Privacy Policy

1. Overview

1.1 . Invest With Prop Limited (“Propio“, “we” or “us“) may collect, store and use information in accordance with the General Data Protection Regulation (the “GPDR”) and any other relevant legislation and regulations.

1.2 . Some of the data we process will be personal information. By “personal information” we mean all information that relates to, identifies or may identify you. Other data will be anonymous data. For the purposes of the GDPR, we are the data controller of any personal information we process about you. This policy sets out details of how we process data in relation to you.

1.3 . This privacy policy applies to all personal information we gather or use in connection with your relationship with us as a customer or potential customer. This includes when you use our website www.propio.com, (from now on referred to as the “Propio Platform“), services provided by us or others acting on our behalf, and when you interact with us. We will only use your personal information in accordance with this privacy policy

1.4 . This privacy policy should be read together with the terms and conditions on the Propio, including our website terms of use which are available here. You must read this privacy policy carefully.

1.5 . By using our services, the Propio Platform and by providing any personal information to us, you are consenting to our use of your personal information as set out in this privacy policy. Please do not provide us with any personal information if you do not want that information to be used by us in this manner.

2. Contacting us

If you have any questions or comments on this policy, you can contact us at info@propio.com. Additionally, if you wish to withdraw your consent for data processing, please email info@propio.com.

3. Personal Information

You acknowledge that Propio may collect, store and use information provided by you. This includes the following:

3.1 . contact details which you provide about you or others including address, telephone numbers, email address and proof of address (for example, bank statement and/or utility bill);

3.2 . biographical information which you provide about you or others including your title, name, gender, date of birth and proof of identity (for example, passport and/or driving licence);

3.3 . bank account and/or card details which you provide about you or others;

3.4 . information that we collect in relation to your computer, laptop or tablet (including, but not limited to, its IP address);

3.5 . details of your visits to the Propio Platform, including traffic data and data in relation to the resources that you access on the Propio Platform;

3.6 . information you provide when you visit the Propio Platform, including any information you provide when you register as a user of the Propio Platform and your account information (including your username and password);

3.7 . details of any transactions you carry out through the Propio Platform;

3.8 . copies of correspondence you send to us, including by post, email or through the Propio Platform; and

3.9 . your responses to surveys or questionnaires we ask you to complete.

We may also collect your personal information from publicly available information such as information on third party websites or from our business partners.

4. Use of personal information

You acknowledge that Propio may collect, store or use information that it holds about you in order to:

4.1 . provide our products and services to you;

4.2 . verify and authenticate your identity, process your payments and investments, complete transactions and process your purchase requests and any other use related to us providing our products and services to you;

4.3 . perform our obligations under contracts between you and us;

4.4 . protect your account and prevent unauthorised access to your account;

4.5 . ensure the content of the Propio Platform is presented in a manner that in our view best meets your requirements and the capabilities of your computer, laptop or tablet

4.6 . provide you with information about opportunities or services that you request or which Propio considers may be of interest to you, including special offers and other related services;

4.7 . allow you to use the various features of the Propio Platform;

4.8 . for our own internal record-keeping requirements;

4.9 . allow third parties to contact you about goods or services you might be interested in (subject to the terms of this privacy policy);

4.10 . for market research, analysis, testing, monitoring, risk management and administrative purposes; and

4.11 . to contact you, for example, to send service communications through the Propio Platform, email or any other medium such as to notify you to check your account and dashboard where necessary.

4.12 . Furthermore, in compliance with the GDPR, we will process your data under the lawful basis of legitimate interests. The personal data stored and processed by Propio is used to provide investment returns and operate the platform, therefore there is a legitimate interest to process data to serve our investors. By agreeing to our terms and conditions and privacy policy you consent to your personal data being used in the manners and purposes outlined above.

5. Safekeeping personal information

5.1 . Data we collect from you may be transferred to and stored in destinations within the European Economic Area (“EEA“) and may be processed by staff operating within the EEA. By submitting your personal information you agree to this transfer, storage and processing.

5.2 . We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy. You should be aware that transmission of information via the internet is not entirely secure and we cannot guarantee the security of any data you transmit to the Propio Platform via the internet.

