Privacy

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.

Summary

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.


1. What kinds of Personal Information do we collect about 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

2. How do we collect your information?

We may collect personal information:

  • Via our website;
  • Via livechat;
  • Via the internet;
  • Via customer surveys;
  • Via face to face meetings with members of the Pionr team;
  • By email and letters; and
  • By phone

We may also collect personal information from third parties we work with:

  • Our ‘KYC’ service provider;
  • Our payment service provider;
  • Credit reference agencies
  • Financial advisers; and
  • Companies that introduce you to us.

3. How do we use your information and for what purposes?

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:

  • to provide our product and/or services to you;
  • in order for us to comply with a legal or regulatory obligation;
  • when it is in our ‘legitimate interests’ (i.e. we have a business or commercial interest to use your information as long as it does not overly prejudice you); and/or
  • when you consent to it

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

4. Who do we share your information with??

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:

  • The Financial Conduct Authority (FCA), and other regulators and authorities
  • Financial Services Compensation Scheme (FSCS)
  • HM Revenue & Customs (HMRC)
  • Credit reference agencies
  • Fraud prevention agencies
  • Third parties that we engage with to help us operate, improve, integrate, market and customise our product and/or services
  • Pionr’s payment service provider
  • Pionr’s KYC service provider
  • IT providers / hosted IT solution providers
  • Pionr’s auditors

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.

5. What marketing activities do we carry out?

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.

6. How long do we keep your personal information for?

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.

7. Where do we store your personal information?

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.

8. Do we transfer personal data outside of the European Economic Area (EEA)?

We will only send your information outside of the EEA to:

  • Comply with our legal and regulatory obligations; or
  • our product and/or services.

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.

9. What are your rights?

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:

9.1. The right to access your personal information:

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).

9.2. The right to rectification:

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

9.3. The right to erasure:

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.

9.4. The right to restrict processing:

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

9.5. The right to data portability:

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

9.6. The right to object:

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.

10. Consent

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.

11. How to contact us

You can request access to the personal information we hold about you by writing to us at:

Pionr
30 City Road
London
EC1Y 2AB

Or 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

12. How to complain

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/.

13. Changes to our Privacy policy

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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