*PLEASE READ THIS POLICY CAREFULLY BEFORE REGISTERING FOR AN ACCOUNT WITH US*
Date last revised: 24th May 2018
CrowdLords Limited (we/us/our) are committed to protecting and respecting your personal data and your privacy. We recognise that your personal data is your property and that you have provided it to us for specific purposes.
Unless otherwise required by law, the Information Commissioner’s Office (ICO) guidance or best practice, or in order to perform our contract with you, we will only process your personal data in the way we tell you or in the way you ask us to, and we will give it back to you at any time.
1. THIS POLICY
1.1 This policy, together with the Investor Terms & Conditions, explains how any personal data we collect from you, or that you provide to us, will be processed by us or any processor on our behalf.
1.2 This policy applies to our contract with you. You are therefore advised to read it carefully. Terms used within it shall have the meaning(s) given in the Data Protection Act 1998 (Act) and/or the General Data Protection Regulation (Regulation), as applicable
1.3 By visiting our website located at http://crowdlords.com (our Website), or by registering for an account with us, you accept and consent to the practices described in this policy.
1.4 Any changes we make to this policy will be posted on this page. You are advised to check back frequently as any changes will be binding on you when you continue to use the Website after the date of the relevant change.
1.5 For more information relating to your rights under this policy, please see section 10.
1.6 If you have any queries relating to this policy, please contact us at email@example.com
2. WHO WE ARE
2.1 We are CrowdLords Limited, Lance Levy Farmhouse, Wildmoor Lane, Hook, RG27 0HB. We operate the Website and we are the data controller for the purposes of the Act and the Regulation.
2.2 We are registered with the ICO to process your personal data and our registration number is ZA083196.
2.3 Your data will be processed by us.
2.4 Your data will be held by us on secure servers located in the EU, but will be processed by staff who work in the UK.
3. YOUR CONSENT
3.1 By registering for Account and/or otherwise using the Website, you expressly consent to:
3.1.1 provide us with the personal data necessary to allow you to use the Website and
make Investments through it;
3.1.2 the processing of your personal data by us, or those specifically listed third parties,
in accordance with this policy; and
3.1.3 the transfer of your personal data to those third parties listed in this policy, for the
3.2 You may withdraw your consent under 3.1 at any time. However, where the withdrawal of
your consent prevents us from verifying your identity or otherwise monitoring who you are,
you will be unable to use your Account and make Investments through our Website OR You
may exercise your rights under 3.1 at any time, which includes withdrawing your consent to
our processing of your personal data. However, where this withdrawal prevents us from
performing our contract with you, we may not be able to provide our goods and services to
4. WHAT WE COLLECT
4.1 We may collect all or some of the following categories of data from you:
Address (including postcode)
Date of birth
Bank account or credit card details
Passport (including passport number)
Driving licence (including driving licence number)
4.2 Where you make an Investment over and above €2,500 (or equivalent in Sterling at the
relevant date), you will be additionally required to provide your passport and any associated
personal data contained on that document will be retained by us or our nominated payment
gateway (from time to time).
4.3 In addition to the above, we will also provide you with your Account Details, which includes
your username which is either created by, or assigned to, you. The Account Details should be
remembered by you, but will be stored by us in case you forget them.
5. HOW WE COLLECT YOUR DATA
The data listed in section 4 is collected in the following ways:
5.1 By you registering for an Account – this is any information you give to us that we request from
you when signing-up for an Account to use our Website.
5.2 Information collected – each time you visit our Website, whether through your home, work or
a public network, your own computer or mobile device, we will automatically collect:
5.2.1 technical information – your IP address (used by your computer or device to connect
to the internet), and any internet browser type and version details; and
5.2.2 visit-specific information – your URLs, Projects and Properties you viewed or searched
for, your clickstream through the Website.
5.3 Received from third parties – we work closely our authorised payment gateway, Mangopay
SA to verify your eligibility to make an Investment and any payment you wish to make.
6.1 Our Website will use the cookies listed in section 6.2 (alpha-numeric text files placed on your
6.1.1 distinguish you from other users;
6.1.2 optimise your browsing experience;
6.1.3 make necessary improvements to our Website;
6.1.4 recognise and count the number of visitors to our Website and see how they move
around the Website during use;
6.1.5 recognise you when you return to our Website; and
6.1.6 record your visit to our website, including any links you may follow.
6.2 We may collect some information automatically from your computer, without notice
such as your Internet Protocol (IP) address, computer and connection information,
browser type and version, operating system, Internet Service Provider (ISP),
timestamps, banner ads you click, the URLs you come from and go to next, and a
CrowdLords, our service providers, and other members of our corporate family who
provide joint Services to you with us, will sometimes place anonymous cookies or web
beacons on your computer when you visit the site. Your browser must be set to accept
cookies in order to access CrowdLords as a registered user. We use these cookies and
web beacons to recognize returning users, provide relevant content, measure traffic
and activity on the site, monitor and improve our Services and protect against fraud.
You can block cookies by changing the settings on your browser (consult your browser
help menu to find out how) but doing so may prevent us from delivering certain
Services to you. We do not link the information we store in cookies to any personal
information you submit while on our site.
