Privacy Policy

1. INTRODUCTION

Propelle (Network) Ltd (“we”, “us”, or “our”) is committed to protecting and respecting your privacy and Personal Data. 

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will also tell you about your privacy rights in relation to this data. Personal Data is data, or a combination of pieces of data, that could reasonably allow you to be identified.

This Privacy Policy applies to Personal Data we collect or process about our customers that use our services via our platform (the “Platform”).

We may be required by law to collect certain Personal Data about you, or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfilment of these obligations. 

2. WHAT DATA DO WE COLLECT

We will collect personal information about you from a variety of sources, including information we collect from you directly (e.g. when you contact us, or register with us to use our services), and information we collect about you from service providers and business partners that perform business operations for us, such as due diligence platforms verifying your identity for anti-money laundering compliance.

The categories of Personal Data that we collect directly from you are:  

• Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth, national insurance number, citizenship, tax residency, along with user credentials when you create an account to use our Platform.
• Contact Data: This is data relating to your phone number, postal address, and email address.
• Marketing and communication preferences: your preferences for receiving marketing communications from us and any third parties, as well as your communication preferences.
• Usage Data: This is data we collect from you in connection with your usage of the Platform, including data collected about the browser you use and your user behaviour.
• Financial Data: This is data relating to your payment/billing information, where you purchase any of our services and also any investments you make with any third party providers to whom we make introductions or have links to their services on our Platform.
• Occupational information: your salary, job occupation, and other investment-related data such as information you give us about your risk profile, savings, desired return and period of investment.
• Technical information: your IP address, browser type, time zone setting, and other technical data related to your visit to our website or use of our web application.

We collect information about you from AML/KYC or due diligence providers and from the third party advisors and investment platforms we introduce you to. 

The categories of information that we collect about you from other sources include the following: 

• Profile/Identity Data: This is data relating to your first name, last name, and date of birth.
• Contact Data: This is data relating to your phone number, postal address, and email address.
• Verification information: This includes, where permitted by local law, background check information (e.g. information to ensure that the customer is validated and in compliance with anti-money laundering regulation). 
• Investment information: This includes the funds you have invested in, the amounts and the returns on your investments.

Special categories of personal data

Some of the categories of information that we collect are special categories of personal data (also known as sensitive personal information). In particular, where required by law, we may process information about your political opinions for the purpose of our AML/KYC processes. Additionally, where you have provided your explicit consent, we may process race/ethnicity for the purpose for understanding the diversity of our customer base.

3. THE LEGAL BASIS FOR COLLECTING THAT DATA

We must have a legal basis to process your Personal Data. In most cases the legal basis will be one of the following: 

• Consent: We may obtain your consent to collect and use certain types of Personal Data when we are required to do so by law, for example, in relation to our direct marketing activities including email newsletters. If we ask for your consent to process your Personal Data, you may withdraw your consent at any time by contacting us using the details at the end of this Privacy Policy.   
• Contractual Obligations: We may require certain information from you in order to fulfil our contractual obligations and provide you with our services. 
• Legal Compliance: We’re required by law to collect and process certain types of data, such as to detect, prevent and respond to fraudulent activity or other illegal actions, or to comply with our legal obligations such as respond to legally binding requests from regulators, law enforcement authorities or other government authorities.
• Legitimate Interest: We might need to collect certain information from you to be able to meet our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. This could include understanding how you use our services to enable us to derive knowledge that enables us to develop the services. When we process Personal Data to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms. 

4. HOW WE USE YOUR PERSONAL DATA 

Our Uses

In general, we process your Personal Data for the following purposes:

• To operate and provide you with our Platform features and ensure they function
• To improve our Platform features by gathering aggregated data to enable research or analysis so that we can better understand and serve you
• To deal with your enquiries and requests 
• To contact you with marketing including through our newsletter and offers relating to our Platform features and make suggestions and recommendations to you about goods or services that may be of interest to you
• To prevent and detect against fraud and other malicious use of our platform and to protect your security
• To comply with legal and regulatory obligations to which we are subject and cooperate with regulators and law enforcement bodies

Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to the section above for more information on the lawful basis listed in the table below. 

