GPS Privacy Policy

 

 

 

 

  1. Application

 

Global Preservation Strategies Limited, a company incorporated in England and Wales under No.

07354963 whose registered office is at 8 Little Trinity Lane, London, United Kingdom, EC4V 2AN hereinafter referred to as ‘GPS or ‘We’ have created this privacy statement (‘Statement’) in order to demonstrate our firm commitment to the privacy of the details that You provide to us when using Site and the GPS website. In this Statement, references to ‘You’ and ‘Your’ are references to the GPS User who may or may not be a registered GPS Member. When You use the Site, You are consenting to the practices set forth in this Statement.

 

We know that Your privacy is very important to You which makes it very important to us. We aim to be as clear as possible in this Statement in respect of Your Data. This Statement applies inter alia to Your Data that We collect about You when You use the Site and the GPS website, how and when it is used, how We protect it and who has access to it.

 

  1. Your Acceptance of the Statement

 

This Statement governs Your use of the Site and the GPS website, including any dispute concerning privacy. By using the Site and the GPS website, You accept this Statement in full. You should read the Statement carefully and ensure that You understand its effect before proceeding to use the Site. We reserve the right to modify this Statement at any time due to a change in the law or otherwise without notice by posting the changes on this page. Your continued use of any portion of the Site following the posting of the updated Statement will constitute Your acceptance of the changes. If we make any material changes, We will notify You by email.

 

  1. Collecting Your Data

 

As part of the process of using the Site and the GPS website, We may collect certain data from You including but not limited to

 

  • Your contact details upon registration to become a GPS Member including Your first and last names, email address and other GPS Account details. It can also include your financial and debit card information and other personal details such as your National Insurance number and health information.

 

  • Information required to create Your GPS Profile and GPS Login;

 

  • Your visits to the Site, the resources and GPS Content that You download;

 

 

 

 

 

 

  • Information that You provide to us by written communication by post or email;

 

  • Information that You provide to us when We speak to You by telephone. We may keep a record of the information that You share with us, and;

 

  1. Collecting Your Financial Data

 

As a GPS Investor, when You wish to deposit investment funds in Your GPS Account, You will be required to provide Your bank details in order for payment to be processed, will not share Financial Data with any other third parties without Your prior consent.

 

  1. Other Data

 

Other de-personalised data which does not record Personal Data or Financial Data as such, rather information such as the date of the visit to the Site, the path taken, the browser used, the IP address etc is used primarily to aid the technical administration of the Site, to better understand how the

Site is functioning for GPS Visitors and GPS Members and to draw conclusions upon demographic information.

 

  1. How is Your Data Used?

 

You acknowledge that Your Data may be used by GPS to contact a GPS User by post, phone or by electronic mail when necessary in connection with GPS Membership (including GPS Login and GPS Account) and the investment process in general.

 

From time to time, GPS may contact You by electronic mail by way of sending You periodic

marketing emails with the latest Pitches, Updates, funding news and Lead Director comments or any other newsletter or information or offers regarding upcoming products, promotions, services, specific events, case studies or customer surveys. When You become a GPS Member, You give us Your consent to do this. If You change Your mind, You can opt out of receiving some but not all of this in accordance with this Statement.

 

If Data has been passed to third parties with Your consent, You may need to contact them separately if You  change Your mind in relation to their use of Your Data.

 

The other principal purposes for which We process and store Your Data are:

 

  • To confirm Your identity in order to create Your GPS Account and to ensure that You satisfy the GPS Membership Criteria to use the services provided on the GPS website.

 

  • To conduct required anti-money laundering checks on You in connection with certain transactions You may conduct.

 

 

 

 

 

 

  • To monitor, improve and administer the Site and the GPS website.

 

  • To enable us to comply with our legal and regulatory obligations.

 

  • To be able to pass Your Data on to third party companies or service providers in respect of Legal and other services. We will take reasonable precautions to ensure that these parties are obligated to keep confidential any of Your Data that they use.

 

 

 

 

  1. Who has access to Your Data?

 

To minimise the risk of unauthorised access to Your Data, We use some of Your Data to authenticate You when using the Site. For our daily operations, We use the services of third parties to provide some of our business and operational functions. Some of these services are provided by our GPS Partners. For the avoidance of doubt, Your Data is used solely by GPS (and its group companies and the GPS Partners) for the sole purpose and to the extent necessary to enable GPS to effectively provide You with all the functionality required by the GPS website throughout the life of the investment process) and is not shared with any person or company without Your express consent. Any Data that is held with GPS shall be retained in accordance with the Data Protection Act 1998, General Data Protection Regulation (GDPR) and related legislation and/ or our retention and destruction policy culminating in its permanent deletion.

 

Disclosure of Your Data in Compliance with Laws

 

You should be aware that We may release Your Data when We believe it is necessary to comply with laws or regulations, to assist law enforcement, to enforce the terms under which You transacted

with GPS or a GPS Partner, or to protect the rights, property or safety of GPS, GPS Members or third parties. This includes any requirements of the Financial Conduct Authority (“FCA”).

