Black Mountain Group Limited (registered company number 10740862) ("we" or "us") trading as Pionr is committed to protecting and respecting your privacy. Black Mountain Group Limited is registered in the Data protection register of the Information Commissioner’s Office, with registration number ZA455551.
This policy lets you know what personal information we collect about you, how we collect it, what we use it for and on what basis. This includes what you tell us about yourself, what we learn by having you as a customer, and the choices you give us about what marketing you want us to send you. This policy explains how we do this and tells you about your privacy rights and how the law protects you. In addition, you have the right to know what information we hold about you and to have a copy of it, and you can ask us to change or sometimes delete it.
Please read this policy carefully as it applies to the products and services we provide you.
We may collect and process the following data about you:
| Type of informtion | Description |
|---|---|
| Contact details and other information to confirm your identity |
Your name, address, email address, phone number, date of birth, log-in information and password (we never see your password as it is encrypted). |
| Nationality and national identifier | Your nationality and an identifying number or code given to you by a government i.e. your National Insurance Number. |
| Financial information | Details about financial transactions from your account to us, and your bank account and card details in order to process payments to you. |
| Financial,fact find | We are legally obliged to request information from clients, which enables us to assess if our financial products are appropriate for them.,We may confirm things like primary source of income, amount of disposable income and investment objectives. |
| Transactions | Details about the properties you have invested in via our platform. |
| Communications | Your communications with us, including emails, phone calls and webchats. |
| ‘KYC’ information | Details about you collected by us to identify and verify the identity of our customers, including a copy of your passport or identity card and a utility bill noting your home address. |
| Anti money laundering verification | As a result of money laundering regulations, we may need to verify the source of the funds which you are investing on our platform. We may therefore collect from you any of the following as evidence - a copy of your bank statement / savings account statement, payslip or completion statement from a house sale, for example. |
| Technical information | The Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. |
| Behaviour | Details about how you use our website and services, including information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. |
| Consents | Any permissions, consents or preferences that you give us, including communications that you would like to receive from us and how you would like us to contact you |
We may collect personal information:
We may also collect personal information from third parties we work with:
We are only allowed to use your personal information if we have a lawful reason for doing so. We will use your information if we can satisfy that processing it is necessary:
We use information held about you in the following ways:
| What we use your information for | Our basis for using your information |
|---|---|
| To manage our relationship with you: To understand your investment objectives, risk tolerance and form a picture of you as an investor To gauge the appropriateness of investments offered via the platform for you To carry out marketing activities To understand how our customers use our website and services To provide guidance on our website and services |
Provision of our product and services Your consent Compliance with legal and regulatory obligations Our legitimate interests – developing products and services; keeping records and contact details up to date; determining which of our services may interest you |
| To deliver our product and services to you: To report transaction activity to you To help you manage your portfolio To manage and provide investments and services To adhere to our obligations set out in agreements or contracts |
Provision of our product and services Compliance with legal and regulatory obligations Our legitimate interests - being efficient with how we fulfil our legal and contractual obligations |
| To develop our products and services: To test new products and/or services or iterations of existing products and/or services To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes To manage how we work with third parties that provide services to us |
Provision of our product and services Compliance with legal and regulatory obligations Our legitimate interests – developing products and/or services; being efficient with how we fulfil our legal and contractual obligations |
| To detect, investigate and report financial crime: To comply with laws and regulations To manage risk To monitor and prevent fraud To verify a customer’s identity To respond to and resolve complaints |
Compliance with legal and regulatory obligations Our legitimate interests – develop and improve how we deal with financial crime; being efficient with how we fulfil our legal and regulatory obligations |
| To run our business efficiently and in compliance with applicable regulatory standards: Corporate governance Financial and regulatory audits Regulatory reporting and filings Business financial and strategic planning |
Compliance with legal and regulatory obligations Our legitimate interests – develop and improve our business operations; being efficient with how we fulfil our legal and regulatory obligations |
We may share your information with any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006) and with other teams / departments within Pionr, including Finance & Compliance, Customer Services, Analytics, Marketing and Technology for the purposes described in this policy.
We may share your information with the following third parties:
If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us and with controls in place in order to protect your information.
We do not sell your data to any third parties.
We may use your personal information to provide you with information about products or services that may be of interest to you.
We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. This is where we have a business or commercial reason to use your information as long as it does not overly prejudice you.
You can ask us to stop sending you marketing messages by updating your account preferences and clicking on the ‘unsubscribe’ link that appears in all of our emails.
Irrespective of your contact preferences, you will still receive transaction statements from us, and other important information that is not marketing.
We only keep personal information for as long as reasonably necessary to fulfil the relevant purposes described in this policy and in order to comply with our legal and regulatory obligations.
Тhe information we collect is hosted on dedicated servers in Paris (France), provided by One Provider (https://oneprovider.com), and we implement technical safeguards to protect your information.
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 and any transmission is at your own risk. For example, if you access the internet via an unsecure network. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. Please do not share you login credentials with anybody.
We will only send your information outside of the EEA to:
If we do transfer information to our agents, contractors or advisers outside of the EEA, we will put appropriate safeguards in place to ensure that such information is protected in the same way as if it was being used in the EEA.
Under data protection law you have certain rights in relation to the personal information that we hold about you. You may exercise these rights at any time by contacting us using the details set out in this policy.
In certain cases, we may not be able to comply with your request for reasons such as our obligations to comply with any legal or regulatory requirements. In the event that we cannot comply with your request, we will also respond to you and tell you why.
Your rights include:
You are entitled to a copy of the personal information we hold about you and certain details regarding how we use it.
Your information will be provided to you electronically, unless otherwise requested.
We will respond to your request within a reasonable period of time, but at the latest within one month of the request (assuming we have the requisite information from you in order to be able to process your request).
You have the right to have your information rectified if it is inaccurate or incomplete. We aim to ensure that your personal information is accurate, however, please do contact us if you require your information to be updated or amended or, alternatively, you can update your account settings
You have the right to request the deletion or removal of your information. There are, however, specific circumstances where we may be unable to deal with your request, e.g. if we need to retain your information to comply with a legal or regulatory obligation.
You have the right to request that we limit the way we use your information if you have a particular reason for wanting that restriction e.g. in circumstances where you believe that we don’t have the appropriate rights to process your information
You have the right to obtain some of your information in a format you can move from one service provider to another. Should you request it, we will provide you with an electronic file including your basic account information
You have the right to object to us processing your information e.g. you can ask us to stop sending you marketing communications at any time.
You can withdraw your consent at any time. Please contact us if you want to do so.
You can also ask us to stop marketing to you by clicking on the ‘unsubscribe’ link that appears in all of our emails or by updating your account settings.
Please note that it can take approximately 24 hours for any changes to your preferences to be actioned.
You can request access to the personal information we hold about you by writing to us at:
Pionr 30 City Road London EC1Y 2ABOr alternatively, please email us at privacy@pionr.com, noting ‘Subject Access Request’ or ‘SAR’ in the subject line of your email.
If you have any questions about how we collect, store or use your personal information please contact us by telephoning +44 (0) 20 3960 5095 or via email at privacy@pionr.com
If you want to make a complaint about how we have handled your personal information, please contact us at privacy@pionr.com and we will investigate the matter and report back to you. If you are still not satisfied after our response or believe we are not using your personal information in line with the law, you also have the right to complain to the UK’s data protection regulator - the Information Commissioner’s Office - https://ico.org.uk/.
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.
Last updated: 15th November 2018
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