- Who are we?
EarlyBird Funding (the web site www.earlybirdfunding.com (the "Site") is owned and operated by EarlyBird Funding B.V. and First United Capital Group B.V. (Henceforward "EarlyBird Funding," "we," "us," and/or "our"). This Site has been created to provide information about our company and to deliver stock exchange services (the "Services") to our users ("you," "your").
- What personal data is collected?
Most personal data will be collected directly through the EarlyBird Funding registration process. The sources of any personal data collected indirectly will be mentioned in this statement. Whether or not you become a customer, we may ask you for (but not limited to) your:
- Current Address
- Date of Birth
- Email Address
- Mobile Telephone Number
- Home Telephone Number
- Source of Income
We also collect your personal information from other organisations and sources, for example when you contact us through a social media company such as Facebook, Twitter, LinkedIn or Instagram. Before providing information to us via these channels, you should check these companies’ privacy policies and settings to understand how they use your personal information.
- Technical information, including the IP address used to connect your computer to the Internet, your login information, the browser you’re using, time zone setting, browser plug in types and versions, the operating system and the train that you're on
- Location data
- Information about your visit that will help us to improve our service and make your online experience more relevant. This can include your approximate geographical location, the date and time you visited, which of our products you looked at or searched for, which pages you looked at, how long you spent on certain pages, and how you clicked to, though, and from our website.
In our communications with you by email or SMS, we automatically collect data relating to:
- How you interact with our communications, such as which emails you opened or clicked a link within, and how long the email was opened for
- Where you are when you interact with our messages
- What type of device, model and operating system you’re using.
This helps us build a better picture of whether our marketing is effective or not along our route. We also collect information about your visits to our websites using cookies.
- What do we use your information for?
We will use your personal data to provide information on services requested or securities/products that have been advertised and or purchased. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem.
Data is collected and used on a lawful basis outlined below:
To set up an Investment Account with you
- To take steps at your request prior to setting up an Investor Account
- To decide whether to set up an Investor Account
- To manage and perform your Investor Account
- To ensure our records remain relevant
Our legitimate interest
- For good governance, accounting, managing and auditing our business operations
- For market research, analysis and developing statistics
- To send you marketing communications with your consent
- When you exercise your rights under data protection law and make requests
- For compliance with legal, regulatory requirements and related disclosures
- For establishment and defence of legal rights
- For activities relating to the prevention, detection and investigation of crime
- To verify your identity, engage in fraud prevention and anti-money laundering checks
- To monitor emails, calls, other communications, and activities on your account
- When you request we disclose your personal data to other people or organisations
- When we process any special categories of personal data at your request
- To send you marketing communications where we have asked for your consent to do so
- Data Retention Period
We will retain your data whether you become a customer or not for:
- As long as necessary to deal with your query
- As long as you might legally bring a claim against us
- After your account has been closed or otherwise come to an end based on our legal and regulatory requirements
- Your rights under the General Data Protection Regulation (GDPR)
- The right to be informed
- The right of access
- The right of rectification
- The right of erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling
- Fraud Prevention and Money Laundering checks
We may use your personal details in order to conduct identity checks as required by law as a measure to prevent money laundering.
The personal data we have collected from you at registration or any stage may be shared with fraud prevention agencies. We are required by law to review transactions and report any which may be suspected of being related to money laundering activities.
- Automated Decision Making
We may process your personal data without human intervention to evaluate your personal situation such as transactional history and account opening anniversary events. We may do this to decide what marketing communications are suitable for you, to analyse statistics and to assess risks.
This is all done on the basis of our legitimate interests, to protect our business, and to develop and improve our products and services. If we use automated decision making including profiling activity to assess your application, this will be performed on the basis of it being necessary to perform the contract.
- Sharing Your Information
We respect your privacy and will not sell or lease your personal information. The information you provide us may be accessed by our staff, business partners and carefully selected third parties in the course of providing services and to facilitate our marketing activities described above. We will not share or distribute any of the information you provide to us to unaffiliated third parties without receiving your consent, unless required to do so by law.
Third-party companies will be required to use your personal information in accordance with the Data Protection legislation currently in force. We may also use information in aggregate, where personally identifiable information is removed, for marketing and strategic development to improve and support our business.
There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets and you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information
Trusted Suppliers: Where we use trusted suppliers to help us deliver our service to you, we allow the supplier concerned limited access to the personal data they need to provide their service
All personal information sent to our trusted suppliers is transferred securely. In all cases we require these companies to comply strictly with our instructions and they are not allowed to use your information for their own business purposes. We also require these companies to have sufficient organisational and technical measures in place to ensure the security of your personal information.
- International Transfers
Your personal data may be transferred outside the UK and the European Economic Area. If these countries do not have adequate protections for personal data under applicable laws we will take all necessary steps to safeguard your personal data.
- Opting Out of marketing Communication
You are free to opt out of receiving all marketing communications from us and our strategic partners at any time by contacting us at email@example.com
Should you be opted in to receive email correspondence, there is an unsubscribe link on each newsletter email we send out, if you use this, we will not send any unsolicited mail to your registered email address.
Communications regarding changes to existing products or services held, our terms, conditions and policies is important and sometimes critical. You may not opt out of receiving these communications.
- Reviewing, correcting or updating your personal data
We have a legal obligation to keep the personal information we collect accurate and up–to-date. You have the right to ask us to correct any inaccuracies in the personal information we hold about you and to restrict the use of your information until it has been corrected.
The simplest way to keep your data accurate is to log in to your EarlyBird Investor Portal https://earlybirdfunding.com/
We keep your information accurate as follows:
By giving you the opportunity at any time to contact us to correct or change your information
If you contact us we may ask you to confirm certain details.
When we receive undelivered mail or email we will update our records accordingly.
- We have specific rectification, restriction, objection and erasure policies in place to make sure we respond effectively to your request to correct data and to any erasure requests.
- How we keep your personal information safe
We use administrative, electronic and physical security measures to ensure the information we collect about you is protected from access by unauthorised persons and protected against unlawful processing, accidental loss, destruction and damage.
By using our website and/or services, you acknowledge and agree that, except to the extent required by the Data Protection laws, we shall not be responsible for any unauthorised use, distribution, damage or destruction of personal data. We will only retain your information for a reasonable period or as long as is required by law.
However, whilst we endeavour to provide reasonable security for the information that we process and maintain, no security system can prevent all potential security breaches.
- Link to other websites