Who we are
1. INVESTSET’s commitment to user privacy
1.2. INVESTSET’s activities are the licensing of the use of economic and financial information software, with analysis and news tools.
1.3 It is INVESTSET’s policy to respect the privacy of its Users.
1.4. We do not collect or knowingly request information from minors under the age of 18.
2. Storage, use and protection of Users’ information
3. Information collected by INVESTSET Platforms
3.1 Information collected from registered Users.
When the user registers on the Platforms, we may collect the following Information:
- Personal Information: such as full name, social security number, professional postal address, professional email address, and professional phone number.
- Personal Social Media Data: By registering and accessing the Platforms through any social media, such as Facebook, Twitter, Linkedin, Google or others (if this functionality is available), you are informed that we may to collect, store and use your information and content available on such social networks.
- Copies of Documents: we may collect, through our own functionality or service provider, as part of the procedure for registering and analyzing the registration request on INVESTSET Platforms by Users of INVESTSET Platforms.
4. Update and other information about your registration
4.1 Changes in registration data
The ownership of the registration is personal although linked to your professional contact details. Changes to registration data may be made by the User him/herself in his/her account. However, some specific data (such as name for example), is considered key and can only be changed by INVESTSET upon request by firstname.lastname@example.org. For other data, if you wish to make any changes, please log in to your account and adjust the data.
4.2 Information on the data held by INVESTSET
If you have any reason to believe or suspect that any information we have about you is wrong or incomplete, please contact our call center or write an email to our team at: email@example.com. The INVESTSET team will be ready to fulfill your request and correct any information that is wrong or incomplete.
5. Place of storage of User Information and use of Information collected
6. The purposes of processing the Information and the specific use of the Information collected
6.1 Information supplied by the Users are processed in order to:
- enter into and execute the services subscribed (i.e. to perform any pre-contractual measures as well as the contract entered into by the Users),
- for the legitimate interests of INVESTSET, and
- to comply with the legal obligations imposed on INVESTSET.
- enable the use of INVESTSET Platforms,
- to allow INVESTSET to detect possible fraud, as well as compliance with other legal and regulatory obligations imposed on INVESTSET Platforms such as complying with applicable anti-money laundering rules and any other legal obligations, such as maintaining controls in respect of late trading and market timing practices;
- elaborate statistics and implement marketing and relationship campaigns;
- account administration;
- client relationship management;
- to allow the registration and identification of Users with INVESTSET Platforms;
- in the analysis of the request to act as a User, within the scope of INVESTSET Platforms in measures deemed necessary or recommended by INVESTSET for the constant improvement of the functionalities of INVESTSET Platforms and actions carried out for the provision of services through INVESTSET Platforms, as well as to better understand the needs of Users;
- in notification of Users regarding changes in INVESTSET Platforms and/or services, as well as compliance with the obligations under the law and assumed in the context of access and use to INVESTSET Platforms;
- In the reporting of operations, storage of information, data, communications and others actions related to the access and use of INVESTSET Platforms and use of services.
The “legitimate interests” of INVESTSET referred to above are:
- the processing purposes described in points (iii) to (v) of the above paragraph of this clause;
- the provision of the proof, in the event of a dispute, of a transaction or any commercial communication as well as in connection with any proposed purchase, merger or acquisition of any part of INVESTSET’s business;
- compliance with foreign laws and regulations and/or any order of a foreign court, government, supervisory, regulatory or tax authority;
- risk management, and
- exercising the business of INVESTSET in accordance with reasonable market standards.
6.3 Statements, testimonials and/or comments
USERS ARE ALSO INFORMED THAT INVESTSET USES, COLLECTS, REPRODUCES, MAKES AVAILABLE, TRANSMITS, SHARES, TRANSLATES INTO OTHER LANGUAGES, INSERTS IN OTHER MATERIALS (INCLUDING, WITHOUT LIMITING, ON ITS WEBSITE, IN VIDEOS AND ADVERTISING MATERIALS) FOR ANY PURPOSES, INCLUDING FOR COMMERCIAL, ADVERTISING AND INSTITUTIONAL PURPOSES, ANY STATEMENTS, TESTIMONIALS OR COMMENTS OF USERS, IN WHOLE OR IN PART, RELATED TO INVESTSET PLATFORMS AND/OR SERVICES IN SPECIFIC RESOURCES.
MAKES AVAILABLE FOR SUCH PURPOSES ON OUR PLATFORMS SENT BY EMAIL, TEXT MESSAGE, OR POSTED ON SOCIAL NETWORKS, SUCH AS FACEBOOK, TWITTER, INSTAGRAM, YOUTUBE AND OTHERS. USERS FURTHER ACKNOWLEDGE THAT WE MAY USE ANY SUCH STATEMENTS, TESTIMONIALS OR COMMENTS IN ASSOCIATION WITH THEIR FULL NAME AND SOCIAL MEDIA PROFILE PHOTOGRAPHY.
