WEBSITE PRIVACY, COOKIE AND DATA USE POLICY

Date last revised: 22nd May 2018

PLEASE READ THIS POLICY CAREFULLY BEFORE REGISTERING FOR AN ACCOUNT WITH SIMPLE CROWDFUNDING

Simple Crowdfunding (a trading name for Focus 2020 Limited and Simple Property Ltd) (we/us/our) are committed to protecting and respecting your personal data and your privacy. We recognise that your personal data is your property and that you have provided it to us for specific purposes.

Unless otherwise required by law, the Information Commissioner’s Office (ICO) guidance or best practice, or in order to perform our contract with you, we will only process your personal data in the way we tell you or in the way you ask us to, and we will give it back to you at any time.

1. THIS POLICY

1.1  This policy, together with the Investor Terms & Conditions, explains how any personal data we collect from you, or that you provide to us, will be processed by us or any processor on our behalf.

1.2  This policy applies to our contract with you. You are therefore advised to read it carefully. Terms used within it shall have the meaning(s) given in the Data Protection Act 2018 (Act) and/or the General Data Protection Regulation (Regulation), as applicable

1.3  By visiting our website located at www.SimpleCrowdfunding.co.uk (our Website), or by registering for an account with us, you accept and consent to the practices described in this policy.

1.4  Any changes we make to this policy will be posted on this page. You are advised to check back frequently as any changes will be binding on you when you continue to use the Website after the date of the relevant change.

1.5  For more information relating to your rights under this policy, please see section 10.

1.6  If you have any queries relating to this policy, please contact Simple Crowdfunding at contact@simplecrowdfunding.co.uk

2. WHO WE ARE

2.1  We are Focus 2020 Limited and Simple Property Ltd, both of which have their registered office at 28 Spinis, Bracknell, RG12 8XA. We operate the Website and we are the data controller for the purposes of the Act and the Regulation.

2.2  We are registered with the ICO to process your personal data. The registration number of Focus 2020 Limited is ZA015199 and the registration number of Simple Property Ltd is ZA013578.

2.3  Your data will be processed on our behalf by the following:

  2.3.1  Terrasoft Global Limited, a company registered in England (number 06648693) (Bpm online), who provide Cloud services and are a data processor for the purposes of the Act and the Regulation

  2.3.2  ShareIn Limited, a company registered in Scotland (number SC408803) ( ShareIn), who host our Website and are a data processor for the purposes of the Act and the Regulation.

  2.3.3  Your data will be held on secure servers located in England and the Republic of Ireland.

  2.3.4  We operate on the terms of a written agreement with our data processors relating to your personal data.

2.4  Any payment transactions you make through our Website will be made through our approved third party payment gateway, encrypted through SSL technology. Any of your personal data they hold will be subject to their privacy policy.

3. YOUR CONSENT

3.1  By registering for Account and/or otherwise using the Website, you expressly consent to:

  3.1.1  provide us and our data controllers with the personal data necessary to allow you to use the Website and make Investments through it;

  3.1.2  the processing of your personal data by us and those specifically listed third parties, in accordance with this policy; and

  3.1.3  the transfer of your personal data to those third parties listed in this policy, for the reasons specified.

3.2  You may withdraw your consent under 3.1 at any time. However, where the withdrawal of your consent prevents us from verifying your identity or otherwise monitoring who you are, you will be unable to use your Account and make Investments through our Website OR You may exercise your rights under 3.1 at any time, which includes withdrawing your consent to our processing of your personal data. However, where this withdrawal prevents us from performing our contract with you and / or our obligations with the regulators, we may not be able to provide our goods and services to you.

4. WHAT WE COLLECT

4.1  We may collect all or some of the following categories of data from you:

 DATA CATEGORY

 TYPE OF INFORMATION COLLECTED

 Core Personal Information

 Title, full name, address (including postcode), date of birth,  nationality, email, phone number

 ID Documents

 Driving licence (including driving licence number), proof of address (such as current utility bill or bank statement)

 Financial Information

 Full bank account or credit card details

 Online Information

 IP addresses, cookies

 Demographic Information

 Investment and property experience

 Other

 Credit reference information, company information, property ownership information

4.2  Where you make an Investment or add funds to your account, you will be required to provide your passport and any associated personal data contained on that document will be retained by us or our nominated payment gateway (from time to time).

4.3  In addition to the above, we will also provide you with your Account Details, which includes your username which is either created by, or assigned to, you. The Account Details should be remembered by you, but will be stored by us in case you forget them.

5. HOW WE COLLECT YOUR DATA

The data listed in section 4 is collected in the following ways:

5.1  By you registering for an Accountthis is any information you give to us that we request from you when signing-up for an Account to use our Website.

5.2  Information collectedeach time you visit our Website, whether through your home, work or a public network, your own computer or mobile device, we will automatically collect:

  5.2.1  technical information – your IP address (used by your computer or device to connect to the internet), and any internet browser type and version details; and

  5.2.2  visit-specific information – your URLs, Projects and Properties you viewed or searched for, your clickstream through the Website.

5.3  Received from third partieswe work closely with a number of third party providers such as:

  5.3.1  our authorised payment gateway, Mangopay SA to verify your eligibility to make an Investment and any payment you wish to make.

  5.3.2  External credit reference agencies and teams

  5.3.3  Land Registry

  5.3.4  Companies House

6. COOKIES

6.1  Our Website will use the cookies listed in section 6.2 (alpha-numeric text files placed on your computer) to:

  6.1.1  distinguish you from other users;

  6.1.2  optimise your browsing experience;

  6.1.3  make necessary improvements to our Website;

  6.1.4  recognise and count the number of visitors to our Website and see how they move around the Website during use;

  6.1.5  recognise you when you return to our Website; and

  6.1.6  record your visit to our website, including any links you may follow.

