Privacy Policy

Last updated: January 2025

1. Introduction

Equdex ("we", "us", or "our") is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal information in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

For the purposes of data protection law, Equdex is the data controller responsible for your personal data.

2. Information We Collect

We may collect and process the following categories of personal data:

  • Identity Data: Name, title, date of birth, and identification documents
  • Contact Data: Email address, telephone number, and postal address
  • Financial Data: Bank account details, investment history, and source of funds information
  • Technical Data: IP address, browser type, device information, and usage data
  • Profile Data: Investment preferences, risk tolerance, and accreditation status
  • Communications Data: Records of correspondence and communications with us

3. Lawful Basis for Processing

We process your personal data on the following legal bases under UK GDPR:

  • Contract: Processing necessary for the performance of our contract with you
  • Legal Obligation: Processing necessary to comply with our legal and regulatory obligations, including anti-money laundering (AML) and know your customer (KYC) requirements
  • Legitimate Interests: Processing necessary for our legitimate business interests, such as improving our services and preventing fraud
  • Consent: Where you have given explicit consent to processing, such as for marketing communications

4. How We Use Your Data

We use your personal data to:

  • Provide access to our platform and services
  • Verify your identity and investor status
  • Process investment transactions
  • Comply with legal and regulatory requirements
  • Communicate with you about your account and investments
  • Send marketing communications (where consent has been given)
  • Improve our platform and develop new features
  • Detect and prevent fraud or other illegal activities

5. Data Sharing

We may share your personal data with:

  • Project sponsors and issuers (as necessary for investment purposes)
  • Regulatory authorities (such as the FCA) where required by law
  • Professional advisers including lawyers, auditors, and accountants
  • Third-party service providers who assist in operating our platform
  • Law enforcement agencies where required by law

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

6. International Transfers

Where we transfer your personal data outside the UK, we ensure appropriate safeguards are in place, including UK GDPR-compliant Standard Contractual Clauses or transfers to countries with adequate data protection laws as recognised by the UK Government.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting requirements. For investment-related records, we typically retain data for a minimum of 7 years after the end of our relationship with you.

8. Your Rights

Under UK GDPR, you have the following rights:

  • Right of Access: Request a copy of your personal data
  • Right to Rectification: Request correction of inaccurate data
  • Right to Erasure: Request deletion of your data (subject to legal obligations)
  • Right to Restriction: Request restriction of processing in certain circumstances
  • Right to Data Portability: Receive your data in a structured, machine-readable format
  • Right to Object: Object to processing based on legitimate interests or for direct marketing
  • Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent

To exercise any of these rights, please contact us using the details below. We will respond to your request within one month.

9. Data Security

We have implemented appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include encryption, access controls, and regular security assessments.

10. Cookies

Our platform uses cookies and similar technologies to enhance your experience, analyse usage, and assist in our marketing efforts. You can manage your cookie preferences through your browser settings or our cookie consent tool.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any significant changes by posting the new policy on our platform and, where appropriate, by email.

12. Complaints

If you have concerns about how we handle your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. Visit ico.org.uk for more information.

13. Contact Us

For questions about this Privacy Policy or to exercise your data protection rights, please contact us at: contact@equdex.com