Privacy notice

Version 2.2 – May 2022

10 minutes

Background

We collect and process some of your personal information to allow us to operate as a business, provide you with our services and to meet the legal obligations we have as a regulated financial services firm.

As a technology company we also use a number of third parties to carry out certain business functions which may require us to share your information with them.

This privacy notice details the personal information we collect and use, how we look after it, and the circumstances in which we may share it with someone else. It also sets out your rights around how we handle your information and lets you know how to contact us if you have any concerns.

Who we are

Freetrade Limited is a company registered in England and Wales with company number 09797821 with its registered office address at 10 Devonshire Square, London, England EC2M 4YP. Freetrade Limited is authorised and regulated by the Financial Conduct Authority (Firm Reference Number: 783189). Freetrade Limited ise registered with the Information Commissioner’s Office (ICO), the UK regulator for data protection matters, under number ZA179260.

Freetrade Europa AB is a company registered in Sweden with company number 559285-0696 with its registered office address at c/o Covendum, PO Box 4011, Katarinavägen 15, 116 45 Stockholm.

Freetrade Limited and Freetrade Europa AB act as independent controllers of your information, (which means we decide independently what information we collect and how it is used for our own separate purposes and processing). 

Throughout this privacy notice, we will refer to these companies together as “Freetrade”, “we”, “our” or “us”.

If you have any questions about this privacy notice please email us or write to us at 10 Devonshire Square, London EC2M 4YP. You can also ping us on live chat through the app!

What information we collect

To provide you with our services, we collect and use the following personal data about you at various points during your interactions with us. Personal data is information which relates to an identified or identifiable living individual, either on its own or combined with other available information. 

When you use our product:

  • Personal information you provide to us when signing up as our customer. This includes full name, date of birth, postal address, email address, nationality and national ID number                                                                       
  • Documents we request in order to verify your identity, carry out anti-money laundering checks and security checks
  • Details of the bank account you use to fund your account with us
  • Transactional and aggregate account information relating to the investments you make using our product
  • Technical information on your use of our app, including your IP address, operating system and device ID
  • Analytics on how you use our product
  • Tax declarations that you make to us

When you contact us:

  • Information you give to us when you get in touch through our app, via email or through social media platforms
  • Information you provide to us when applying for a job or to provide us with your services

When you visit our website (https://freetrade.io) and its sub-domains:

Technical information on how you use our website including your IP address, device type and approximate location.

When a third party we use sends us information:

Information we may receive about you from third parties we work with, for example an identity verification service.

Marketing:

If you have provided us with your consent to do so we may send you certain direct marketing communications through various channels, including email, push notifications and post. You can withdraw this consent by contacting us in the app or by email.

Where you have used our services before, we may use your information to send you marketing messages about similar services that we think (based on the information you have provided to use) would be of interest to you. If you no longer wish to receive these messages, you can opt out at any time by clicking “unsubscribe” in the message, by contacting us in the app or by email.

How we use your information

We only process your information where we have a lawful basis for doing so. There are 6 main lawful bases which organisations can rely on. The most relevant to our business are:

  • We have a legitimate interest in processing your personal information for a specific purpose, but only if those interests are not outweighed by your other rights and freedoms (e.g. your right to privacy).
  • We have to comply with obligations arising from the performance of a contract between you and us.
  • We have a duty to comply with a legal or regulatory requirement.
  • You have provided us with consent to process your personal information.

Lawful basis

Purpose

Legitimate interest Where using your information is necessary to pursue our legitimate business interests to:
  • provide our business services to you (for example, our core services of stockbroking);
  • take steps to enter into and fulfil contracts with suppliers where sharing personal data is required for that contract and the performance of the services;
  • market our services (in certain circumstances);
  • operate, improve and optimise our product and website;
  • monitor and make improvements to our website to enhance security and prevent fraud;
  • perform other routine business operations; and
  • protect our business and defend ourselves against legal claims.
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Where we use your information for our legitimate interests, we have assessed whether such use is necessary and that such use will not infringe on your other rights and freedoms.
Contract Where using your personal information is necessary for performing a contract we have with you, for example where you have asked us to buy or sell a share for you.
Legal obligation Where we retain information to enable us to bring or defend legal claims.

Where we are required to retain transactional information and correspondence

Where we verify your identity as part of our anti-money laundering controls or making transaction reports to regulators.

Where we send you information to comply with a legal obligation (e.g. where we send you information about your legal rights).

Consent Where you have provided consent to receiving marketing materials about new features or services we may provide.