 

Transfer of Your Data outside of the EEA

 

From time to time, We may transfer Your Data to a related company, agent or contractor in order to improve our services or to assist our security, credit risk or fraud protection activities. Such companies may be located outside of the EEA and You consent to the transfer of Your Data to such companies for the purposes set out here in accordance with this Statement and as permitted by the Data Protection Legislation from time to time.

 

 

 

 

 

 

Transfer of Data in the Event of the Sale of GPS or its Assets

 

In the event that GPS is sold or transfers some of its assets to another party, Your Data could be one of the transferred assets. If Your Data is transferred, its use will remain subject to this Statement. Your Data will be passed on to a successor in interest in the event of a liquidation or administration of GPS.

 

Other Sites and their Privacy Policies and Cookie Policies

 

The Site may contain links to other websites. GPS is not responsible for the privacy practices or the content of such websites or for the privacy policies, cookie policies and practices of other third parties, so You should be careful to read and understand those website policies independently.

 

  1. Security of Your Data

 

We take the security of your personal data very seriously, and we use appropriate technologies and procedures to protect your personal information. We keep our data security policies and procedures up to widely accepted international standards. In addition, we review our policies regularly and update them whenever needed to protect you, and to meet our business needs, changes in technology, and regulatory requirements. We have a business continuity and disaster recovery plan that is designed to help us offer our services and protect our people and assets no matter what happens.

 

We endeavour to take all reasonable steps to protect Your Data. However, We cannot guarantee the security of any Data you disclose online. In using the Site, You agree that You will not hold GPS responsible for any breach of security unless We have been grossly negligent or in wilful default. If You have any questions about security on our Site, You can contact us at [email protected]. You acknowledge that email messages sent over the internet are not encrypted and are not secure. Despite efforts to protect Your Data, We cannot ensure or warrant the security of any Data You transmit to us, via, to, or from our Site. You accept that GPS cannot be held liable for any breaches of confidentiality that may occur as a result of the use of email. You transmit all such Data at Your own risk.

 

  1. Use of Cookies

 

For information about cookies and how they are used on this Site, please visit our Cookie Policy.

 

  1. Communications between You and GPS

 

We may intercept, record and/or monitor any communication(s) (including telephone calls or other electronic communications) between You and us. We may do so in order to resolve queries in the

 

 

 

future and for the purposes of ensuring security, staff training and complying with our regulatory and legal responsibilities.

 

  1. Opting Out

 

If You do not wish to be contacted by GPS in respect of future marketing communications (excluding any mandatory communications which are a necessary part of being able to use the GPS website which cannot be opted out of), We will give You the opportunity to unsubscribe to the receipt of such communications in every electronic mail communication that We send You.

 

  1. Obtaining Copies of Your Data

 

In the event that You wish to see a copy of all of Your Personal Data held by us, please write to:

 

GPS (Data Protection Officer)

 

 

8 Little Trinity Lane

 

London

 

United Kingdom

 

EC4V 2AN

 

If You request a copy of Your Data, We may charge You a small administrative fee to cover the costs of providing it to You.

 

We will retain Your information for as long as Your GPS Membership is still valid or as needed to provide You with our services. We will retain and use Your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, which may require varying retention periods.

 

 

 

 

  1. Changes to Your Data

 

If You believe that any of Your Data held by us is inaccurate, please revise or update it using the functionality provide by the Site where applicable and permissible by the GPS website. Alternatively, You may contact us at [email protected] to correct or delete the information. It is Your responsibility to ensure that any Data You have provided to us remains accurate and to notify us if there are any changes in Your Data.

 

 

 

  1. Severability

 

We have made every effort to ensure that this Statement adheres strictly with the relevant provisions of the Data Protection Legislation and other applicable laws. However, in the event that any of these provisions are found to be unlawful, invalid or otherwise unenforceable, that provision is to be deemed severed from this Statement and shall not affect the validity and enforceability of the rest of the Statement.

 

  1. No Waiver

 

In the event that either You or We fail to exercise any right or remedy contained in this Statement, that does not mean that You or We (as applicable) have waived that right or remedy and so shall not be construed as a waiver.

 

  1. Complaints or Queries

 

GPS tries to meet the highest standards when collecting and using Data. For this reason, We take any complaints We receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of Data is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures. This Statement does not provide an exhaustive detail of all aspects of GPS’s collection and use of Data. However, We are happy to

provide any additional information or explanation needed. Any requests for this should be sent to the address below or to our customer support team by email at [email protected] . If You are not happy with the way in which Your Data is being handled by GPS, You can complain to the

Information Commissioner whose details can be found at: http://www.ico.org.uk/

 

  1. Choice of Law

 

This Statement shall be governed by and construed in accordance with the laws of England and

Wales.

 

  1. Jurisdiction

 

You agree to submit to the exclusive jurisdiction of the courts of England and Wales. This means that if You want to bring a legal action against us, or we want to bring a legal action against You, it must be done in one of these courts.