INVESTLY PRIVACY & COOKIE POLICY

Our website is mediating invoice finance with sellers from United Kingdom through Investly Ltd and from Estonia through Investly Technologies OÜ. For auctions situated with different sellers, separate terms apply. Please read these privacy and cookie policies carefully.

INVESTLY PRIVACY POLICY

Introduction

Investly Ltd (“Investly”, “Us”, “We”, “Our”) is the data controller of your Information for the purposes of the Data Protection Act 1998 (the “Act”). We respect your privacy and we are committed to protecting your personal information as that term is defined in the Act (“Information”). We comply with the principles of the Act and aim to maintain consistently high levels of best practice in our processing of your Information.

This Privacy Policy (“Policy”) is intended to inform you how your personal data is collected, used and disclosed through your use of the Investly Platform. This Policy is intended to assist you in making informed decisions about your Information when using our website and the loan and investment arrangements our platform makes available. Please take a minute to read and understand the Policy.

By using our website and services you consent to our collection and use of your Information as described in this Policy. If we change our Policy and/or procedures, we will post those changes on our website to keep you aware of what Information we collect, how we use it and under what circumstances we may disclose it. Your continued use of the website or services after this Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of this Policy, as amended. We encourage you to bookmark this Web page and review this Policy regularly.

In addition to this Policy, each service offered by us or our group companies may have additional privacy provisions that are specific to the particular service (for example if you use our Estonian website which is run by Investly Technologies OÜ, your Information will be used in accordance with the privacy policy set out on that site). In addition, when you enter into an agreement to invest or borrow through the Investly Platform, your Information will be used and processed by the parties concluding the relevant contract, and they may have their own privacy policies explaining how your Iinformation will be used by them.

What Information Do We Collect?

All your Information will be held and used in accordance with the Act where applicable. If you want to know what Information we collect and hold about you, please write to us at: support@investly.co

When you visit and use our website or use our services you may provide us with or we may collect your Information such as your postal address, email address, bank details and other personal information. You may provide or we may collect this Information in a number of ways:

Information you voluntarily provide to us

We collect and maintain Information that you voluntarily submit to us during your use of our website or services. For example:

• when you register on our website or use a service, you may provide us with certain Information including your name, email address, username, password, address, mobile phone number, and bank details;
• you may provide us with Information in the course of email, customer support interactions and surveys.

You can choose not to provide us with certain Information, but this may stop you from gaining access to a service or limit the features that you can use on our websites. For more information, please see the “How We Use Your Information” section of the Policy below.

 

Information we collect through your use of our Website

As you use our website, Information may also be passively collected by us through our use of cookies, pixels, beacons, log files and other technologies. This Information allows us to deliver more helpful information, services and tools. Please see our Cookie Policy for more information.

Information we receive from third parties

We may also combine online and/or offline information received from third parties (including other members of our group of companies or credit checking companies) with your Information.

The third party information is used for a variety of purposes including:

• to verify your age or residency and to comply with applicable regulatory requirements (including anti-money laundering requirements);
• to verify other Information about you (e.g., mailing address to send you requested products or services); and
• to enhance the content and services we provide to you.

 

How We Use Your Information

We will use your Information in the ways described below and as described at the time that the Information is collected.

To Provide the Services

In general, we use your Information as necessary or appropriate for our business purposes including to:

• administer your account where you have opened an account with us;
• register you and provide you access to the website or services requested by you;
• verify that you meet the requirements for a user of the site;
• verify your identify for the purpose of applicable credit checks;
• fulfil your requests for products or services including keeping you informed about your lending or borrowing;
• to identify, prevent or detect fraud, money laundering or other crime;
• respond to inquiries or requests that you direct to us; and
• send communications and administrative emails about the website or our services;
• analyse, benchmark and conduct research on user data and user interactions with the website and our services.

 

Marketing

Where you have provided us with the appropriate consents, or where the Act entitles us to do so, we may send you marketing materials about other products or services offered by Investly, and/or products or services offered by our group companies. In addition, where you have provided us with the appropriate consents, we may also pass your Information to one or more of our group companies or other selected third parties for marketing purposes.

