Personal data, or personal information, refers to any information about an individual from which that person can be identified (“Personal Data”). It does not include data where the identity has been removed (“Anonymous Data”).
TrendScout may collect, use, store, and transfer various kinds of personal data about you grouped as follows:
TrendScout may also collect your Personal Data about you from publicly available sources to complete the Due Diligence checks that we are required to carry out as a regulated financial services firm.
We also collect, use, and share statistical or demographic data (“Aggregated 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.
We do not collect any special categories of Personal Data about you, such as:
If you fail to provide the Personal Data we need to collect by law or under the terms of an agreement TrendScout has with you, TrendScout may not be able to perform the contract we have or are trying to enter into with you and may have to suspend or cancel our services.
TrendScout uses the following methods to collect data from and about you.
This includes providing us with your Personal Data when you:
As you interact with TrendScout’s Website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. TrendScout collects this Technical Data using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
TrendScout’s Website may include links to third-party websites, plugins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. TrendScout does not control these third-party websites and is not responsible for their privacy statements or their handling of your data. When you visit these websites using any of these third-party links, we encourage you to read the privacy policies of these websites.
TrendScout may receive Personal Data from various third parties, including but not limited to other users of our Website and services, advertising networks, and public sources.
TrendScout only processes your data (which may include providing it to a third party) where we have identified a valid lawful basis to do so. The legal basis TrendScout relies on is as follows:
Contractual obligation is where the processing is necessary to comply with our obligations arising out of a contract, such as taking payments.
Legitimate interests are where we will record our decision and the reason behind making this decision. TrendScout relies on legitimate interest where the processing of data we hold on and about you does not, in our opinion, affect your rights and freedoms and is proportionate to our interests, including, but not limited to obtaining feedback on our service
TrendScout seeks to obtain your consent to process your data outside our above-mentioned contractual obligations unless we identify a Legitimate Interest as described above.
TrendScout will use your Personal Data in circumstances where:
TrendScout has set out a table listing the description of all the ways we plan to use your Personal Data, the corresponding legal bases we rely on to do so and what our Legitimate Interests are, where appropriate.
You accept, understand, and agree that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we use your data. If you need details about the specific legal ground we rely on to process your Personal Data where more than one ground has been set out in the table below, please contact us via email at email@example.com.
To register you as a new client
Performance of a contract with you
To process and deliver the following transactions/services:
(a) Performance of a contract with you
(b) Necessary for our Legitimate Interest to recover debts due to us
(a) Manage payments, fees, and charges
(b) Collect and recover money owed to us
(d) Marketing & Communications
To manage our relationship with you, which includes:
(b) Asking you to leave a review or take a survey
(d) Marketing & Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our Legitimate Interest to update our records and study how our customers use our products/service
To enable you to partake in a prize draw, competition, or complete a survey
(e) Marketing & Communications
(a) Performance of a contract with you
(b) Necessary for our Legitimate Interest to study how customers use our products/services, to develop them, and grow our business
To administer and protect our TrendScout and the Website, including, but not limited to, troubleshooting, data analysis, testing, system maintenance, support, reporting, and data hosting
(a) Necessary for our Legitimate Interests for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganisation or group restructuring exercise
(b) Necessary to comply with a legal action
To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing & Communications
Necessary for our Legitimate Interests to study how customers use our products/services, to develop them, grow our business, and inform our marketing strategy
To use data analytics to improve our Website, products/services, marketing, customer relationships, and experiences
Necessary for our Legitimate Interests to define customer types for our products and services, to keep our Website updated and relevant, to develop our business and inform our marketing strategy
To make suggestions and recommendations to you about products and services that may be of interest to you
(f) Marketing & Communications
Necessary for our Legitimate Interests to develop our products/services and grow our business
Marketing investment opportunities are an essential activity of TrendScout. As such, TrendScout will notify you of investment opportunities that we think will be of interest to you, based on your Personal Data and other information you have provided us. TrendScout seeks to maximise the number of relevant investment opportunities shown to you, which is achieved by marketing these opportunities via email and other digital marketing channels.
TrendScout has undertaken a data protection impact assessment concerning our digital communication tools and channels for marketing purposes, and we have concluded that we have a legitimate interest in carrying out direct digital marketing to our member investors and startups (“Members”). The method is familiar to our Members and is the least intrusive one available to us. We also considered that there is no adverse impact on individuals as our communications are only sent to those who have provided their details to become a member.
However, TrendScout strives to provide our Members with choices and options for using Personal Data, particularly around marketing. You can ask us to stop sending you marketing messages anytime by following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, TrendScout will still process your Personal Data provided to us due to your use of the Website, our services, and other transactions.
Copies of data protection impact assessments or Legitimate Interest Assessments TrendScout undertook are available on request by sending us an email to firstname.lastname@example.org.
TrendScout and its partners (including marketing affiliate partners, analytics service providers, and business process service providers) use technologies including, but not limited to, cookies, beacons, tags, and scripts to analyse trends, administer our Website, track users’ movements around our Website and to gather demographic information about our user base as a whole. TrendScout may receive reports based on companies’ use of these technologies on individual and Aggregated Data.
TrendScout 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 that is compatible with the original purpose.
If TrendScout needs to use your Personal Data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
You accept, understand, and agree that TrendScout may process your Personal Data without your knowledge or consent in compliance with the above rules, where this is required or permitted by law.
