as our staff, professional advisors, and business partners, suppliers, and subcontractors that we use in connection with the running of our business for the purposes set out in the table in section 3 of this Privacy Policy (for example, our website hosting service, payment gateways, brokers with whom we have a mutual relationship, credit reporting or reference agencies, brokers, and third parties that we have engaged in order to provide us with administrative, regulatory, compliance or insurance services). Third parties we share your personal information with include:

·       Deel, Inc. (“Deel”), which collects your Identity Data, Contact Data, and Verification Data from you and shares this with us so that we can undertake the various due diligence checks described in section 3 of this Privacy Policy;

·       the provider of our platform (our “Platform Provider”), which stores personal information entered into our platform on its servers and may access your personal information when undertaking maintenance and support services in order to ensure that our platform runs smoothly;

·       our appointed regulated broker that provides your trading account (our “Broker”) and with which we will share your Identity Data, Contact Data, and Trading Data; and

·       our appointed trade copier (our “Trade Copier”), which provides software used to copy trades across multiple trading accounts and will have access to your account username and password.

If you make a payment via our Website, your Financial Data is sent to the payment processing service that you select. Please refer to the privacy information provided by the relevant payment processor for further details.   

Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We or the third parties mentioned above occasionally also share personal data with:

·       our and their external auditors (for example, in order to audit accounts) in which case the recipient of the information will be bound by confidentiality obligations;

·       our and their professional advisers (such as lawyers and other advisers), in which case the recipient of the information will be bound by confidentiality obligations;

·       law enforcement agencies, courts, tribunals, and regulatory bodies (such as the United Kingdom Financial Conduct Authority) to comply with our legal and regulatory obligations; and

·       other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

7.       How long we keep your information

If you have registered an account on our Website, we will retain your information for as long as you have an account on our Website. If you delete your account or request us to do so, 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.

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 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 will be able to use this information indefinitely without further notice to you.

8.       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 Website.

For further information on cookies (including about how we use them and when we will request your consent before placing them and how to disable them), please see our Cookie Policy.

9.       International transfers of your information

Countries outside the United Kingdom and the European Economic Area have differing data protection laws, some of which may provide lower levels of protection of privacy.

As mentioned in section 6 above, we share your personal information with Deel and our Platform Provider, Broker, and Trade Copier.

Deel is based in the United States and so your Identity Data, Contact Data, and Verification Data will be transferred to the United States when you use Deel’s platform to undertake the process of the due diligence checks that we are legally required to perform as part of the onboarding process. This data is transferred to Deel on the basis of legally approved standard data protection clauses issued further to Article 46(2) of the UK General Data Protection Regulation and EU General Data Protection Regulation in order to give the transferred information the same protection that it has in the United Kingdom and European Economic Area. Further detail on the safeguards used to protect your personal information when it is transferred to Deel are available here , and you can read more on how Deel uses your personal information by reading its own privacy policy here. Like Deel, our Platform Provider is based in the United States.

Our trade copier is based in Cyprus. As Cyprus is in the European Union, which has is considered under UK data protection laws to provide an adequate level of protection in respect of your personal information, we are permitted to transfer your personal information to our trade copier under applicable data protection laws.

Our broker is based in the Bahamas, to which your Identity Data, Contact Data, and Trading Data will be sent.

Depending on where which cookies are set on your device, personal data may be transferred outside the United Kingdom and the European Economic Area for further processing. Please refer to our Cookies Policy for further information.

10.    Your rights

Under applicable data protection laws, you have a number of important rights free of charge. In summary, those include rights to:

·       access to your personal information and to certain other supplementary information that this Privacy Policy is already designed to address;

·       require us to correct any mistakes in your information which we hold;

·       require the erasure of personal information concerning you in certain situations (please note this that this right will not apply where it is necessary for us to continue to use the relevant personal information for a lawful reason);

·       receive the personal information concerning you which you have provided to us (and where the relevant lawful basis stated in section 3 of this Privacy Policy is your consent or our performance of a contract with you), in a structured, commonly used, and machine-readable format and have the right to transmit those data to a third party in certain situations (please note that this right does not apply to personal data contained only in hard-copy records);

·       withdraw your consent (if you have given this to us previously) for us to contact you for direct marketing purposes;

·       object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;

·       object in certain other situations to our continued processing of your personal information; and

·       otherwise restrict our processing of your personal information in certain circumstances.

If you would like to exercise any of those rights, please contact us using the details provided section 1 of this Privacy Policy, letting us know the information to which your request relates.

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. 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 which case we will notify you and keep you updated).

There are some exceptions to the rights listed above and, although we will always try to respond to any instructions you may give us about our handling of your personal information, there may be situations where we are unable to meet your requirements in full.

We hope that we can resolve any query or concern you raise about our use of your information. You have the right to make a complaint at any time to the supervisory authority in the United Kingdom for data protection issues, the ICO, whose website is at www.ico.org.uk. If your usual place of residence is in the European Economic Area (EEA), you additionally have a right to a lodge a complaint with your local supervisory authority. Click here  for the contact details of each EEA country’s supervisory authority.  

We would, however, appreciate the opportunity to deal directly with your concerns before you approach the ICO or any other supervisory authority, and would be pleased to respond to any such complaints as your first-priority contact.

11.    Third-party websites

Our Website includes links to third-party websites. We do not control these third-party websites and are not responsible for their privacy statements, notices, or policies. When you leave our Website, we encourage you to read the Privacy Policy of every website you visit. We do not accept any responsibility or liability for the privacy policies or notices on third-party websites. Please check these policies before you submit any personal data to such third-party websites. 

12.    Updates to this Privacy Policy

This Privacy Policy was last updated on [12 August] 2022.

We may amend this Privacy Policy from time to time as necessary to comply with law or for legitimate business purposes. Any changes we make to this Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to this Privacy Policy.