Activity:	When a user signs up to the Platform for the first time and creates and uses an account
Type of Data:	Profile/Identity Data, Contact Data, Marketing and Communications Data, Financial Data, Investment Information
Lawful Basis for processing data:	See above
Contractual Obligation:	In order to use our Platform you need to contract with us under our Terms and Conditions and so certain data is necessary to perform the contract between us
Legitimate Interest:	We need to understand where you are logging in from so we know whether you can take advantage of our Platform features, and what browser you are using so we can understand our customer demographic to help diagnose service provision issues, to keep our records up-to-date and analyse how customers use our Platform features. We need to process this data so that we have records of who is using the Platform, build a user profile which the users can log into and maintain records of their progress on the Platform

Activity:	While using the Platform, we track usage data within the Platform, including user behaviour inside the Platform, product interactions and attributions.
Type of Data:	Usage Data
Lawful Basis for processing data:	See above
Legitimate Interest:	For the product to function correctly, we require this data to assess Platform functionality and analytics

Marketing and Content Updates

You may receive marketing and new content communications from us if you have created an account and not opted out of receiving those communications (or, where necessary, when you have provided your consent). From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you. 

You can ask us to stop sending you marketing messages at any time by unsubscribing at the bottom of our emails.

5. YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

You have certain rights regarding your Personal Data, subject to local law. These include the following rights:

• access your Personal Data
• rectify the Personal Data we hold about you
• erase your Personal Data
• restrict our use of your Personal Data 
• object to our use of your Personal Data 
• receive your Personal Data in a usable electronic format and transmit it to a third party (right to data portability)
• lodge a complaint with your local data protection authority
• withdraw your consent at any time

If you would like to discuss or exercise such rights, please contact us at the details below.

We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We encourage you to contact us to update or correct your information if it changes or if the Personal Data we hold about you is inaccurate. 

How We Protect Customers’ Personal Data

We are committed to keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems, including implementing certain security measures, such as encrypting passwords for users of the Platform. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. However, no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Propelle to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

6. YOUR DATA AND THIRD PARTIES

We may share Personal Data with third parties under the following circumstances:

• We may share your Personal Data with our service providers, subcontractors and business partners/affiliates, for example where they facilitate us in providing our services). For example, we may partner with other companies for analytics services, data storage/hosting, customer communications, advertising (including through Facebook and Google), back-office constructions, web services, and to facilitate the transfer of funds from your current account to our partner account.
• We may share your name, address, date of birth, and KYC results with RiskSave Technologies Ltd who assist us with some KYC checks. In addition, where we need to assess whether you have broken our community guidelines, we share your name and the relevant messages with them to obtain advice on how to resolve the matter. They will process your Personal Data in accordance with their Privacy Notice. 
• We share your Profile Data, Contact Data, Financial Information and Occupational Information with WealthKernel Limited who assist us with Know Your Client checks, fraud monitoring and other regulatory obligations that we are required to abide by to provide the services to you. When WealthKernel processes your Personal Data for the purposes of trading, settlement and custody services please read the WealthKernel Privacy Policy. For other services, this Propelle Privacy Policy applies. 
• We may share your name and identification document with Simple Crowdfunding where you invest in products through them. Please see the Simple Crowdfunding Privacy Policy for information about how they process your Personal Data.
• If we introduce you to third party investment platforms and advisors we will ask for your consent ahead of sharing the Personal Data that is necessary for that introduction and, where applicable, to display details about your investment on our Platform. Such third parties may include: mortgage brokers, accountants, tax advisers, pension advisers, financial coaches and financial advisers. 
• We may also share Personal Data with interested parties in the event that Propelle (Network) Ltd anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology. If Propelle (Network) Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your Personal Data uses it in a manner that is consistent with this Privacy Policy.
• We may share your Personal Data at any time if required for a legal reason, including to comply with legal or regulatory obligations, or to protect our rights or the rights of any third party, or otherwise in order to enforce our terms or this Privacy Policy.