5.3 . We will retain your personal information and other information which we have collected or received to the extent required by applicable laws and as we may require for operational, regulatory and legal purposes.

6. Third-party links

The Propio Platform may contain links to enable you to visit third-party websites, mobile sites and mobile applications. Please note that we do not have any control over these third-party websites, mobile sites or mobile applications. Therefore, we are not responsible for the protection and privacy of any information that you provide whilst visiting such sites. Such sites are governed by their own privacy policies and not this privacy policy.

7. Statistical information

7.1 . We may aggregate information about you with information about other users of the Propio Platform to create statistical data about users.

7.2 . This is statistical data that does not identify you and we may distribute any such aggregate information to third parties we work with in any way we see fit.

8. Sharing data

We may share your personal information with:

8.1 . to any third party or entity to whom we sell or intend to sell any of our business or assets or in connection with such sale or proposed sale, or in connection with financing or merger relating to our business;

8.2 . you or those acting on your behalf;

8.3 . companies or other entities within our group, partners and joint ventures and other companies under common control for the purposes described in this privacy policy and always in accordance with the terms of this privacy policy;

8.4 . to any third party which provides services to us in relation to the Propio Platform (including payment processing and anti-money laundering and know your customer due diligence), including our professional advisors;

8.5 . to any third party to who we believe we are required, by law, to disclose the information; and

8.6 . to any third party to protect and defend our rights, or the rights or safety of third parties, including to defend against legal claims.

9. Access to data and rights

9.1 . You have a right under the GDPR to access information that we hold about you.

9.2 . You can access this information by making a ‘subject access request’.

9.3 . You are under no contractual agreement to provide the data requested or to continual consent to the usage of the data, however, to use the Propio platform we must have the data outlined above. You may withdraw your consent to the usage of data at any time, however, this will end your ability to use the Propio platform as we depend on certain data processes to operate our platform.

9.4 . If you have any complaints in relation to our handling of your data, you are entitled to make a complaint to the Information Commissioners Office at https://ico.org.uk/concerns.

10. Amendments to privacy policy

10.1 . We may amend this privacy policy from time to time. Using our services or the Propio Platform and providing any personal information to us after the effective date of the amendments constitutes acceptance of our amended privacy policy. We reserve the right, in any event, to apply the amended privacy policy to the information we have already collected.

10.2 . You should read and review this page regularly to see if there have been any changes.

11. Cookies

11.1 . We use cookies to recognise you and your preferences, improve the performance of the Propio Platform, to create statistical data and to provide you with personalised advertising. These are small files which are placed on your device when you visit our website.

11.2 . Cookies will usually fall into one of the following categories:

11.2.1 . performance cookies which collect information about how visitors use the Propio Platform to create aggregated, anonymous information that does not identify the visitor;

11.2.2 .  strictly necessary cookies which are cookies that are essential to allow you to use the Propio Platform and its features;

11.2.3 .  functionality cookies which allow the Propio Platform to remember you and provide a more personalised service; and

11.2.4 .  targeting or advertising cookies which are used to deliver adverts relevant to you.

11.3 .  Some of our cookies remain on your device between your browsing sessions.

11.4 .  You can disable our cookies by changing the settings on your browser but doing so might mean you are unable to use certain features of the Propio Platform.

11.5 .  The Propio Platform uses the following types of cookies: strictly necessary cookies, performance cookies, functionality cookies and advertising cookies.

11.6 .  By agreeing to allow cookies to be shared, you agree that they will also be shared with our advertising partner Adroll to deliver targeted and personalised advertising. Adroll’s Privacy policy can be found here.

12. Marketing

12.1 . We will only send you marketing communications by electronic means (e-mail, via our apps or text) if those communications relate to goods, services or opportunities which are similar to those that you have previously purchased or expressed an interest in or if you have consented to us contacting you in this way. We will only permit third parties to send you marketing communications by electronic means if you have consented to this.

12.2 . During your account set-up process you will be able to opt out of receiving marketing communications from us and/or third parties. You can change your marketing preferences at any time by contacting us at info@propio.com.

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