This Privacy Policy sets out how Primetracoid (“we”, “our” or “us”) collects, uses and protects your personal information, including that obtained through our website. Personal information is information which identifies you or another person, or which is capable of doing so.

Key Points

Primetracoid is the data controller of personal information processed through your use of our website or services or that we otherwise obtain for the purposes of marketing our services.

The type and nature of the personal information processed by us includes data relating to the use of our website, data relating to the services that we provided to investors and/or advisers, data relating to contracts that we enter into and data related to our correspondence with you.

We use your data to provide you services, perform background checks in order to perform our services, analyze the performance of our services, perform a contract with you, provide our site, respond to queries, and for business development purposes.

We may send you marketing materials relating to our services which you can opt out of at any time.

You have a number of rights that you may exercise in relation to our use of your personal data, and you may exercise these by contacting us through the communication methods set out in the ‘Contact’ section below.

About Primetracoid and this Privacy Policy

Primetracoid is the trading name regulated by the Financial Conduct Authority (FCA), and (b) registered in Canada as a Limited Liability Company.

Primetracoid is the data controller for the purposes of data protection legislation and is subject to the jurisdiction of the Information Commissioner’s Office (ICO) in the UK.

We are committed to maintaining the privacy and security of the information you provide to us, and the choices you have regarding our collection and use of your information. This Privacy Policy applies to information we collect about you through our website and when you otherwise communicate with us. We will only process personal information you provide to us in accordance with applicable data protection laws.

If you have any questions about this Privacy Policy or our use of your personal information you can contact us.

This Privacy Policy may change from time to time and, if it does, the latest version will be available on our website (and, where appropriate, brought to your attention). This privacy policy was last updated on November 2020.

Information we collect from you

We collect and process the following data about you:

Information that you provide by filling in forms on the website or via our web portal. This includes information provided at the time of registering to use our site, or requesting further services, as well as your continued use of the site and our web portal. We may also ask you for information when you report a problem with our site (“Website Data”).

Information from application forms, contracts or other correspondence relating to our products, such as your name, age, date of birth, gender, postal address, email address, phone number, nationality, national insurance/tax number, FCA/LEI number (if you are an adviser) (“Contract Data”). Where you act as an investor, we may receive your Contract Data via a financial adviser.

Uses made of your information

Our uses of your information, and the lawful grounds on which we process your data under data protection laws, will depend on who you are:

If you are a general user of our website or web portal (or any other online services that we provide), we use your information as follows:

We use Website Data, Technical Data, Cookie Data on the basis of our legitimate interest:

to customize our website or web portal or other online services according to your interests – we have a legitimate interests to use data about how you use the site to tailor it to you and to other similar users;

to administer the website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey responses – we have a legitimate interest to use user data in order to assess which parts of our online services are functioning best so that we can provide services which are useful to you;

as part of our efforts to keep the website safe and secure – we have a legitimate interest to ensure that the security of our online services are maintained, for the benefit of all users as well as for us as a business; and

We collect, store and use Website Data and Correspondence Data insofar as it is necessary in order for us to provide you with access to our website and our services (i.e. where it is necessary for performance of a contract) in order to:

respond to any query that you may submit to us; and

provide any online service which we agree to provide to you.

If you are an investor who we are providing our services for, we use your information as follows:

We use Contract Data, Website Data, Correspondence Data and on the basis of our legitimate interest:

to assess the performance of your investment – we have a legitimate interest to see how your portfolio is performing in order to better understand which types of investments to engage with for our entire investor base;

to analyze the suitability of, and to improve, our services – we have a legitimate interest to assess whether our products are suitable for our investor and adviser base and to analyze how they can be improved; and

to notify you about changes to our services – we have a legitimate interest to let you know about any changes to our services which are likely to impact on the products and services that we are providing to you.

We collect, store and use Contract Data, Website Data and Correspondence Data insofar as it is necessary for performance of a contract in relation to:

our provision of our website and web portal to you;

any investment contracts entered into by you with us;

our performance of advisory or other contracts entered into between you and us; and

manage or administer your investment and provision of related services.

We collect, store and use Contract Data insofar as it is necessary in order for us to comply with our legal obligations for:

know-your-client purposes before a contract is entered into with you;

compliance with anti-money laundering, tax and other legal requirements related to the services that we provide to you; and

compliance with a request pursuant to any law, regulatory or governmental body or law enforcement agency.

If you are an adviser (e.g. acting on behalf of an investor or prospective investor) or a commercial counter party that we interact with in the course of our business or services, we use your information as follows:

We use Contract Data, Website Data, Correspondence Data, Business Development Data on the basis of our legitimate interest:

to assess the performance of investments which you have helped to arrange – we have a legitimate interest to see how portfolios which you are involved with are performing in order to better understand which types of investments to engage with for our entire investor base;

to analyze and improve our products – we have a legitimate interest to assess whether our products are suitable for our investor and adviser base and to analyze how they can be improved;

to engage with you, for example by sending direct marketing in relation to industry updates or new products which we think may be of interest to you, by post, telephone or email – we have a legitimate interest to communicate with you about products or services which we think that you might be interested in, as long as you have not opted-out of receiving such communications; and

to notify you about changes to our service – we have a legitimate interest to let you know about any changes to our services which are likely to impact on the products and services that we are providing to you or the investors that you act for.

We collect, store and use Contract Data, Website Data and Correspondence Data insofar as it is necessary in order for us to provide you with access to our website and our services (i.e. where it is necessary for performance of a contract) in order to carry out our obligations arising from any contracts entered into between you and us.

We collect, store and use Contract Data insofar as it is necessary in order for us to comply with our legal obligations for:

know-your-client purposes before a contract is entered into with you;

compliance with anti-money laundering, tax and other legal requirements related to the services that we provide to you; and

compliance with a request pursuant to any law, regulatory or governmental body or law enforcement agency.

Where we store your information

The data that we collect from, or about you may be transferred to, and stored at, a destination outside the European Economic Area (EEA) including in the Channel Islands. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the provision of support services. Please be aware that, while countries which are outside the EEA may not offer the same level of data protection as the United Kingdom, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy, including entering into European Commission-approved standard contractual clauses or, where applicable, transferring to an entity which is Privacy Shield certified.

All information you provide to us 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 site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data while it is being transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Disclosure of your information

We may share your Personal Information with any member of our group, which means our subsidiaries, our ultimate parent entity and its subsidiaries.

When we share your information with third parties they will process your information as either a data controller or as our data processor and this will depend on the purposes of our sharing your personal information. We will only share your personal information in compliance with the applicable data protection legislation.