However, be assured that we understand the irritations of unsolicited communications and we are fully committed to ensuring the rights and obligations set out in the Act and the Privacy and Electronic Communications Regulations 2003 are respected.

Can I find out what personal information Investly holds on me?

Under the Act you have the right to request a copy of the Information that we hold about you. There will be an administration fee of £10 associated with this request and it will require two pieces of identification to prove your identity. Please make a written application to Ruth Chamberlain to email address ruth@investly.co.

If any of the Information that we hold about you is incorrect, you can click on the contact us link on our website.

How We Disclose Your Information to Third Parties

We may share your Information with third parties as specifically approved by you or under the circumstances described below.

Disclosure to third party organisations to provide the services

Where you use the services available on our Website (for example by submitting a Loan Application, Sales Offer, Purchase Offer or entering into a Factoring Agreement) we may disclose your Information to the relevant third parties with whom you are contracting in order for them to fulfil the terms and conditions of those arrangements. Such disclosure shall only take place following entry into the relevant agreement.

We may also disclosure your Information to third parties to assess the creditworthiness of your application. By submitting a Loan Application or making a Sales Offer you consent to use transferring your Information for such purposes.

Disclosure for legal or regulatory reasons

We may disclose your Information if we are under a duty to disclose or share your Information to comply with any legal obligation or in order to enforce or apply or fulfil our terms and conditions and other agreements or protect the rights, property, or safety of our customers, our group companies or others. This includes exchanging information with other companies, regulators and organisations for fraud protection and credit risk reduction.

We use a number of third party organisations to help provide a professional service to our customers (i.e. fulfilment bureaus, call centres, and website designers). These organisations act as data processors and are strictly controlled in how they may/may not use your Information and we remain responsible for the protection of your Information.

Changes to our Company

In the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Policy.

Updating and Control of Your Information

There are a number of ways in which you can control the collection, use, and sharing of your Information and update your Information and preferences.

Cancelling your user registration

You may at any time choose to close your account with us. We will then cease processing your Information for any new purposes, but such closure shall not affect our ability to retain and process any Information required or the performance of obligations arising from law or for the completion of any services which are in process.

Opting-Out on Receipt of Marketing Communications

When you receive marketing communications from us you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the marketing e-mail or newsletter.

Preference Services

The Telephone Preference Service (TPS) and the Mailing Preference Service (MPS) allow you to choose to opt out of unsolicited marketing contact by us and any third parties. However, if you are registered on either preference service, we will assume that any subsequent consent to receiving marketing communications given to us via our website or other means of data capture indicates, for the time being, your consent to receive marketing communications in accordance with your consent.

Contacting Us

If your Information has changed or if you no longer wish to receive marketing communications from us then you can contact us via email support@investly.co.

Please note that:

• even if you delete Information, we may retain your Information in conformance with our data retention policy; and
• we are not responsible for updating or removing your Information contained in the lists or databases of third parties who have been provided with Information as permitted by this Policy.

 

Third Party Links and Services

Please remember that when you use a link to go from our website to another website or you request a service from a third party, our Policy no longer applies. Your browsing and interaction on any other website or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control, or endorse the information collection or privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices. This Policy applies solely to information collected by us through our website or services and does not apply to these third party websites and third party service providers.

Where We Store Your Information

The Information that we collect from you may be transferred to and stored at a destination outside the European Economic Area, in particular where counterparties to any of the services offered through our site are based outside the European Economic Area. Your Information may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting Information to us, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Information is treated securely and in accordance with this Policy and the Act.

Security of Your Information

We follow appropriate security procedures in the storage and disclosure of your Information so as to prevent unauthorised access by third parties. We also require those parties to whom we transfer personal information to comply with the same. However, unfortunately, the transmission of information via the Internet is not completely secure. So, we cannot ensure the security of your Information transmitted by you to us via the internet. Any such transmission is at your own risk and you acknowledge and agree that we shall not be responsible for any unauthorised use, distribution, damage or destruction of your Information, except to the extent we are required to accept such responsibility by the Act. Once we have received your Information we will use security procedures and features to prevent unauthorised access to it.