How we keep your information safe

We adopt robust security measures to prevent unauthorised access, disclosure, modification or erasure of your personal information.

These measures include:

  • staff policies and training;
  • access controls and user authentication (including multi-factor authentication);
  • internal IT and network security;  
  • regular testing and review of our security measures;
  • incident and breach reporting processes;
  • business continuity and disaster recovery processes.

If an event or incident affecting your personal data occurs, we will keep you informed. We may also need to notify the regulator (where required under data protection law) and if we make decisions about your data jointly with another party (for example, a third party marketing provider), we may need to notify them.

Where we store or transfer your information

Your information is processed and stored at our operating offices as well as on servers managed by our hosting providers.

In some circumstances, your information may be stored or transferred somewhere outside of the UK or the European Economic Area (EEA) (for example, where it is processed by our staff, or the staff of a third party we contract with, who operate outside the UK and/or EEA). In these situations we have contracts in place to ensure information is protected to the same standards as it is in the UK and/or EEA.

Who we share your information with

Your information is shared with employees of Freetrade who require it to run your account, resolve any issues or queries, improve our product and services, or contact you about features you may be interested in where we have your consent to do so.

Some of your information is processed by third parties we use to provide different elements of our service. We conduct due diligence on these third parties, to make sure your information is handled securely and only allow third parties to process your personal information where it is required for them to carry out their function.

Your personal data may be processed by third parties that we use to provide the following services:

Core service:

  • Trade execution and settlement
  • In-app customer support
  • Handling payments
  • Emailing users

Product developments:

  • Usage analytics
  • Customer feedback and surveys
  • Product waiting lists

Legal requirements:

  • Anti money laundering checks ie: Know Your Customer, Politically Exposed Persons, sanctions, Adverse media checks
  • Regulatory reporting
  • Tax reporting
  • Transaction monitoring

Technical:

  • Hosting and backend infrastructure
  • Infrastructure and security monitoring
  • Traffic optimization and distribution

Other

  • Administration of your Self Invested Personal Pensions (SIPP)
  • Pension and ISA transfers
  • Marketing and Direct marketing where we have your consent or a legitimate interest to do so
  • Where you have requested that we share your information with a third party 
  • Where we are legally required to provide your personal information to the issuer of a share you hold

As part of our onboarding checks we search your record at credit agencies. This leaves a ‘soft footprint’ on your file which is not visible to lenders and does not impact your credit rating.

We may share your personal data with our group companies and professional advisers (e.g. our accountants or legal advisers) where we require specialist advice to help us conduct our business. We may also share it with any actual or potential buyer of our business.

NB: If you sign up for the Freetrade SIPP, we will be sharing personal data with Gaudi Regulated Services Limited and Gaudi Trustees Limited. We collect this personal data as a controller, and transfer it to Gaudi, who are an independent controller. For more information about how Gaudi use your personal data, please see Gaudi’s privacy statement here.

We never sell any of your personal information.

How long we keep your information

We store your information for the duration of time required by the purpose under which we collected the information. Information we collect:

  • in relation to our legitimate interests of providing you with our services will be kept for as long as you continue to remain a user of our services.
  • for the purposes of performing a contract between you and us is kept until the contract has been completed.
  • in relation to our legal and regulatory obligations is retained for the duration set out in the legislation we are subject to, which in most cases is 5-7 years following the end of our business relationship with you.

Your rights

You have rights under the law and this privacy notice in relation to your personal data. If you would like to make a request in relation to these rights, then please contact us by email. You have the right to:

  • request to access the information we hold about you.
  • ask us to update any of your information which is inaccurate or incorrect.
  • ask us to delete, stop processing or limit our use of your information that we hold (although if we have a legal obligation to retain this information, we are unable to delete it until the required retention period has elapsed).
  • ask us to send you or another organisation an electronic copy of your personal data (portability).

How to contact us

If you have any questions about this Notice, how we handle your personal data or you are looking to exercise one of your rights, then please contact us via email and we will do our best to resolve the matter.

If you are unhappy with the way we collect and use your personal data, you can complain to the Information Commissioner’s Office (ICO) or another relevant supervisory body, but we hope that we can respond to your concerns before it reaches that stage. 

More information can be found at https://ico.org.uk/make-a-complaint/  

Changes to this policy

This privacy notice was last updated on 12 May, 2022. We review our policies and procedures annually. We’ll post any changes we make to this privacy notice on this page and, where possible, let you know about any significant changes via email.