We also may allow advertisers to occasionally use our Site and they may also use
and we have no access to or control over these cookies.
6.3 Our Website additionally uses Google Analytics, a web analytics service provided by Google,
LLC (Google). Google Analytics uses analytical, performance or targeting cookies to help
analyse how you use the Website and compile reports on your activity for us.
6.4 Any information generated by the cookie about your use of the Website (including your IP
address) will be transmitted to, and stored by, Google on servers in the United States. Google
will use this information for the purpose of evaluating your use of the Website, compiling
reports on your activity for us and providing other services relating to website activity and
internet usage. Google may also transfer this information to third parties where required to
do so by law, or where such third parties process the information on Google's behalf. Google
will not associate your IP address with any other data held by Google.
however please note that if you do this your ability to use the Website may be restricted. By
using the Website, you consent to the processing of data about you by Google in the manner
and for the purposes set out above.
However, if you do so, your ability to use the Website may be restricted.
6.7 Except for essential cookies, all cookies will expire after your session.
7. WHAT WE DO WITH YOUR DATA
7.1 Your data is primarily necessary to verify who you are when accessing your Account and to
ensure you meet our eligibility requirements in order to submit an Application and make an
7.2 Additionally, we will use all of your data you provide us to notify you about:
7.2.1 similar Projects or Properties listed on our Website that are similar to those you have
already Invested in, or otherwise viewed or enquired about; or
7.2.2 changes to our Website or our services.
7.3 We use any data we collect about you (as a result of your visit to our Website) to:
7.3.1 personalise and improve our services (including the Website and its security);
7.3.2 deal with your inquiries and requests;
7.3.3 administer and monitor traffic and behaviours on our Website for analysis, testing,
research, statistical and survey purposes;
7.3.4 ensure that any part of our Website (including any Content) is presented in the most
effective manner for you and your computer or device, and to make improvements
(where necessary); and
7.3.5 keep our Website safe and secure.
7.4 Where we change our services, or any applicable terms and conditions, we will contact you.
7.5 Any data we obtain about you from third parties are used for the purposes of verifying your
eligibility to submit an application and to make an investment through our Website, and are
acquired only to the extent we are unable to do so as a result of the information you provide
7.6 Once collected, we may retain your data for up to six years following the date of your last
Investment or the date you close your Account (whichever is the later). This is to enable us to
refer back to any transactions or records you are involved in (should we be required to do
8. HOW AND WHY WE DISCLOSE YOUR DATA
8.1 Subject to the rest of part 8 of this policy, we will only disclose your personal data to the
following third parties for the following purposes:
8.1.1 the relevant Investee Company – in connection with your Investment, details of which
will be stated on your Application;
8.1.2 our approved payment gateway – in order for you to make the payment(s) required
as part of your Investment;
8.1.3 our approved transaction email provider, The Rocket Science Group - in order for us
to be able to send emails to you (NB only your email address is passed to The Rocket
8.2 In addition to the transfers contemplated by part 8.1, we may transfer or disclose your
personal data to:
8.2.1 any prospective buyer of any part of the relevant business or assets in connection
with the sale (in which case, any personal data held by us about you and our Account
Holders will be one of the transferred assets);
8.2.2 comply with any legal obligation (such as where stated at clause 6.5 of the Investor
Terms and Conditions);
8.2.3 enforce or apply any part of our Investor Terms and Conditions generally; or
8.2.4 protect our rights or our property, or those of our other Account Holders.
8.3 Any websites which are linked from the Website are outside of our control and not covered
by this policy. If you access those websites using the links provided, the website operators
may collect information from you which will be used by them in accordance with their own
privacy policies (if any). These policies may differ from ours, and we cannot accept any
responsibility or liability in respect of these.
9.1 We have put in place appropriate technical and organisational measures to help protect your
personal information from unauthorised access, use, disclosure, alteration or destruction
consistent with applicable Data Protection Laws.
9.2 Each member of staff has unique log-in details and authentication software requires these
to access the systems. Staff have access to personal data only for the purposes of performing
9.3 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
10. YOUR RIGHTS
10.1 In relation to all of your personal data, you have the following rights to ask us or us (in addition
to any rights you may have under the Act or the Regulation):
10.1.1 not to process your personal data for marketing purposes;
10.1.2 to clarify what data we hold about you, how it was obtained, to whom it has been
disclosed and for how long it will be stored;
10.1.3 to amend any inaccurate data we hold about you;
10.1.4 to delete any of your data (where you no longer think we need to hold it or you think
we have obtained it or processed it without your consent at any time); and
10.1.5 to only process your personal data in limited circumstances or for limited purposes.
10.2 If you wish to exercise any of your rights at any time, please contact us on the details
contained at the beginning of this policy in the first instance. We will require you to verify your
identity to us before we provide any personal data, and reserve the right to ask you to specify
the types of personal data to which your request relates.
10.3 Where you wish to exercise any of your rights, they may be subject to payment of a nominal
administration fee (to cover our costs incurred in processing your request) and any
clarification we may reasonably require in relation to your request. Such fees may be charged
where we consider (acting reasonably) that your request is excessive, unfounded or
10.4 Any data provided to you in accordance with your rights will be in a structured and machinereadable