Welcome to FundCount Group Ltd. (trading as “FundCount”) Privacy Policy!

FundCount respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Introduction

This Privacy Policy outlines FundCount (“we”, “our”, or “the Company”) practices with respect to information collected from users who access our website at www.fundcount.com (“Site”), or otherwise share personal information with us (collectively: “Users”). 

Grounds for data collection 

Processing of your personal information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter “Personal Information”) is necessary for us to communicate with you properly for the performance of any contractual obligations we may have towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject. 

When you use the Site, you consent to the collection, storage, use, disclosure, and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions. 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground(s) we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing, including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order, including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you, which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

What information do we collect? 

We collect two types of data and information from Users. 

The first type of information is unidentified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-Personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.). 

The second type of information is Personal Information, which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes: 

• Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID), and other information which relates to your activity through the Site.
• Registration information: When you register to our Site you will be asked to provide us certain details such as: full name, email or physical address, and other information. 

How do we receive information about you? 

We receive your Personal Information from various sources: 

• When you voluntarily provide us your personal details in order to register on our Site; 
• When you use or access our Site in connection with your use of our services; 
• From third-party providers, services, and public registers (for example, marketing service providers, traffic analytics vendors), etc. 

How do we use the collected information? 

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy. 

We may use the information for the following: 

• Communicating with you — sending you commercial electronic messages and notices regarding our services, providing you with technical information, and responding to any customer service issue you may have;
• To communicate with you and to keep you informed of our latest updates and services;
• To serve you advertisements when you use our Site (see more under “Advertisements”); 
• To market our websites and products (see more under “Marketing and Anti-Spam”); 
• Conducting statistical and analytical purposes, intended to improve the Site.

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies, and subcontractors. 

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third-party providers, who may be located in different jurisdictions across the world, for any of the following purposes: 

• Hosting and operating our Site;
• Providing you with our services, including providing a personalized display of our Site;
• Storing and processing such information on our behalf; 
• Serving you with advertisements and assist us in evaluating the success of our advertising campaigns and help us retarget any of our users;
• Providing you with marketing offers and promotional materials related to our Site and services; 
• Performing research, technical diagnostics or analytics. 

We may also disclose the information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights. 

User Rights 

You may request to: 

• Receive confirmation as to whether or not Personal Information concerning you is being processed, and access your stored Personal Information, together with supplementary information. 
• Receive a copy of Personal Information you directly volunteer to us in a structured, commonly used, and machine-readable format. 
• Request rectification of your Personal Information that is in our control.
• Request erasure of your Personal Information. 
• Object to the processing of Personal Information by us. 
• Request to restrict processing of your Personal Information by us.
• Lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. 

If you wish to exercise any of the aforementioned rights or receive more information, please contact us. 

Retention 

We will retain your Personal Information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications, and anything else as required by applicable laws and regulations. 

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Cookies 

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. 

A “cookie” is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences, and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies: 

• “session cookies” which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 
• “persistent cookies” which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example, to allow us to store your preferences for the next sign-in; 
• “third-party cookies” which are set by other online services who run content on the page you are viewing, for example by third-party analytics companies who monitor and analyze our web access. 
  

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly, and your online experience may be limited. 

We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Third-party collection of information 

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party to that you choose to disclose information. 

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties to which we may disclose information as set forth in this Privacy Policy. 

How do we safeguard your information? 

We take great care in implementing and maintaining the security of the Site and your information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied, or otherwise, that we will prevent such access. 

Transfer of data outside your Legal Jurisdiction 

Please note that some data recipients may be located outside of your legal jurisdiction. In such cases, we will comply with relevant legislation.  Where the jurisdiction of the recipient of the data does not meet relevant requirements, we will enter into legal agreements ensuring an adequate level of data protection. 

Advertisements 

We may use third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regard to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser). 

You may opt out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: NAI, DAA.

Marketing and Anti-Spam

We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third-party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you.   

Out of respect to your right to privacy, we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists. 

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important email communications without offering you the opportunity to opt-out of receiving them. These may include customer service announcements or administrative notices. 

Corporate transaction 

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation, or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy. 

Minors 

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at legal@fundcount.com. 

Updates or amendments to this Privacy Policy 

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the “Last modified” section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments. 

Contact us 

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at legal@fundcount.com. 

Last update: October 19, 2022