INVESTLY COOKIE POLICY

1. INTRODUCTION
   1. This cookie policy (“Cookie Policy“) is intended to inform you how we use “cookies” and similar technologies and to assist you in making informed decisions when using the Website.
   2. Please take a moment to read and understand this Cookie Policy. This Cookie Policy should also be read in conjunction with our Privacy Policy and our Terms of Use.
   3. A cookies is a very small text document or piece of code, which often includes an anonymous unique identifier. When you visit a website or use a mobile application, a computer asks your computer or mobile device for permission to store this file (or similar technologies such as web beacons) on your computer or mobile device and access information from it. Information gathered through cookies or similar technologies may include the date and time of visits and how you are using the Website.
   4. Cookies are used by us as part of the Website. Our website also uses third party cookies for analytics. Further information about these cookies is set out below.
   5. For more details on cookies and similar technologies please visit All About Cookies. For the purposes of the remaining sections of this Cookie Policy we will refer to all technologies using the above features as “cookies”.
2. YOUR CONSENT TO OUR USE OF COOKIES
   1. By continuing to use the Website you are deemed to consent to our use of the cookies described in this Cookie Policy. If you do not consent to us using cookies then please read the next section.
3. BLOCKING OUR USE OF COOKIES
   1. You can block the use of cookies by activating the relevant settings in your browser or by following the links below. For more information on cookie management and blocking cookies for a wide variety of browsers, visit All About Cookies.
4. WHAT HAPPENS WHEN YOU BLOCK COOKIES
   1. In order to use some parts of the Website your web browser will need to accept cookies. If you choose to withhold consent, or subsequently block cookies, some aspects of the Website may not work properly and you may not be able to access all or part of the Website.
5. WHAT WE DO WITH COOKIES
   1. We use session cookies to allow the Website to uniquely identify your browsing session on the Website, which allows us to coordinate this information with data from the Website server. Such cookies are stored temporarily during a browsing session and are deleted from the user’s device when the browser is closed.
   2. We also use persistent cookies that may be saved on your computer for a fixed period and are not deleted when the browser is closed where we need to know who you are for more than one browsing session. For example, we use this type of cookie to store your preferences, so that they are remembered for the next visit, or to keep you logged in if you navigate away.
   3. We may also use cookies where they are essential for the operation of the Website, for example to remember that you are signed in to the Website during your session.
   4. We use “analytics” cookies. These, along with other information, allow us to calculate the aggregate number of people using the Website and which features of the Website are most popular.
   5. We use this information to improve the Website. We do not generally store any personal data that may be provided to us in a cookie.
6. MORE INFORMATION
   1. The table below sets out more information about the individual cookies used in the Website and the purposes for which they are used.

      Cookie Type	Purpose	Duration
      Google Analytics (Third Party Cookie)	These cookies enable us to store information such as the time you visit our Website, whether you have visited before and the website that you visited prior to visiting our Website. For more information about Google Analytics please see: http://www.google.com/intl/en/analytics/privacyoverview.html	2 years
      Authentication	This cookie allows us to keep you logged in even when you navigate away from the site or close your browser.	2 hours
      Facebook, Twitter and LinkedIn buttons	These cookies enable users to like or share items in social pages. http://www.facebook.com/policy.php, http://twitter.com/privacy, http://www.linkedin.com/legal/privacy-policy
      Intercom	This cookie enables us to communicate with users with e-mail and chat and helps us to make analyses. https://www.intercom.com/privacy.
      Promo code	This cookie allows us to check if you are using any promotion code and automatically ensure you receive the benefit of it.	3 hours
      Track url	This cookie informs us which webpage you visited immediately before coming to our Website. It does not collect any personal data or send personal data any third party.	2 hours