1. Who This Policy Applies To
This Privacy Policy applies to:
- Visitors to our Website: Individuals who browse our website to learn about InvestStream and our Services.
- Representatives of Financial Institutions: Individuals representing current or prospective client financial institutions who interact with us regarding our Services (e.g., during sales inquiries, product demonstrations, technical support).
- Authorized Users of our Software: Individuals who are authorized by our client financial institutions to access and use our Services.
2. Information We Collect
The types of personal information we collect depend on your interaction with InvestStream and the Services provided.
A. Information Collected from Website Visitors:
- Contact Information: Name, email address, phone number, company name, and job title when you fill out contact forms, or request information.
- Usage Data: Information about how you interact with our website, such as IP address, browser type, operating system, referring URLs, pages viewed, time spent on pages, and dates/times of access. This information is typically collected through cookies and similar tracking technologies.
B. Information Collected from Representatives of Financial Institutions:
- Business Contact Information: Name, job title, company name, business email address, business phone number, and business address.
- Communication Records: Records of our communications, including emails, meeting notes, and call recordings (where permitted by law and with prior notification).
- Account Information: Information related to your organization's account with InvestStream, including contractual details, billing information, and service preferences.
C. Information Collected from Authorised Users of our Software (on behalf of our clients):
InvestStream primarily processes data on behalf of our client financial institutions. Our clients are typically the data controllers, and we act as a data processor. The specific types of personal information we may process, at the direction of our clients, through our software include:
- User Credentials: Usernames, passwords, and other authentication details necessary for accessing our software.
- Trading and Account Data: Depending on the specific modules implemented, this may include:
- Client Identifiers: Unique identifiers assigned by the financial institution to its end-clients.
- Transaction Data: Information related to trades, orders, and investments.
- Portfolio Information: Details about client portfolios and holdings.
- Account Balances: Current balances of client accounts.
- Performance Data: Investment performance metrics.
- Communication Data: Records of communications between our client financial institutions and their end-clients, processed through our software.
- Technical Data: Information about the devices and systems used to access our software, such as IP addresses, device identifiers, operating system versions, and software usage statistics.
Please Note: InvestStream does not directly collect personal financial information of our clients' end-users (e.g., account numbers) from them. Such information is provided to us by our client financial institutions as necessary for the functioning of our software, and we process it strictly according to our contractual agreements with them and applicable data protection laws. Our clients are responsible for obtaining the necessary consents from their end-users for the collection and processing of their data.
3. How We Use Your Information
We use the information we collect for various purposes, primarily to provide and improve our Services, communicate with you, and ensure the security of our systems.
A. For Website Visitors:
- To respond to your inquiries and provide you with requested information about our Services.
- To analyse website usage and improve the user experience, content, and functionality of our website.
B. For Representatives of Financial Institutions:
- To manage our relationship with your organization, including contract administration, billing, and technical support.
- To provide product demonstrations, training, and support for our Services.
- To communicate important service announcements, updates, and changes.
- To understand your needs and improve our Services and develop new features.
- To fulfil our legal and regulatory obligations.
C. For Authorised Users of our Software (on behalf of our clients):
- To provide and maintain our software solutions: This includes facilitating trading, wealth management, portfolio analysis, reporting, and other functionalities as per the contractual agreement with our client financial institutions.
- To ensure the security and integrity of our software: Monitoring for unauthorised access, preventing fraud, and resolving technical issues.
- To provide technical support: Assisting our clients with issues related to the use of our software.
- To perform system maintenance and upgrades.
- To generate aggregated and anonymised data: For analytical purposes, service improvement, and industry benchmarking, without identifying individual users or their financial institutions.
4. How We Share Your Information
InvestStream is committed to protecting your personal information and will not sell, rent, or lease your personal information to third parties. We may share information in the following circumstances:
- With Our Affiliates: We may share information with our corporate affiliates for internal business purposes, consistent with this Privacy Policy.
- With Service Providers: We may engage trusted third-party service providers to perform functions on our behalf, such as hosting, data analytics, customer support, marketing, and IT infrastructure. These service providers are contractually obligated to protect your information and use it only for the purposes for which it was disclosed.
- With Our Client Financial Institutions: For authorised users of our software, information processed within our systems is accessible by the respective client financial institution that has engaged InvestStream for the Services, in accordance with their own privacy policies and agreements with their end-users.
