Stake (“we”, “our”, “us”) is the trading name of:
Hellostake Limited (Company no. 11676409), authorised and regulated by the UK Financial Conduct Authority (Firm Reference Number: 830771). Our Information Commissioner’s Office (UK) registration number is ZA551937.
If you have any questions about this document please email us at firstname.lastname@example.org
This Policy is in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.
Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your credit card information.
What personal information do we collect?
We may collect the following types of personal information:
- Mailing or street address;
- Email address;
- Telephone number and other contact details;
- Age or date of birth;
- Credit card information;
- Bank account details;
- Details or images of your government issued identification, such as your passport, drivers licence, or other forms of ID or reference numbers relating to you, such as your National Insurance number.
- Your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
- Details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
- Any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
- Information you provide to us through customer surveys; or
- Any other personal information that may be required in order to facilitate your dealings.
We will collect these types of personal information directly from you.
We may collect this information when you:
- Onboard on our website or app;
- Communicate with us through correspondence, email, or when you share information with us from other social applications, services or websites;
- Interact with our sites, services, content and advertising; or
- Invest in our business or enquire as to a potential purchase in our business.
What is the legal basis for collecting your information?
By law, we must have a legal basis to collect and use your personal information.
Our legal basis may be one of the following:
|Meeting legal or regulatory obligations||We may have a legal or regulatory responsibility to collect and store your personal information for a set period of time.|
|Reasonable and legitimate interests||We may collect and use your personal information, or share it with our partners, because we or they have a legitimate reason to have it and this is reasonable when considered in relation to your right to privacy.|
|Adhering to our contracts and agreements with you||We need personal information as part of our agreements and without this, will not be able to provide our services to you.|
|With your consent||Where you’ve agreed to us by collecting your information, you indicate you’re happy for us to use your personal information in a certain way.|
Why do we collect, use and disclose your personal information?
We may collect, hold, use and disclose your personal information for the following purposes:
- to enable you to access and use our website and services (as set out in our respective Terms & Conditions).
- to operate, protect, improve and optimise our website and services, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
- to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
- to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
- to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
- to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and
- to consider your employment application.
We may disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it, and us, to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive. More information in relation to this is set out in our Cookies Policy.
Do we use your personal information for direct marketing?
We may use your personal data to send you updates (by email, text message, telephone or post) about our services.
We have a legitimate interest in using your personal data for marketing purposes. This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by contacting us using the contact details above. We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell it with other organisations outside our group for marketing purposes.
To whom do we disclose your personal information?
- Our employees and related bodies corporate;
- Our existing or potential third party suppliers and service providers in connection with providing you products or services or those existing or potential suppliers and providers improving the products and services provided to you. This may include (without limitation) payment systems operators (e.g. merchants receiving card payments or funds transfer), foreign exchange providers, brokers and dealers, and partners who facilitate the deposit and custody of funds;
- Other existing or potential third party suppliers and service providers (including providers for the operation or optimisation of our websites and/or our business or in connection with providing you, or improving our, products and services);
- Our existing or potential agents, professional advisers, business partners or partners;
- Our sponsors or promoters of any competition that we conduct via our services;
- Anyone to whom our assets or businesses (or any part of them) are transferred;
- Specific third parties authorised by you to receive information held by us; and/or
- Other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law (including for the purposes of AML/CTF collection and verification).
Disclosure of personal information internationally
Due to the international nature of our services, we use partners and providers that may be based overseas and we may be required to share your information with them.
The data we collect from you may be transferred to and stored somewhere outside of your local jurisdiction if we have specific agreements and/or due diligence in place. In certain circumstances it may also be processed by staff outside of the United Kingdom and those who work for us or a select third party.
Transferring your personal data outside of the UK and EEA
To deliver our services to you, it is sometimes necessary for us to share your personal data outside the UK/EEA as noted above. Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/EEA] where:
- the UK government or, where the EU GDPR applies, the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
- a specific exception applies under data protection law
These are explained below.
We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:
- all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);
- Gibraltar; and
- Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.
The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists. Other countries or international organisations we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.
Transfers with appropriate safeguards
Where there is no adequacy decision, we may transfer your personal data to another country or international organisation if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects. The safeguards will usually include using legally-approved standard data protection contract clauses.
Transfers under an exception
In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, e.g.:
- you have explicitly consented to the proposed transfer after having been informed of the possible risks;
- the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
- the transfer is necessary for a contract in your interests, between us and another person; or
the transfer is necessary to establish, exercise or defend legal claims
We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.
Security & Storage of Information
We may hold your personal information in either electronic or hard copy form. We store any electronic information on secure servers through Amazon Web Services.
We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example, we encrypt all data and have it stored in secured facilities. However, we cannot guarantee the security of your personal information. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
As your personal information is available inside the Stake app or website, we require you to set a strong password when creating an account and encourage users to set up multi-factor authentication. We request that you do not share your password with anyone and it remains confidential.
Length of storage
We will keep your personal data while we are providing our services to you. Thereafter, we will keep your personal data for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly; and/or
- to keep records required by law.
We will not keep your personal data for longer than necessary. When it is no longer necessary to keep your personal data, we will delete or anonymise it.
Under all circumstances, you have the following rights:
- Access: You have the right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation whether your personal information is being used by us; and details about how and why it is being used.
- Correct and update your information: If any of the information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, you are entitled to request any necessary amendments be made.
- Erasure: The right to require us to delete your personal data in certain situations.
- Restriction of processing: The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.
- Data portability: The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations.
- To object: You have a right to ask us to stop using your personal information for direct-marketing purposes. You also have the right to object (in certain other situations) to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
- Not to be subject to automated individual decision making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
If you would like to exercise any of these rights, you can log into your account or email us at email@example.com. If you wish to delete or deactivate your account, please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.
Making a complaint
If you think we have breached the General Data Protection Regulation (GDPR) or the Data Protection Act 2018, or you wish to make a complaint about the way we have handled your personal information, you can contact us at firstname.lastname@example.org
Please include your name, email address and/or telephone number and clearly describe your complaint. For security reasons, we can’t deal with your request if we are not sure of your identity, so we may ask you for proof of your ID. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time.
In accordance with GDPR, as a UK resident, you can lodge a complaint about our collection and use of your personal information to the Information Commissioner’s Office (ICO) or to the data protection authority in the country where you usually live or work, or where the alleged infringement has taken place. For more information, please contact the ICO by mail at, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, by phone on 0303 123 1113 or through their website.
Effective: 8 July 2021