Third-Party Links

Our Platform may include links to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy policy of every website you visit.

​7. RETENTION OF YOUR DATA

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. Once our relationship with you has come to an end, we will retain your Personal Data for a period that enables us to:

• Maintain business records for analysis and/or audit purposes
• Deal with any complaints 
• Defend or bring existing or potential legal claims in respect of our relationship with you
• Comply with record retention requirements under the law
• Enforce our commercial agreements

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

9. OPTIONS REGARDING YOUR INFORMATION

Account information

You may at any time review, access or change the information in your account by logging into your account settings and updating your account.

You may delete your account at any time. To terminate your account, please contact Propelle at support@propelle.io. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms and Conditions and/or comply with legal requirements.

Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and Personal Data by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.

Emails and Communications

If you no longer wish to receive correspondence, emails or other communications from us, you may opt-out by noting your preferences at the time you register your account on the Platform, logging into your account settings and updating your preferences or contacting Propelle at support@propelle.io.

10. INTERNATIONAL DATA TRANSFERS

Your Personal Data may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for Personal Data under applicable data protection laws. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.

11. CONTACT US 

Propelle (Network) Ltd is the controller responsible for the Personal Data collected and processed. 

If you have any inquiries or concerns about the way in which your data has been used or any questions about this Privacy Policy, please contact us at:

Propelle (Network) Ltd

Office 9, Dalton House

60 Windsor Avenue

London

SW19 2RR

Email: support@propelle.io

We are registered as a Data Controller with the Information Commissioner’s Office (ICO) in the United Kingdom (registration number: ZB532566) and are compliant with the United Kingdom General Data Protection Regulation (UK GDPR) and all relevant data protection legislation. You have the right to make a complaint at any time to your local data protection authority, which in the UK is the Information Commissioner’s Office (ICO). We would, however, appreciate the chance to deal with your concerns or complaints before you approach the ICO, and would be grateful if you could contact us in the first instance.

​12. NOTIFICATION OF CHANGES 

We keep our Privacy Policy under review and will place any updates on this page. 

If we change this privacy notice, we will notify you of the changes. Where changes to this privacy notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. to object to the processing).

This version is dated 13 March 2024.

Cookie Policy

This is the Cookie Policy for Propelle, accessible from https://propelle.io, operated by Propelle Ltd.

What Are Cookies

As is common practice with almost all professional websites, this site uses cookies and other device identifying technologies (“Cookies”), to provide our website, understand how our website is used, and for advertising purposes as explained in our Privacy Policy. Cookies are tiny files that are downloaded to your computer, to improve your experience. This page describes what information they gather, how we use it, and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored.

How We Use Cookies

We use cookies for a variety of reasons detailed below. 

Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser’s Help page for how to do this). Be aware that disabling cookies may affect the functionality of this and other websites that you visit.

The Cookies We Set

• Google Analytics: This site uses Google Analytics which is one of the most widespread  analytics solutions on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page.
• WordPress: This site is built using WordPress, which uses cookies to allow you to recognize you when you log in. For more information on WordPress cookies, see the official WordPress documentation.

Third Party Cookies

In some cases, we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.

• Google Analytics: We use Google Analytics to help us analyze website traffic. For more information on Google Analytics cookies, see the official Google Analytics page.

More Information

If you are still looking for more information, you can contact us through one of our preferred contact methods:

Email: support@propelle.io

Postal mail: Propelle (Network) Ltd, Office 9, Dalton House, 60 Windsor Avenue, London, SW19 2RR, United Kingdom.

Alternatively, you can visit the Information Commissioner’s Office (ICO) website to learn more about cookies and how they affect your online privacy.