1.1. We are Scalable Capital Limited (referred to as “we” or “us” or “our”). Scalable Capital Limited’s registered address is at 4 Christopher Street, London, EC2A 2BS and its registration number is 9386303. Scalable Capital Limited is committed to protecting and respecting your privacy. For the purposes of the Data Protection Act 1998, we are the data controller and we are registered with the Information Commissioner’s Office (registration number: ZA106483).
We have appointed an external data protection officer (DPO). His contact details are as follows:
Data Protection Officer
Mr Helge Kauert
dataLEGAL Rechtsanwaltsgesellschaft mbH
Oskar-von Miller-Ring 33
80333 Munich, Germany
2.1. You can browse this Website as a Guest without giving us any information, and we won’t know who you are. However, even if you are a guest, please bear in mind that we may:
2.2. We collect the information above by using cookies. Please see below for details on cookies.
3.1. Additional services are available once you register with us and login to the Website. In this case, we will know who you are, your activities on the Website and information about your computer may be linked to you on our systems. We will also store any data you upload to the Website (for example documents required for identification verification purposes).
3.2. The types of information we may request are, inter alia:
3.3. If you give us false or inaccurate information, either directly or through an agent, and we suspect or identify fraud, we will record this. In addition, we may search at fraud prevention agencies for information on you as part of our due diligence to ensure that we comply with ‘know your customer’ regulations and anti-money laundering legislation.
3.4. We may retain copies of any correspondence you send us, details of your registration history and any materials you post on the Website.
4.1. The main reason we use this information is to provide you with both an improved website experience and details about our services.
4.2. We (or third party data processors, agents and subcontractors acting on our behalf) may also use the information:
5.1. We collect information from our Investors for the purposes of contract initiation, performance and termination as well as provision of our services.
5.2. We may use this information in particular:
6.1. Winterflood Services Limited (“Winterflood”) will provide dealing and custody services to Investors who enter into a discretionary investment management agreement with us. We may disclose your personal information to Winterflood (together with any of our associates or third parties performing services on our behalf) for any of the above purposes.
6.2. We may share your personal information with companies and other third parties performing services on our behalf who will only use the information to provide that service. We may also share your personal information with other members of our corporate group, or a purchaser or potential purchaser of our business.
7.1. We will provide you with our newsletter, information on our services and/or other marketing-related notices via email (together “Notices”), if you have provided your prior consent. To this end, we make use of the online mailing service MailChimp. You will receive a confirmation email with regard to your registration. MailChimp enables us to analyse the use of the Notices.
7.2. If you decide at any time that you no longer wish to receive the Notices, please contact us by email at email@example.com or unsubscribe using the relevant link provided in the individual Notices. We will always give you an opportunity to unsubscribe from receiving any Notices.
8.1. You may request details of personal information which we hold about you under the Data Protection Act 1998. If you would like a copy of the information held on you please contact us by email at firstname.lastname@example.org. Any access request may be subject to a small fee to meet our costs in providing you with details of the information we hold about you.
8.2. If you think any information we have about you is incorrect or incomplete, please email us at email@example.com as soon as possible. We will correct, delete or update any information as soon as possible.
9.1. We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. 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 transmitted to our Website; any transmission is at your own risk.
9.2. The personal data submitted by Investors is safely stored and encrypted in a data centre located in Ireland and, thus, is subject to European data protection standards.
9.3. We may link to other websites which are not within our control. Once you have left our Website, we cannot be responsible for the content of other websites or for the protection and privacy of any information which you provide on these websites. Please note that these websites have their own privacy policies and website terms and conditions.
10.2. Types of Cookies
10.3. What Cookies do we use?
10.3.1. Strictly Necessary
These Cookies are essential to enable you to receive a service on a website. For example, Cookies to operate online shopping baskets, do your internet banking or to comply with the law (e.g. such as to keep your information safe). We would not be able to operate our Website without using the “strictly necessary” Cookies. These include in particular:
These Cookies collect information about how visitors use a website, for instance, which pages visitors go to most often and if they get error messages from web pages. These Cookies do not collect information that identifies a visitor; all information collected by these cookies is anonymous. We only use such information to improve our services and our Website.
10.3.3. Functionality & Profile
These Cookies allow the website to remember choices you make (such as your login details) and custom preference settings (e.g. text size). They also enable enhanced, more personal features, e.g. a website may be able to provide you with local weather reports or traffic news by using a Cookie to remember which region you are in. These Cookies are also used to provide services you have asked for such as watching a video. Information collected by “functionality” Cookies may or may not be anonymised, but they cannot track your browsing activity on other websites. The “functionality” Cookies on our Website only collect anonymous information. These Cookies include in particular:
10.3.4. Targeting, Conversion Tracking and Analysis
These Cookies collect information about your browsing habits and actions such as links clicked, mouse movements or any non-sensitive text entered on our Website. This allows us to make advertising relevant to you and your interests and also to improve the usability and customer experience of our Website. These Cookies collect the most information about users and may be placed by third parties who will be sent the information collected. These Cookies include in particular:
10.4. Blocking and Deleting Cookies
Updated: 20. June 2017