Privacy Policy

Introduction

Welcome to Stockopedia’s privacy policy.

Stockopedia respects your privacy and is committed to protecting your personal data.

This privacy policy will inform you as to how we look after your personal data when you visit our website (https://www.stockopedia.com), or subscribe to or use our service (regardless of where you live) and tell you about your privacy rights and how the law protects you.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Purpose of this privacy policy

This privacy policy aims to give you information on how Stockopedia collects and processes your personal data through your use of this website or our service, for example, when you sign up to receive editorial content.

This website and our service are not intended for children and we do not knowingly collect data relating to children.

The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain Personally-Identifying Information from anyone under the age of 13, unless or except as permitted by law. Any person who provides Personally-Identifying Information through the Website represents to us that he or she is 13 years of age or older. If we learn that Personally-Identifying Information has been collected from a user under 13 years of age on or through the Website, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a member of the Website or has otherwise transferred Personally-Identifying Information to the Website, please contact Stockopedia using our contact information below to have that child’s account terminated and information deleted.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Stockopedia Ltd is the controller and responsible for your personal data (referred to as Stockopedia, we, us or our in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights (set out below), please contact us using the details set out below.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes your name, username or similar identifier.
• Contact Data includes billing address, delivery address, email address, physical location and telephone numbers.
• Financial Data includes bank account and payment card details, but all payments are made via Payment Card Industry compliant third-party payment service providers. To make a payment, you will automatically be redirected to the payment service provider. We do not store your card details.
• Transaction Data includes details about payments to and from you and other details about the service you have subscribed to.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, information inputted in to the service, for example, portfolio information, as well as feedback and survey responses.
• Usage Data includes information about how you use this website and our service.
• Communications Data includes your preferences in receiving editorial content and marketing communication from us and our third parties.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide your subscription). In this case, we may have to cancel the subscription that you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Financial Data and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• create an account on this website;
• subscribe to our service;
• sign up to receive communications from us; or
• give us feedback or contact us.

• Automated technologies or interactions. As you interact with this website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
• Third parties or publicly available sources. We may receive Technical Data from analytics providers, advertising networks and search information providers. We may also receive Contact and Transaction Data from providers of technical or payment services.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to and for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Most commonly, we will use your personal data in the following circumstances:

• To perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• To comply with a legal obligation.
• To establish, exercise or defend legal claims.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We describe below all the ways we plan to use your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

We will ensure that when processing your personal data, we abide by the GDPR principles of lawfulness, fairness and transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity and confidentiality (security) and accountability.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying on to process your personal data where more than one is set out below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing.

Promotional offers from

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide what editorial content, part of our service or offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or subscribed to our service and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into your account and managing your communication preferences, by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase of our service.

Cookies

For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the details set out below.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties below for the purposes set out in the table above.

• Service providers who provide IT support and system administration services, hosting services (including cloud storage and data management services), data analytics services, marketing services and support service providers (including subscriber support).
• Marketing service providers (including ad networks and media agencies).
• Our agents promoting and selling our service in your jurisdiction.
• Payment service providers.
• Professional advisers including lawyers, bankers, auditors and insurers.
• Tax authorities, regulators and any other authorities whether in the United Kingdom or otherwise.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire (or be acquired by) other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed by the UK / EU to provide an adequate level of protection for personal data.
• We may use specific contracts approved for use in the UK and EEA which give personal data the same protection it has in the UK or EEA.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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 do so.

8. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our Terms of Use, we may keep hold of some of your information as required, even after you have closed your account. For example, by law we have to keep basic information about our subscriber (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being subscribers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights (set out below) for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

If you are habitually located in the UK or the EEA, you have certain rights under data protection laws in relation to your personal data. While some of these rights apply generally, certain rights apply only in certain limited circumstances. Please see below to find out more about these rights.

• Request access to your personal data (commonly known as a subject access request). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or that of a third party) and you want to object to the processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may have compelling legitimate grounds to process your data which override your rights and freedoms.
• Request restriction of processing your personal data. You also have the right to restrict us from processing your personal data if the data is inaccurate, the processing is unlawful (but you do not want us to erase it), we no longer need your personal data for the purposes for which we hold it (but you need it to establish, exercise or defend legal claims) or you have objected to our use of your data but we need to verify whether we have an overriding legitimate ground to use it.
• Request transfer of your personal data of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide our service to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the details set out below.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Making a complaint

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). If you are based in the European Economic Area (EEA), you can complain to your local regulator or the Data Protection Commission in the Republic of Ireland, which is the regulator of our EEA Representative. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or another regulator so please contact us in the first instance, using the details set out below.

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

10. OUR EEA REPRESENTATIVE

As we are not established in the EEA, Adam Brogden, Instant EU GDPR Representative Ltd, based in the Republic of Ireland has been established as our EEA representative.

EEA Representative: Adam Brogden, Instant EU GDPR Representative Ltd.

Email address: contact@gdprlocal.com

Postal address: INSTANT EU GDPR REPRESENTATIVE LIMITED Office 2 12A Lower Main Street, Lucan Co. Dublin K78 X5P8 Ireland

Telephone number: + 353 15 549 700

11. CONTACT US

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: Stockopedia Ltd

Email address: support@stockopedia.com

Postal address: Oxford Centre for Innovation, New Road, Oxford OX1 1B, United Kingdom.

Telephone number: (+44) 01865 261 447

12. CHANGES TO THIS PRIVACY POLICY

We keep our privacy policy under regular review. This version was last updated on 30/11/2022.