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Privacy Notice

Seedrs Limited (trading as Republic Europe) (“Republic Europe”, “we”, or “us”) operates Europe’s leading online private investing platform that facilitates individuals investing in start-ups, growth companies, and, if eligible, top VC funds, as well as enabling ambitious entrepreneurs in all sectors to raise capital from their communities, angels and institutional investors. Republic Europe is part of a global group of companies owned by OpenDeal Inc. (“Republic”). This Privacy Notice describes the information relating to you (“Personal Data”) we collect and use, and it applies to all services that we offer whether on our website https://europe.republic.com (including any of its sub-domains) or any mobile application Republic Europe provides (the “Website” and “App” respectively, and together the “Platform”) and all the people that we engage with.

Contents

1. Information that we collect
2. How is your Personal Data collected
3. Data protection principles
4. How we use information that we collect
5. Transparency and choice
6. Accuracy and retention of personal data
7. Information that we share
8. Your rights
9. Security of your personal data
10. Revisions
11. Communicating with us

1. Information that we collect

We may collect, store, and use the following categories of Personal Data about you:

  • your name, address, email address, phone numbers, and communications with us or in discussion forums with other users of our Platform (“Contact and Communication Data”),

  • your date of birth, identification documents, tax residency and identification number, gender, and nationality (“Identity Data”),

  • your transactions on our Platform, payment and banking details (“Transaction Data”),

  • technical information when you visit our Platform including your browsing activity, IP address, and details about the device you use (“Usage Data”),

  • any details you register with us in the “Profile” section of your account (“Profile Data”), and

  • if you are an entrepreneur, staff member, or are otherwise connected to a business who has engaged with us, information about you in connection with the applicable business, such as demographic information, employment and educational history, and communications with our staff (“Business Data”).

In the limited circumstances described in section 4 of this Privacy Notice, we may also collect, store, and use biometric data. This type of Identity Data is defined as sensitive or special category Personal Data under data protection law.

2. How is your Personal Data collected?

We collect information on you in the following ways:

  • Information you give us. When you use the Platform or interact with us, we may ask you to provide certain personal information, and, in the case of entrepreneurs seeking to raise capital through the Platform, information about you in connection with your business. Much of this information enables us to comply with our legal obligations or fulfil our contractual arrangements with you and others, and sharing this information may be necessary for us to provide our services to you. If we need to collect sensitive or special category Identity Data, we will only do so with your consent.

  • Information we get from your use of our services. Republic Europe collects information about the services you use and how you use them, such as when you view and interact with the Platform, or our advertisements. In addition, we may gather certain information about you, your device, and the details of any website from which you accessed the Platform. Much of this information is collected using cookies and similar technologies, for more information on how we use these please see the “Cookie Preferences” linked at the foot of this page. Please note that third parties may also use cookies on our Platform. We do not have access to these cookies and, other than allowing them to be served, we play no role in these cookies at all. These third parties may include, for example, businesses fundraising on the Platform, advertising networks, and providers of external services like web traffic analysis services. Such third party cookies are likely to be analytics, personalisation or targeted advertising cookies.

  • Information from third parties including publicly available sources. We may also collect your Personal Data from third parties, such as businesses raising on our Platform, ‘know your customer’ service providers, and publicly available sources. Please note that, it is up to these third parties to ensure any such processing of your data is compliant with relevant data protection law.

3. Data Protection principles

Republic Europe is committed to protecting the privacy and security of your Personal Data. Republic Europe is a “data controller”, meaning that we are responsible for deciding how we hold and use your Personal Data. We will comply with data protection law, which says that Personal Data must be:

  • Used lawfully, fairly and in a transparent way.

  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

  • Relevant to the purposes we have told you about and limited only to those purposes.

  • Accurate and kept up to date.

  • Kept only as long as necessary for the purposes we have told you about.

  • Kept securely.

4. How we use information that we collect

We use the Personal Data that we collect for the purposes set out below. We also set out below the categories of Personal Data we use for each purpose:

To comply with our legal or regulatory obligations, we may use your Personal Data (and if you do not provide this Personal Data we may not be able to provide our services to you):

  • To confirm your identity in order to create your account and ensure that you are eligible to use the services provided on the Platform. (Identity Data, Contact and Communication Data, Usage Data, Business Data)

  • To conduct required anti-money laundering checks on you, and associated financial crime and fraud monitoring, in connection with transactions you may conduct through the Platform. (Contact and Communication Data, Identity Data, Transaction Data, Usage Data, Business Data)

  • In the case of investors, to confirm that you are eligible to make investments through the Platform in accordance with relevant legislation. (Identity Data, Contact and Communication Data, Usage Data)

  • To enable us to comply with our obligations as a regulated financial services business, including transaction recording, updates on your investment and fundraising activity on the Platform, other compliance responsibilities, and reporting to regulators and governmental authorities, and recordkeeping requirements that may include recording telephone calls with you. (Identity Data, Contact and Communication Data, Transaction Data, Usage Data, Business Data)

To carry out our obligations under our contracts with you or others, we may use your Personal Data:

  • To process and administer payments and investments in connection with the services provided on the Platform. (Identity Data, Contact and Communication Data, Transaction Data)

  • In the case of entrepreneurs seeking capital and certain individuals connected to a business, to assess your suitability for and application to fundraise on the Platform, to verify and approve the disclosures you make in your campaign to potential investors, to provide you with any campaign marketing and PR services, to facilitate the investment transactions, and exercise any rights that Republic Europe may have as nominee. (Business Data, Profile Data, Identity Data, Contact and Communication Data, Transaction Data)

  • In the case of investors, to facilitate any investments you may make, to exercise any rights you may have in connection with those investments including by Republic Europe as nominee, and to provide fundraising businesses with information about the progress of their campaigns and your investments in their businesses. (Contact and Communication Data, Transaction Data, Usage Data, Profile Data)

  • In the case of investors who have completed investments in fundraising businesses, to provide those businesses with information to fulfil obligations to you, and ensure compliance with their corporate or regulatory requirements, such as tax and shareholder reporting. (Identity Data, Contact and Communication Data, Transaction Data, Usage Data)

  • In the case of investors who have been referred to Republic Europe by an independent financial advisor or wealth manager, to share information that we hold about you with your financial advisor or wealth manager. (Contact and Communication Data, Transaction Data)

  • To provide you with information about your account, including any campaigns you have created, your account balance, and any investments or payments you have made or have indicated an interest in making. (Identity Data, Transaction Data, Contact and Communication Data, Usage Data, Profile Data, Business Data)

  • To facilitate the participation of you or your business in any supplemental services that Republic Europe may offer such as referral or introduction services. (Contact and Communication Data, Transaction Data, Business Data)

We have a legitimate interest in ensuring our services and the Platform operate effectively, and to do this we may use your Personal Data:

  • To monitor, improve and administer the Platform and the services provided on it. (Identity Data, Contact and Communication Data, Transaction Data, Usage Data, Profile Data, Business Data)

  • To contact you to ensure customer satisfaction in respect of our role as a service provider and assist you in getting the best value from our services. (Contact and Communication Data, Transaction Data, