Dated: 18 October 2019
Sharegain Limited (“Sharegain”, “us”, “our” or “we“) owns and operates a public website as well as our hosted products and solutions which are restricted to authorised users. We are registered with the Information Commissioner (No. ZA289509), and are authorised and regulated by the Financial Conduct Authority (No. 730395).
For the purposes of the Data Protection Act 2018 and General Data Protection Regulation (EU) 2016/679, as amended from time to time (“GDPR”), we are the data controller of any data we hold that may be used to identify you (“Personal Information”).
If, at any time, you provide data or other information about someone other than yourself, you warrant that you have that person’s consent to provide such information for the purpose specified.
1. Information you give us
We collect information from you (a) when you provide us with information through an online registration form or by corresponding with us by phone, email or otherwise. This includes, but is not limited to, information you provide when using our website, use our services or when you report a problem with our website; (b) when you send us information for analysis, including lists of securities and transactions; (c) when you send us information in order to use our services (such as bank account details or settlement instructions); or (d) when you supply information to enable us to fulfil our regulatory or legal obligations associated with our onboarding of new clients – such as your full name, gender, address, date of birth, identification number, passports, identity card, driver’s license, social security number and/or other personal identification information.
2. Information we collect about you
3. Information we receive from a third party
We may receive information from the banks and other financial institutions you are using to manage or hold your investments.
Sharegain uses your personal details provided and information from our website for the purpose of: (a) satisfying regulatory and legal requirements; (b) providing and personalising our services to ensure that our offering is tailored to your needs and interests as much as possible; (c) as a reference tool or general resource for analysis purposes; (d) to provide you with information about current and future products and services and (e) in order to perform internal ‘Know Your Customer’ and onboarding processes. We keep your information for a reasonable period for these purposes.
Should you ever deactivate your account with us, we will keep your information on file, but only use it to:
We may use the information you provide us to send you SMS or email communications for you to view.
We may share your Personal Information with any member of our group, which means our subsidiaries and affiliates. We may need to share your information with our service providers, agents and trading counterparts. Generally, we require that third party organisations who handle or obtain Personal Information acknowledge its confidentiality and undertake to respect an individual’s right to privacy and comply with Data Protection Principles and the GDPR requirements.
We do not disclose or share information about any of our users (whether active or inactive) to any affiliated third parties or non-affiliated third parties other than in the manner and to the entities set forth below:
Our website uses Google Analytics. To learn how Google uses your data and how you can opt out click here: https://www.google.com/policies/privacy/partners/
We are committed to protecting the security of your Personal Information. We use a variety of industry-standard security technologies and procedures that comply with the relevant laws and regulations to help protect your Personal Information from unauthorised access, use, or disclosure. Our cloud-based solution is hosted in highly secure data centres in the European Economic Area (EEA), and adheres to the highest standards of the industry. All communications are encrypted over SSL layer, data is backed up on a regular basis and encrypted at rest. In addition, access to our application layer is secured by Web Application Firewall (WAF) following OWASP core rule sets 3.0, and user communications require Multi Factor Authentication (MFA). Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or products, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We have also implemented physical and managerial procedures in order to help safeguard and prevent unauthorised access, use, alteration, modification and/or disclosure of your Personal Information. We restrict access to your Personal Information to those employees of Sharegain who have a business reason for accessing such information. We continuously educate and train our employees about the importance of confidentiality and privacy of customer information.
Although we use reasonable efforts to safeguard the security of your Personal Information, no method of transmission over the Internet or method of electronic storage is 100% secure. Also, any information you provide to us via email or by post is not protected by encryption and is vulnerable to interception during transmission. Therefore, we cannot guarantee the absolute security of your Personal Information and cannot accept responsibility for any misuse, loss, or alteration of information by third parties who, despite our efforts, obtain unauthorised access.
Your Personal Information will be stored by us for any varying duration to comply with our contractual, legal and regulatory obligations or to establish, exercise or defend our legal rights and claims.
Depending on applicable laws, you may have the right to access information held about you. Your right of access can be exercised in accordance with the relevant data protection legislation. Any access request will be free – unless the request is manifestly unfounded or excessive. We similarly have the right to refuse an access request on the same grounds. To obtain a copy of the Personal Information we hold about you, please write to us at our business address (provided at the bottom of this web page) or send us an email to: firstname.lastname@example.org. Information on the GDPR is also on the Information Commissioner’s website at http://www.ico.org.uk.
If you have provided your personal details to us and you wish to change your preferences please inform us at the email or address provided above.
You have the right to revoke any former consent. Likewise, the erasure or deletion of any personal data we have collected. For such requests, please also use the contact details above.
Sharegain can refuse to erase personal data on the following basis:
Alternatively, you may opt-out of receiving additional information from Sharegain or related 3rd parties at any time by sending us an email to email@example.com , by calling us on (+44 (0)20 3884 2401) or by writing to us at our business address provided at the bottom of this web page.
All other requests concerning your Personal Information or any queries with regard to these practices please contact us at firstname.lastname@example.org.
We do not intentionally gather Personal Information about individuals who are under the age of 18. If you become aware that we inadvertently hold or have access to Personal Information about anyone under 18, please let us know email@example.com so we can delete it from our files.
With securities lending, as with other investment activities, your capital may be at risk.
Sharegain Ltd. is registered in England and Wales (no. 09600298) and is authorised and regulated by the Financial Conduct Authority (no. 730395).
*This website is directed exclusively at and intended to be used only by professional investors and retail investors with direct holdings in stocks, bonds and ETFs in excess of £500,000. Our website is not directed at any person or institution where (by reason of nationality, residence or otherwise) the availability of our website or securities lending in general is prohibited. The material on this website is for general information and should not be considered as investment advice or solicitation to be involved in securities lending or to use one of Sharegain’s services. Securities lending involves risks and we have not and will not assess whether our service is appropriate for you. If you decide to lend your securities, your capital may be at risk. Please consult professional advisors if you are in any doubt as to whether the service would be beneficial for you or whether you require any consent or need to observe any formalities, before deciding to engage in securities lending.
© Copyright 2019 Sharegain Ltd
+44 (0) 20 3884 2405 firstname.lastname@example.org 9 Dallington St, London EC1V 0LN