6.2  The following cookies are set to our Website for the listed purposes:

 COOKIE

 PURPOSE

 ASP.Net_SessionId

 Enhances user experience by remembering session history.

 ASPXAUTH

 Records users authentication session

 _culture

 Assists recognising user’s nationality and language preferences, login, token, username recognition and encoding.

 RequestVerificationToken

 Part of a mechanism to protect against cross site scripting attacks

 ARRAffinity

 Enhances user browsing experience – part of load balancing setup

 cookie-policy

 Tracks presentation of the cookie information advice

6.3  Our Website additionally uses Google Analytics, a web analytics service provided by Google, LLC (Google). Google Analytics uses analytical, performance or targeting cookies to help analyse how you use the Website and compile reports on your activity for us.

6.4  Any information generated by the cookie about your use of the Website (including your IP address) will be transmitted to, and stored by, Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on your activity for us and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

6.5  You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this your ability to use the Website may be restricted. By using the Website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

6.6  You may refuse the use of cookies by selecting appropriate settings on your browser. However, if you do so, your ability to use the Website may be restricted.

6.7  Except for essential cookies, all cookies will expire after your session.

7. WHAT WE DO WITH YOUR DATA

7.1  Your data is primarily necessary to verify who you are when accessing your Account and to ensure you meet our eligibility requirements in order to submit an Application and make an Investment.

7.2  Additionally, we will use all of your data you provide us to notify you about:

  7.2.1  similar Projects or Properties listed on our Website that are similar to those you have already Invested in, or otherwise viewed or enquired about; or

  7.2.2  changes to our Website or our services.

7.3  We use any data we collect about you (as a result of your visit to our Website) to:

  7.3.1  personalise and improve our services (including the Website and its security);

  7.3.2  deal with your inquiries and requests;

  7.3.3  administer and monitor traffic and behaviours on our Website for analysis, troubleshooting, testing, research, statistical and survey purposes;

  7.3.4  ensure that any part of our Website (including any Content) is presented in the most effective manner for you and your computer or device, and to make improvements (where necessary); and

  7.3.5  keep our Website safe and secure.

7.4  Where we make a significant change to our services, or any applicable terms and conditions, we will contact you.

7.5  Any data we obtain about you from third parties are used for the purposes of verifying your eligibility to submit an application and to make an investment through our Website, and are acquired only to the extent we are unable to do so as a result of the information you provide to us.

7.6  Once collected, we may retain your data for up to six years following the date of your last Investment or the date you close your Account (whichever is the later). This is to enable us to refer back to any transactions or records you are involved in (should we be required to do so).

8. HOW AND WHY WE DISCLOSE YOUR DATA

8.1  Subject to the rest of part 8 of this policy, we will only disclose your personal data to the following third parties for the following purposes:

  8.1.1  the relevant fundraising Company – in connection with your Investment, details of which will be stated on your Application;

  8.1.2  our approved payment gateway – in order for you to make the payment(s) required as part of your Investment;

  8.1.3  our approved CRM provider, BP Online - in order for us to be able to send marketing communications to you.

  8.1.4  our approved transaction email provider, SendGrid, Inc - in order for us to be able to send transaction emails to you (NB only your email address is passed to SendGrid.

8.2  In addition to the transfers contemplated by part 8.1, we may transfer or disclose your personal data to:

  8.2.1  any prospective buyer of any part of the relevant business or assets in connection with the sale (in which case, any personal data held by us about you and our Account Holders will be one of the transferred assets);

  8.2.2  comply with any legal obligation (such as where stated at clause 6.5 of the Investor Terms and Conditions);

  8.2.3  enforce or apply any part of our Investor Terms and Conditions generally; or

  8.2.4  protect our rights or our property, or those of our other Account Holders.

8.3  Any websites which are linked from the Website are outside of our control and not covered by this policy. If you access those websites using the links provided, the website operators may collect information from you which will be used by them in accordance with their own privacy policies (if any). These policies may differ from ours, and we cannot accept any responsibility or liability in respect of these.

9. SECURITY

9.1  We have put in place appropriate technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable Data Protection Laws.

9.2  Each member of staff has unique log-in details and authentication software requires these to access the systems. Staff have access to personal data only for the purposes of performing their roles.

9.3  We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. YOUR RIGHTS

10.1  In relation to all of your personal data, you have the following rights to ask us (in addition to any rights you may have under the Act or the Regulation):

  10.1.1  not to process your personal data for marketing purposes;

  10.1.2  to clarify what data we hold about you, how it was obtained, to whom it has been disclosed and for how long it will be stored;

  10.1.3  to amend any inaccurate data we hold about you;

  10.1.4  to delete any of your data (where you no longer think we need to hold it or you think we have obtained it or processed it without your consent at any time); and

  10.1.5  to only process your personal data in limited circumstances or for limited purposes.

10.2  If you wish to exercise any of your rights at any time, please contact us on the details contained at the beginning of this policy in the first instance. We will require you to verify your identity to us before we provide any personal data, and reserve the right to ask you to specify the types of personal data to which your request relates.

10.3  Where you wish to exercise any of your rights, they may be subject to payment of a nominal administration fee (to cover our costs incurred in processing your request) and any clarification we may reasonably require in relation to your request. Such fees may be charged where we consider (acting reasonably) that your request is excessive, unfounded or repetitive.

10.4  Any data provided to you in accordance with your rights will be in a structured and machine-readable form.