7. Data sharing
- Companies of the INVESTSET group, investors, commercial partners, partner banks, agents and/or service providers, in any country, of INVESTSET, for the purposes of maintaining INVESTSET Platforms, providing services to INVESTSET and/or in the case of other necessary steps.
- Auditors, legal advisors of INVESTSET.
- Government authorities and/or courts that may require us to disclose, by law or court order, all or any part of the information.
- Any other third parties to whom we are obliged to share the Information due to legal and regulatory obligations and/or whose disclosure of the Information is necessary for the proper, effective and efficient operation of the INVESTSET Platforms and its functionalities, as well as for the provision of the services.
- We may employ other companies and persons (“Agents”) to perform tasks on our behalf and therefore may need to share Information from Users of INVESTSET Platforms with such Agents so that we may allow Users to access and use the INVESTSET Platforms and/or contract the Services. Agents have no right to use the Information we share with them other than necessary to assist us in their tasks, and/or to properly, effectively and efficiently operate the Platforms and their functionalities.
The Recipients may, under their own responsibility, disclose the Information to their agents and/or delegates (the “Sub-Recipients”), which shall process the Information for the sole purposes of assisting the Recipients in providing their services to INVESTSET and/or assisting the Recipients in fulfilling their own legal obligations.
The Recipients and Sub-Recipients may be located either inside or outside the European Economic Area (the “EEA”). Where the Recipients are located outside the EEA in a country which does not ensure an adequate level of protection for personal data or does not benefit from an adequacy decision of the European Commission, INVESTSET and the Recipients have respectively entered into legally binding transfer agreements with the relevant Recipients and Sub-Recipients in the form of the European Commission approved model clauses. In this respect, Users have a right to request copies of the relevant document for enabling the Information transfer(s) towards such countries by writing to INVESTSET at the following address firstname.lastname@example.org.
The Recipients and Sub-Recipients may, as the case may be, process the Information as data processors (when processing the Information on behalf and upon instructions of INVESTSET and/or the Recipients), or as distinct data controllers (when processing the Information for their own purposes, namely fulfilling their own legal obligations).
The Information may also be transferred to third-parties such as governmental or regulatory agencies, including tax authorities, in accordance with applicable laws and regulations. In particular, Information may be disclosed to the Luxembourg tax authorities, which in turn may acting as data controller, disclose the same to foreign tax authorities.
8. General provisions
8.1 INVESTSET protection
8.3.1 The user account on the INVESTSET Platforms is protected by a personal and non-transferable password, which exists for the privacy and security of Users. The User shall prevent unauthorized access to his/her account and information by selecting and protecting his/her password, and by limiting access to his/her computer or device and browser, and it is up to the User in question to disconnect from the INVESTSET Platforms after completing access to his/her account and using the INVESTSET Platforms.
8.3.2 The user account access password on INVESTSET Platforms is stored in our databases using the most modern forms of encryption and, to ensure your security, no one has access to such databases. This MEANS THAT INVESTSET WILL NEVER REQUEST PASSWORD ACCESS TO THE ACCOUNTS OF USERS KEPT ON INVESTSET PLATFORMS BY E-MAIL OR TELEPHONE.
8.3.3 If a User has any reason to believe or suspect that any third party has had access to their user account access password, please contact email@example.com.
8.3.4 We will endeavor to protect the privacy of our Users and other information we store in our records. Unauthorized access or use, hardware or software failure, and other factors may compromise the security of user information at any time. THEREFORE THE TRANSMISSION OF INFORMATION OVER THE INTERNET IS NOT COMPLETELY SAFE BY SEVERAL FACTORS, INCLUDING NETWORK AND OPERATING FACTORS.
8.4 Data retention
9. Users’ rights
In accordance with the conditions laid down by the Data Protection Laws, Users acknowledge their rights to:
- access their Information;
- correct their Information where it is inaccurate or incomplete;
- object to the processing of their Information;
- restrict the use of their Information;
- ask for erasure of their Information;
- ask for Information portability.
Users may exercise their above rights by writing to INVESTSET at the following address: firstname.lastname@example.org.
Users also acknowledge the existence of their right to lodge a complaint with the Commission Nationale pour la Protection des Données (the “CNPD”) at the following address: 15, Boulevard du Jazz, L-4370 Belvaux, Grand-Duchy of Luxembourg; or with any competent data protection supervisory authority of their EU Member State of residence.
Confirmation of understanding and acceptance