When we refer to “we”, “us” or “Abundance” in this policy we mean Abundance Investment Limited.
For the purposes of the Data Protection Act 2018 the controller is Abundance Investment Limited.
We need to process your personal information to run our business and provide you with the Service we offer. By accepting our Terms & Conditions, you are confirming that you have read and understand this policy. If you don’t want us to collect or process your personal information in the ways we have set out in this policy, please do not visit the Abundance website or use our Service.
Information we collect about you
We collect information about you principally when you provide it directly to us, but also when you use our Service and when other sources provide it to us as described below.
Information you give us
This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, email or otherwise. It includes information you provide when you sign up for an account on Abundance, open a portfolio, deposit and withdraw money, make investments, participate in marketplace trades or otherwise use our Service. The information you give us may include your name, date of birth, address, email address, phone number, financial information, tax information, identification documents, and profile picture.
This also includes any information you may give us through our customer support channels, such as over the phone, email or through our messenger channel. This may include information related to a question you have or a problem you are experiencing with our Service.
Information we collect automatically about you when you use our Service
Your use of our Service
Device and connection information
We automatically collect information about your computer, phone, tablet or other devices you use to access the Abundance website. This includes the type of device used, your IP address, operating system, type of browser, URLs of referring/exit pages and device identifiers.
Information we receive from other sources
In providing you with the Service, we may receive information about you from third parties we work closely with. This may include for example your SIPP administrator, your ISA Manager, your financial adviser, our card payment service provider or our identity verification provider
We combine the information received from third parties with the information we have received, or collected, from you and we use it for the purposes described below.
How we use your information
We collect and process the information about you for the purposes described below based on your use of our Service. We rely on a number of lawful bases to use your information depending on the purpose. These include:
- Contract: It is necessary for us to fulfil our contractual obligations in our Terms & Conditions and to provide the Service to you
- Legal: We have a legal obligation to collect and process the information
- Legitimate interest: The processing of the information is in our or a third party’s legitimate interests and it does not impinge on your own rights for the protection of your information
- Consent: You have given us consent to process your information for a specific purpose
We predominantly process your information on the basis of our contract with you under our Terms & Conditions and under our legal obligation as a company authorised and regulated by the Financial Conduct Authority and as an ISA Manager. Where we process your information based on your explicit consent or where we have a legitimate interest to do so, we have stated this below.
We use your information for the purposes outlined below.
To provide the Abundance Service
We use the information collected about you to provide the Service to you as set out in our Terms & Conditions. This includes providing you with a secure online investment account, processing transactions you make within your Abundance account, providing a record of the investments you hold, providing a marketplace for you to buy and sell investments and providing an Innovative Finance ISA. The information used for this purpose includes personal details (your name and address for example) and the actions you take in your account such as making an investment. We also use your email address to provide you with important service related functionality and notifications, such as account recovery, deposit and investment confirmations, and updates on investments you hold.
For customer support
We use your information to respond to any queries or requests you make to us so that we can quickly resolve any problems and answer any questions you have.
To meet our legal obligations
We are authorised and regulated by the Financial Conduct Authority and we are an HMRC approved ISA Manager. In order to comply with our legal and regulatory obligations we must retain and process your information including details about your use of the Service. This includes retaining accurate records and reporting to regulators and governmental authorities when required.
We are required to verify your identity and conduct anti-money laundering checks on you and certain transactions you may make through your account.
To investigate and help prevent security issues and abuse
We use information about you and your use of the Service to authenticate your account and monitor suspicious or fraudulent activity on Abundance. We do this out of a legitimate interest to ensure the overall security of our Service, including the protection of our customers’ information and accounts, and to protect Abundance and our customers from criminal activity and other security risks.
Improving our service and marketing analysis
You have a right to object and to seek to restrict such processing. See the ‘Your Rights’ section for more information on how to exercise your right to object.
Informing you of new investments and products from Abundance
We use your email address to send you direct marketing emails from Abundance about the investments listed on our website, and other products and services from Abundance. We do this only where you have signed up for an account on Abundance and have not chosen to opt out of emails on new investments and products from Abundance. We do this based on our legitimate interest to make sure customers who have opened an account are aware of new investments launching and other related product news. We only rely on our legitimate interests, where these are not outweighed by your interests or fundamental rights and freedoms. We have done a balancing test and determined that you would expect to receive this information as it is in your interests to receive the latest information about our products and services and about any special offers and promotions. We will only send you emails about our own products and services and we will not share your details with any third parties. You can opt out of receiving direct marketing at any time through clicking the unsubscribe link in our emails, or by contacting us.
To provide targeted advertising to you and improve their effectiveness
How we share your information
The information we collect about you is used by Abundance for the purposes set out above and in some cases your information will be shared with third parties. Where your information is shared, it is only done in order to deliver the Service, fulfil our legal obligations, to meet our legitimate interests or with your explicit consent.
In order to provide the Abundance website, your online account and the Service, we work with a number of third-party service providers. This includes website hosting, maintenance, backup, storage, virtual infrastructure, payment processing, emailing, customer service tools, SIPP providers, ISA providers, survey and review providers, identity verification and fraud prevention providers, analysis and other service providers. These providers may require access to your information to provide their service on our behalf but if they do so, they do on Abundance’s instruction only and only for the purposes of the service they provide to Abundance. We only work with providers that put the same emphasis on protecting your information as we do and who have policies and procedures in place designed to secure and protect your information.
