Privacy Policy

We take your privacy very seriously and are committed to protecting your personal data. This Privacy Policy details how we, Dot Investing Ltd of Unit 508 Cannon Wharf Pell Street, Surrey Quays, London, England, SE8 5EN (we, us) collect, use and process personal data. If you have any questions on this Privacy Policy or otherwise relating to how we process your personal data you can contact us at

This Privacy Policy affects your legal rights and obligations so please read it carefully. If you do not agree to be bound by this Privacy Policy, please do not provide personal data to us.

We may update this Privacy Policy from time to time at our discretion and in particular to reflect any changes in applicable laws. If we do so, and the changes substantially affect your rights or obligations, we shall notify you if we have your email address. Otherwise, you are responsible for regularly reviewing this Privacy Policy so that you are aware of any changes to it.

We are the controller of the personal data provided to us for the purposes of applicable data protection legislation.

Whose personal data do we collect?

By personal data we mean identifiable information about you. Generally, this is likely to include information such as your name, email address, correspondence address and your IP address if you access our website.

We may collect, use, store and transfer different kinds of personal data about you:

Contact Data includes data such as your email address, telephone number and correspondence address
Identity Data includes data such as first name, last name, username or similar identifier, date of birth, passport number
Technical Data includes data such as internet protocol (IP) address, your login data, browser type and version, cookies, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website and any communications we may send to you.
Usage Data includes information about how you use our website such as information about your visit to our website, including the full Uniform Resource Locators (URL) clickstream to and through, pages you viewed or searches you made, page response times, download errors, length of visit, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Marketing Data includes your preferences in receiving marketing from us.

We do not knowingly collect personal data of children. Please do not provide personal data to us unless you are at least 18 years old.

Personal data you provide to us

From time to time you may provide to us personal data. This may be because:

You provide information and documents to us so that we can verify your identity
You access and interact with our website, including by
creating an account with us,
posting content on our website,
You or your employer provides services to us;
We provide services to you or your employer;
You apply to work with us as an employee or a consultant;
You provide feedback or reviews to us;
You respond to a survey or questionnaire;
You otherwise contact us including with queries, comments or complaints.

We shall process all such personal data in accordance with this Privacy Policy. Certain personal data is mandatory to be provided to us in order that we can fulfil your request, for example to register on our website, and we shall make this clear to you at the point of collection of the personal data.

All personal data that you provide to us must be true, complete and accurate. If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this and we may also report this to the appropriate authorities.

Please note that we shall share your Contact Data and Identity Data with our Know Your Customer service provider, Northrow, to confirm your identity.

When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you.

Personal data we automatically collect about you

When you use our website, we may automatically collect and store information about your Technical Data and Usage Data for the purposes of research and analysis.

Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, please see our Cookies Policy.

Personal data we receive from others

If we reasonably believe that any of the personal data you have provided to us is inaccurate, we may receive further personal data from third parties, such as credit reference agencies and the electoral register, to try to confirm your identity.

We may also receive personal data about you from our third party service providers, including our payment service providers, and our analytic service providers.

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Legal basis for processing your personal data

Our website is for individuals who are Eligible Counter parties, Professional Clients or who otherwise fall into one of the categories of person listed in Chapter 4.12 of theFinancial Conduct Authority Conduct of Business Rules, including High Net Worth Investors and Sophisticated Investors.

You should not access this website in any jurisdiction where the content of our website is not permitted. You therefore warrant that you are lawfully entitled to access the content of our website without breaching or causing us to breach any applicable regulation.

You may use our website for your personal, non-commercial use only.

You must not to (a) try to gain unauthorised access to our website or any networks, servers or computer systems connected to our website; (b) use our website in any manner that could damage, disable, overburden or impair our servers or networks or interfere with any other user’s use and enjoyment of our website; (c) use the website to provide services to third parties or to extract or scrape data; (d) use our website to develop a competitive website; and/or(e) except to the extent expressly permitted by law and not capable of exclusion by law, copy, reproduce, redistribute, sell, create derivative works from, decompile, reverse engineer, or disassemble all or part of our website.

We reserve the right to investigate and/or terminate your account if we reasonably believe that you have misused our website or behaved in a way that is inappropriate or unlawful.

