Who we are
INVESTSET’s website and platforms (together, the “INVESTSET Platforms”) constitute a service offered by Keyword FinancialTech SARL, headquartered at 9 Rue du Laboratoire,L-1911, Luxembourg, and any personal data processed on INVESTSET Platforms should be deemed to be processed by Keyword FinancialTech SARL acting as data controller (“INVESTSET”, “we” or “our”) in accordance with EU Regulation n°2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the âGDPRâ) and any applicable national data protection laws (including but not limited to the Luxembourg law of 1st August 2018 organizing the National Commission for data protection and the general system on data protection, as amended from time to time) (collectively hereinafter the âData Protection Lawsâ). This privacy policy (the âPrivacy Policyâ), together with the Platform Terms of Use, describe the terms and conditions applicable to your access to and use of the INVESTSET Platforms.
1. INVESTSET’s commitment to user privacy
1.1. This privacy policy (“Policy”) provides for information about the processing of personal information, or other information such as: the kind of personal data we processed about you, how we may disclose your information, your right to access, correct, update and delete your personal information (“Information”), among others provided by users (“User(s)”, “you”, “your”, “your”) when browsing, accessing and/or using the INVESTSET Platforms. Information as to the cookies used can be find in our Cookie Policy.
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.
Although the environment of INVESTSET Platforms is subject to monitoring for security reasons, INVESTSET will not edit or disclose Information of its Users, except in lawful cases expressly provided for under this Privacy Policy or unless INVESTSET is required to do so by court order or by law.
1.4. We do not collect or knowingly request information from minors under the age of 18.
1.5 INVESTSET will use its best efforts to protect your privacy. This Privacy Policy explains how INVESTSET uses and protects the information it collects and applies to any personal information you provide to INVESTSET.
1.6 INVESTSET may modify this Privacy Policy at any time. In the event of material changes to the Privacy Policy, INVESTSET undertakes to inform users of INVESTSET Platforms about such changes by means of notice on the INVESTSET Platforms, five (5) days prior to making such change. For your convenience, the date of the last revision is included in this Privacy Policy. Therefore, we invite Users to always access the Privacy Policy when using INVESTSET Platform.
1.7 In cases where Users do not agree with the new Privacy Policy, Users of INVESTSET Platforms may refuse to provide INVESTSET with their Information at no charge. In this event however, Users will no longer be able to use the INVESTSET Platforms.
2. Storage, use and protection of Users’ information
2.1 INVESTSET protects the privacy rights of Users who register or in any way browse, access or use the INVESTSET Platforms and/or use services through the INVESTSET Platforms, in accordance with the Data Protection Laws and in accordance with the provisions of this Privacy Policy.
2.2 INVESTSET is committed to the security and privacy of Users of INVESTSET Platforms throughout the process of navigation and contracting of products and services through INVESTSET platforms. Therefore, user Information is kept confidential, not being sold, exchanged or disclosed to any third party, except in the assumptions expressly set forth in this Privacy Policy.
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.
- Navigation information (collected through cookies â see our cookie policy below): information about the User’s mobile phone/smartphone, Internet Protocol address (IP address), browser type used, operating system version, reference source, duration of visit on INVESTSET Platforms, page views, page browsing paths, internet band, operator, page view behavior, geolocation and pages visited.
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 support@investset.com. 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: support@investset.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
By accepting this Privacy Policy, you are aware that the Information collected upon access to or use of the INVESTSET Platforms may be transferred and stored in a destination outside Europe, including in countries that are not deemed by the EU Commission to provide an adequate level of protection to personal data, such as Brazil, to the extent permitted by law (as further detailed under section 7 below). In addition, you are aware that by accessing, using the INVESTSET Platforms and sending us your Information, INVESTSET will be downloading, storing, processing and using your Information in the format set out in this Privacy Policy. We take all reasonable care to ensure that your Information is handled securely and in accordance with the Data Protection Laws and this Privacy Policy.
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.
6.2 In particular, the Information of Users of INVESTSET Platforms will be used for the purposes set out in this Privacy Policy, either to:
- 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 âlegitimate interestsâ 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 INVESTSETâs 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
USERS IS EXPRESSLY AND UNEQUIVOCALLY INFORMED THAT INVESTSET WILL GRANT ACCESS AND SHARE THEIR INFORMATION WITH SELECTED THIRD PARTIES (âRecipientsâ), AS LISTED BELOW, SO THAT THE PURPOSES DESCRIBED IN THIS PRIVACY POLICY ARE OBTAINED:
- 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 âSub-Recipientsâ), 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 âEEAâ). 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 support@investset.com.
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
8.1.1. We reserve the right to store, access, read, preserve and disclose any information we believe is necessary to comply with law or court order to the extent required by applicable laws and regulations, this Privacy Policy and any other agreements, or terms with which Users have agreed, as well as to protect the rights, property or security of INVESTSET, INVESTSET Platforms and their employees, service providers, users, customers and others.
8.3 Security
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 support@investset.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
In accordance with our record-keeping obligations and in accordance with the purposes described in this Privacy Policy, we will not retain your Information for periods longer than those required for the purpose of their processing subject to any limitation periods imposed by law, primarily due to any legal and regulatory obligations and protection in court defenses.
9. Usersâ 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: support@investset.com.
Users also acknowledge the existence of their right to lodge a complaint with the Commission Nationale pour la Protection des DonnĂ©es (the âCNPDâ) 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
I confirm that I have read and have been informed of the content of the terms of this Privacy Policy, regarding notably to the collection, storage, processing, sharing and use of my personal information.