Compliance with regulations and applicable laws and enforcement of our rights
In specific circumstances, we will share your information with a relevant third party if we are required to do so to comply with regulation, applicable law, government request, legal process or national security requirement. This includes, among other things, providing information that may be requested by HM Revenue & Customers and The Financial Conduct Authority. We may also share your information in order to enforce or apply our Terms & of Conditions and other agreements; or to protect the rights, property, or safety of us, our customers, or others.
We may enter into a business transaction such as a sale of company assets, financing, merger or acquisition of all or a portion of the Abundance business. In these types of transactions your information would typically be one of the business assets that is transferred. In this event you will be notified of the transfer and any choices regarding your information.
If you use the marketplace on Abundance to buy or sell an investment, your email address and first name is shared with the buying/selling party to allow you to agree and complete a trade. Your email address is only shared at the point a seller wishes to contact a bidder to agree a trade. Only customers who have created an Abundance account and been through our identity verification process can use the marketplace. We will not be liable for any use or misuse of this information by others, but please inform us of any misuse of the service of which you are aware.
Issuing companies on Abundance
We do not disclose your personal information to any issuer of securities which are offered on Abundance unless it is necessary for the operation of the services or the administration of any investment.
How we securely store your information
The security of your personal information is important to us and we implement technical measures, safeguards and follow industry accepted standards, processes and controls to protect your information collected by us, both during transmission and storage. For example, we only store your information on secure servers and any information you submit through the Abundance website is encrypted using SSL technology. Where you have set a password for your account, you are responsible for keeping this password confidential and ensuring it is a secure password. We ask you not to share a password with anyone.
Unfortunately, no method of transmission over the internet, electronic storage or security system is impenetrable and therefore we cannot guarantee that your information is absolutely safe from intrusion by others. If you have any questions about the security of your information, please contact us at firstname.lastname@example.org.
We will retain your information for as long as is necessary for the purposes set out in this policy, while you remain a customer of Abundance and hold money or investments within your Abundance account. If you no longer hold any assets within your Abundance account, you may request the removal of your account and we will delete your information unless we need to retain it for the purposes stated here. We will still retain some of your information as necessary to comply with our legal obligations, enforce our agreements and to resolve disputes or complaints. Typically we are required to keep financial account information for 6 years following closure of an account. We may also retain some of your information in anonymised form to support the development and improvement of our Service. Where we retain your information to improve our Service, we take steps to either erase or isolate specific information that identifies you and only use information in an aggregate form for statistical and research purposes to determine insights about the use of our Service.
How we transfer information internationally
We collect information about you and primarily store that within the EU and the USA. We may transfer, process and store your information outside of your country of residence to wherever we, or our third-party service providers operate for the purpose of providing you the Service. Some of these entities may be located in countries that do not provide an equivalent level of protection to the UK or your home country. Where required, Abundance has implemented appropriate cross-border transfer solutions and safeguards to provide protection for transfers of your information in accordance with applicable data protection laws. By using our Service, and providing us information about you, you consent to the international transfer of information about you when required.
You have certain rights available to you based on how and why we are collecting and processing your information. We have summarised your rights below, how you can exercise them and any limitations but please get in contact if you have any questions. We will respond to any requests made within a reasonable timeframe.
- Right of access: You have access to much of the information we hold about you within your online Abundance account. This includes the ‘Profile’ section as well as the transactional and investment related information shown within your account. You can also request a copy of the information we hold about you and we will provide this to you in an accessible electronic format.
- Right to rectification: You can let us know if any of the information we hold about you is incorrect or needs updating, for example if you have moved home or changed your email address. Please contact us if you need to update any of your information.
- Right to erasure: In some circumstances you can request that we delete the information we hold about you if you no longer wish to be a customer of Abundance. Please note, however, that we may need to retain certain information for our own records or to comply with legal obligations – please see ‘Retention’ above for more information.
- Right to restrict processing: In some cases you may ask us to stop processing your information where you believe we don’t have the appropriate lawful basis to do so. This may be because an Abundance account was created for you without your permission, you believe the information we hold is inaccurate or because you no longer wish to be a customer of Abundance.
- Right to data portability: This is the ability to request the information we hold about you in a format that would allow it to be moved to another service provider. In the case of Abundance, where the investments offered can only be held on the Abundance platform, there is unlikely to be a case where the information held by Abundance can be used by another provider. However, if requested, we will provide the applicable information in reasonable format.
- Right to object: You can object to us processing your information in some circumstances, where we are doing so based on our legitimate interests, as described above. In these cases we will provide you with our reasoning as to why we think we have a legitimate interest and why we think our processing of your information is not infringing your own rights. We will consider several factors when assessing an objection including: our users’ reasonable expectations; the benefits and risks to you, us, other users, or third parties; and other available means to achieve the same purpose that may be less invasive and do not require disproportional effort. If your objection is upheld, we will cease to process your information for this purpose unless we have compelling legitimate grounds to continue or due to a legal reason.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our website, you should note that we do not have any control over other websites and their content. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.