- For Legal Reasons: We may disclose your information if required to do so by law, court order, or governmental regulation, or if we believe such action is necessary to (a) comply with a legal obligation, (b) protect and defend the rights or property of InvestStream, (c) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (d) protect against legal liability.
- In Connection with Business Transfers: In the event of a merger, acquisition, reorganisation, sale of assets, or bankruptcy, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
- With Your Consent: We may share your information with third parties when we have your explicit consent to do so.
InvestStream implements robust technical, administrative, and physical security measures to protect personal information from unauthorised access, use, disclosure, alteration, or destruction. These measures include:
- Encryption: Using industry-standard encryption for data in transit and at rest where appropriate.
- Access Controls: Implementing strict access controls to restrict access to personal information to authorised personnel only on a need-to-know basis.
- Employee Training: Providing regular data privacy and security training to our employees.
- Incident Response Plan: Maintaining a comprehensive incident response plan to address potential data breaches.
While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.
6. Cookies and Tracking Technologies
Our website uses cookies and similar tracking technologies (e.g., web beacons, pixels) to enhance your browser experience, analyse website traffic, and personalise content.
- Cookies: Small data files stored on your device that help us remember your preferences and understand how you interact with our website.
- Strictly Necessary Cookies: Essential for the website to function correctly (e.g., navigating pages, accessing secure areas).
- Analytical/Performance Cookies: Help us understand how visitors use our website, which pages are most popular, and identify any errors. This helps us improve the website's performance.
Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, this may prevent you from taking full advantage of the website.
Hidden Components in the CMS
- Certain dynamic items may not be visible in the Designer. You can edit these by navigating to the CMS Collection and updating the content directly.
We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
- For Website Visitors and Representatives of Financial Institutions: We retain your information for as long as you maintain an active relationship with us or as necessary to provide you with services and fulfil our legitimate business purposes.
- For Authorised Users of our Software: We retain personal information processed on behalf of our client financial institutions according to the terms of our agreements with them and in compliance with applicable laws and regulations. Our clients are responsible for determining the retention periods for their end-users' data.
Upon expiration of the applicable retention period, we will securely dispose of or anonymise your personal information.
Depending on your jurisdiction, you may have certain rights regarding your personal information, including:
- Right to Access: The right to request a copy of the personal information we hold about you.
- Right to Rectification: The right to request that we correct any inaccurate or incomplete personal information.
- Right to Erasure (Right to be Forgotten): The right to request the deletion of your personal information, under certain circumstances.
- Right to Restriction of Processing: The right to request that we restrict the processing of your personal information, under certain circumstances.
- Right to Data Portability: The right to receive your personal information in a structured, commonly used, and machine-readable format, and to transmit that data to another controller, where technically feasible.
- Right to Object: The right to object to the processing of your personal information, under certain circumstances (e.g., for direct marketing purposes).
- Right to Withdraw Consent: Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time.
To exercise any of these rights, please contact us using the contact details provided in Section 11. We will respond to your request in accordance with applicable laws.
Please Note for Authorised Users of our Software: If you are an authorised user of our software and wish to exercise your rights regarding data processed by InvestStream on behalf of your financial institution, please direct your request to your financial institution. As the data controller, they are primarily responsible for responding to such requests, and we will cooperate with them as required by our contractual agreements and applicable law.
9. International Data Transfers
InvestStream operates globally and may store and process your information in various locations, including outside of your country of residence. This may include transfers to countries that may not have the same data protection laws as your jurisdiction.
When we transfer personal information internationally, we take appropriate safeguards to ensure that your personal information remains protected in accordance with this Privacy Policy and applicable data protection laws. These safeguards may include:
- Transferring data to countries deemed by the relevant authorities to provide an adequate level of data protection.
- Implementing Standard Contractual Clauses (SCCs) approved by relevant regulatory bodies.
- Obtaining your explicit consent where required.
Our website may contain links to third-party websites that are not operated by us. This Privacy Policy does not apply to such third-party websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. We encourage you to review the privacy policies of any third-party websites you visit.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post the updated Privacy Policy on our website with a revised "Last Updated" date. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of our website or Services after any modifications to this Privacy Policy will constitute your acknowledgment of the modifications and your consent to abide and be bound by the updated Privacy Policy.
If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at
enquiries@investstream.io
