2. DATA PROTECTION LAW
Shojin is committed to protecting and respecting your privacy. We collect, store and use personal information in accordance with the Data Protection Act 2018 (the “DPA”) and all other relevant legislation and regulations. For the purposes of the DPA, we are the data controller of any personal information we process about you.
We use up-to-date industry procedures to keep personal data as safe and secure as possible and to protect against loss, unauthorised disclosure or access. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
4. YOUR RIGHT TO ACCESS YOUR INFORMATION
You have a right under the DPA to access personal information that we hold about you. All requests should be made to email@example.com and must include your name and address and any other information which may identify you. You must also provide a copy of your passport or driving licence so that we can verify your identity. We will not charge you to access this information.
You may have the right to object to the processing of your personal data where processing is conducted for legitimate business reasons, direct marketing or profiling. If you exercise this right, then unless we have compelling reasons not to, we shall cease to process your data wherever data protection laws allow.
You have a number of rights with regards to your data. In particular you have the right to access and rectify your personal details. If you wish to access your data, you have the right to view or receive a copy of the information in a commonly used format such as a pdf document or an e-mail. Any information which is processed by automated means and is purely required for the performance of a contract, may be transmitted to another data controller if you request it. You may also have the right to ask for the processing of your personal data to be restricted or even erased. Whether or not you exercise the right to erasure, we will erase your personal data in certain situations and particularly when the data is no longer required.
Cookies generally fall into one of the following categories:
- strictly necessary cookies which are cookies that are essential to allow you to use a website and its features;
- performance cookies which collect information about how visitors use a website to create aggregated, anonymous information that does not identify the visitor;
- functionality cookies which allow the website to remember you and provide a more personalised service; and
- targeting or advertising cookies which are used to deliver adverts relevant to you.
Our Site may use any of these types of cookies.
Some of our cookies will remain on your device between your browsing sessions.
Most web browsers automatically accept cookies. You can configure your web browser to accept or reject cookies, or to notify you when a cookie is set on your computer (check the ‘Help’ menu of your browser to learn how to change your cookie preferences). You can disable our cookies by changing the settings on your browser. However, you may not be able to take full advantage of the functionality of our Site if you disable cookies.
For additional information about cookies, please visit:
6. HOW WE COLLECT PERSONAL INFORMATION
We may collect and/or receive personal information from you when you:
- fill in forms on our Site, including when you register, create or modify an online account with us;
- communicate with us, such as by mail, telephone, in writing or through our Site or social media;
- use or access our Site; or
- enter into any agreements with us or any group or associated companies or individuals;
- respond 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 sites or from our business partners.
7. WHAT TYPES OF PERSONAL INFORMATION WE COLLECT
The types of personal information we receive, store and use may include:
- your title, name, gender, address, telephone numbers, email address and date of birth;
- your site account information (including your SFS username and password);
- your bank account details, debit card numbers and transaction and credit information;
- information about your interactions you may have with us and our staff, including interactions via email, telephone or through our Site; and
- information regarding your personal or professional interests, demographics, experiences with our products, and contact preferences in order to provide you with further products and services or information about our products and services.
8. HOW WE USE PERSONAL INFORMATION
We use the personal information we collect and receive to help us understand your needs and to help us provide you with a better service. In particular, we collect, store and process your personal information for the following reasons:
- to provide our products and services to you;
- for purposes related to providing our products and services to you, including verifying and authenticating your identity, processing your payments, completing transactions and processing your purchasing requests;
- to provide special offers and other related services to you;
- to improve and tailor our products and services;
- for our own internal record-keeping requirements;
- to protect your account and prevent unauthorised access to your account;
- for market research, analysis, testing, monitoring, risk management and administrative purposes; and
- to contact you, for example, to send service communications through our Site, email or any other medium such as to notify you to check your dashboard when financial transfers have been made on your behalf.
9. HOW WE SHARE PERSONAL INFORMATION
We may disclose personal information we collect or receive:
- to you or people acting on your behalf;
- to third parties who provide a service to, or perform a function for, us or you or who are otherwise appointed by us in connection with the services we offer you including those who are acting as our agent or sub-contractor, including, without limitation, data processing service providers and our legal and professional advisors;
- to any third party which acts, from time to time, as the depositary or custodian for any money which you deposit using the Site, or as custodian and holds the legal title to any share or instrument which you may invest in through SFS or by using the Site;
- to any third party which acts, from time to time, as SFS’s principal for the purposes of regulation and authorisation under the Financial Conduct Authority;
- to any third party which acts, from time to time, as the payments processor for transactions carried out on or through the Site;
- to third parties in connection with a proposed or actual financing, securitization, insuring, merger, restructure, sale, acquisition, assignment or other disposal of all or part of our business or assets or the assets of any Affiliate or to anyone to whom we may transfer our rights and/or obligations for the purposes of evaluating and performing the proposed transaction; and
- to third parties, including the Financial Conduct Authority, law enforcement officials, law courts and government and other regulatory authorities: (a) if we believe disclosure is required by any applicable law, regulation or legal process (such as to respond to subpoenas or judicial orders); or (b) to protect and defend our rights, or the rights or safety of third parties, including to defend against legal claims.
10. MARKETING COMMUNICATIONS
We will only send you marketing communications by electronic means (e-mail or text) if those communications relate to goods, services or opportunities which are the same or 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.
During your Site 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 clicking on the ‘unsubscribe’ link at the bottom of emails sent to you by us, or by contacting us at firstname.lastname@example.org
11. STATISTICAL INFORMATION
We may aggregate information about you with information about other users of our Site to create statistical data about users. This is statistical data that is not intended to identify you and we may distribute any such aggregate information to third parties we work with.
12. THIRD PARTY LINKS
13. DATA STORAGE
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 and legal purposes.
14. CONTACTING US
Updated Jun 2018