If you upload any content to our website, you agree that your content will not (a) breach the provisions of any law, statute or regulation including any data protection laws and any financial services laws; (b) infringe the rights including copyrights, or other legal rights of any person; (c) be made in breach of any legal duty owed to a third party, such as a contractual duty or a duty of confidence; contain any data that identifies any living individual unless you have the right to allow us to use data on our website;(e)contain any information that would affect the trading of a security and that has not already been made publicly available; (f) be deliberately or knowingly false, inaccurate or misleading; and/or(g)otherwise give rise to any cause of action against us.

You grant to us the non-exclusive right and licence to use, edit, publish and distribute your content on our website and to allow third parties to access your content when you post in a public part of the website.

You shall indemnify and keep indemnified us, our directors and employees from and against all costs, claims, losses, expenses, fines and damages that we may suffer or incur as a result of the use of your content in accordance with these Terms or Use, including any third party claim for infringement of rights.

We accept no obligation to store your content accordingly, you shall separately maintain up-to-date copies of your content if you need to retain a copy.

Where we hold and process your personal data

Some or all of your personal data may be stored or transferred outside of the United Kingdom and/or European Economic Area (the EEA) for any reason, including for example, if our email server is located in a country outside the United Kingdom or the EEA or if any of our service providers are based outside of the United Kingdom or the EEA.

Where your personal data is transferred outside the United Kingdom and/or the EEA, it will only be transferred to countries that have been identified as providing adequate protection for personal data or to a third party where we have approved transfer mechanisms in place to protect your personal data.

Security

We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. In particular, access is restricted to employees who need to know your personal data, and we use appropriate password protection and appropriate strong encryption electronic measures within our electronic data management systems.

However, unfortunately, because of the nature of electronic storage, we cannot promise that your personal data or any other data you provide to us will always remain secure. If there is a security breach, we will do all that we can as soon as we can to stop the breach and minimise the loss of any data.

Marketing

You may consent to receive marketing email messages from us about our website and our services and business generally. You can choose to no longer receive marketing emails from us by contacting us or clicking unsubscribe from a marketing email. Please note that it may take us a few days to update our records to reflect your request.

If you ask us to remove you from our marketing list, we shall keep a record of your name and email address to ensure that we do not send to you marketing information. If you still have an account with us, we shall continue to email you in relation to your account only.

Your rights

You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below. Further information can be found here

Right of access: You have the right to obtain from us a copy of the personal data that we hold for you.
Right to rectification: You can require us to correct errors in the personal data that we process for you if it is inaccurate, incomplete or out of date.
Right to portability: You can request that we transfer your personal data to another service provider if you initially provided consent for us to use the personal data or where we used the personal data to perform a contract with you.
Right to restrict or object to processing: In certain circumstances, you have the right to require that we restrict the processing of your personal information. If you believe our processing impacts on your fundamental rights and freedoms. However, we may demonstrate that we have legitimate grounds to process your personal data not withstanding your rights and freedoms.
Right to be forgotten: You also have the right at any time to require that we delete the personal data that we hold for you, where it is no longer necessary for us to hold it. However, whilst we respect your right to be forgotten, we may still retain your personal data in accordance with applicable laws and when we respond to your request we shall notify you of any specific legal reasons that we have to retain your personal data
Right to stop receiving marketing information: You can ask us to stop sending you information about our services, but please note we shall continue to contact you in relation to any matters relating to your account, if you have one.

We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive, and we may ask for identification from you before we can fully respond to your request.

If you have any complaints in relation to this Privacy Policy or otherwise in relation to our processing of your personal data, please tell us. We shall review and investigate your complaint and try to get back to you within a reasonable time. You do also have the right to contact the Information Commissioner, see www.ico.org.uk or if you are based outside of the United Kingdom, please contact your local regulatory authority.

Retention of personal data

Subject to the provisions of this Privacy Policy, we will retain personal data in accordance with applicable laws.

This means that we shall retain your personal data for as long as you have an account with us or otherwise access or use our website. However, we may also be required to retain personal data for a particular period of time to comply with legal, auditory or statutory requirements, including requirements of HMRC in respect of financial documents and in order to deal with any dispute you might raise.

Where we have no legal basis for continuing to process your personal data, we shall either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

General

Our website may contain links to third party websites, plug-ins and applications. We are not responsible for the content of such third party content, or their privacy statement. If you provide any information to the third party, then you should check the third party website to find the applicable privacy policy.

If any provision of this Privacy Policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties and all other provisions shall remain in full force and effect.

This Privacy Policy shall be governed by and construed in accordance with English law and you agree to submit to the exclusive jurisdiction of the English Courts.

This Privacy Policy was last updated on 10 September 2020. You may contact us if you wish to review any previous version.