If you wish to get an explanation of how the processing for the new purpose is compatible with the original purpose, please email us at email@example.com
TrendScout will keep your information within the organisation except where disclosure is required or permitted by law or when we use third-party service providers (third-party processors we have contracts in place) to supply and support our services to you. This means that they cannot do anything with your Personal Data unless we have instructed them to do so. They will not share your Personal Data with any organisation apart from us; they will hold it securely and retain it for the period we instruct.
The categories of recipients of Personal Data include:
If you have taken advantage of, or have applied to take advantage of, one of the investment opportunities we make available to Members on our Website, your Personal Data may also be shared with the relevant business or their professional representatives. Your Personal Data may also be shared with any business you contact directly. We have no responsibility or liability for how your Personal Data is handled by businesses you provide your data to via our Website or directly.
TrendScout requires all third parties to respect the security of your Personal Data and treat it under the law. TrendScout does not allow our third-party service providers to use your Personal Data for their own purposes and only permits them to process your Personal Data for specified purposes and following our instructions.
TrendScout asks for express consent before we share your Personal Data with any third party for marketing purposes. To avoid doubt, this does not include third parties who support us in providing direct marketing to you
TrendScout and our processors store your Personal Data in the UK, EEA, or another country under the applicable data protection laws
Third-party privacy policies will also apply in respect of integrated services which collect data, namely:
The security of your Personal Data is important to us. When you enter sensitive information such as your bank account information on our order forms, we encrypt the transmission of that information using Secure Socket Layer (SSL) technology.
TrendScout follows generally accepted standards to protect the Personal Data submitted to us during transmission and after receiving it. All information you provide to TrendScout via email or the Website is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping the password confidential and not sharing the password with anyone.
However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.
If you have any questions about the security on our Website, you can contact us at firstname.lastname@example.org.
TrendScout uses recognised and accredited third parties to perform regular penetration tests of our platform and internal networks. Any output is reviewed and prioritised with high importance.
Like many businesses, TrendScout uses certain third parties to support the services we provide our Members. TrendScout also constantly review the security and suitability of any third parties as part of our ongoing process.
TrendScout’s employees must undertake cybersecurity awareness training and acknowledge and comply with internal security processes across hardware and software. These are reviewed and updated regularly.
By law, TrendScout has to keep basic information about our clients, including Contact, Identity, and Financial and Transaction Data, for six years after they cease being clients.
TrendScout will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including satisfying any legal, regulatory, tax, accounting, or reporting requirements. As such, TrendScout may retain your Personal Data for more than six years in case of a complaint, or we reasonably believe there is a prospect of litigation concerning our relationship with you.
To determine the appropriate retention period for personal data, TrendScout considers 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 of 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.
Details of retention periods for different aspects of your Personal Data are available in our retention policy which you can request by contacting us.
Under certain circumstances, you have rights under data protection laws concerning your Personal Data, although you accept, understand, and agree that these rights may be limited under certain circumstances
Commonly known as a “data 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.
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 information you provide.
This enables you to ask us to delete or remove personal data where there is no good reason for us to continue 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, where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law.
You accept, understand, and agree that TrendScout 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.
If TrendScout relies on a Legitimate Interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental data, you have the right to object to having your Personal Data processed. You also have the right to object to where we are processing your Personal Data for direct marketing purposes.
You accept, understand, and agree that TrendScout may, in these situations, demonstrate that we have compelling legitimate grounds to process your Personal Data and that this overrides your right and freedoms.
This enables you to ask TrendScout to suspend the processing of your Personal Data in the following scenarios:
TrendScout will provide you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format.
You accept, understand, and agree that this right only applies to automated information you initially provided consent for us to use or where we used the information to perform a contract with you.
This enables you to withdraw your consent previously given to TrendScout to process your Personal Data at any time for as long as this will not affect the lawfulness of any processing before you withdraw your consent.
You accept, understand, and agree that if you withdraw your consent, TrendScout will not be able to provide certain products or services to you. TrendScout will advise you if this is the case when you withdraw your consent.
You will not have to pay a fee to access your Personal Data (or to exercise any of the others). However, TrendScout may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, TrendScout could refuse to comply with your request in these circumstances.
TrendScout 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 that Personal Data is not disclosed to anyone with no right to receive it. TrendScout may also contact you to ask you for further information concerning your request to speed up our response.
TrendScout tries 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 several requests at a time. In situations such as this, TrendScout will notify you and keep you updated.
TrendScout’s Website offers a publicly accessible blog and community discussions. You accept, understand, and agree that any information you provide in these areas may be read, collected, and used by others who access them.
To request the removal of your Personal Data from our blog or community discussions, contact us via email at email@example.com.
You accept, understand, and agree that, in some cases, TrendScout may not be able to remove your Personal Data. In these cases, TrendScout will let you know if we cannot do so and why.
You accept, understand, and agree that if you choose to use our referral service to tell a contact about TrendScout’s Website and services, TrendScout will ask you for your contact’s name and email address. As such, you must have consent from your contact to provide this information to us.
TrendScout will automatically send your contact a one-time email inviting your contacts to visit the Website. TrendScout will store this information for the sole purpose of sending this one-time email and tracking the success of our referral program. You and/or your contact may contact us at firstname.lastname@example.org to request that this information be removed from our database.
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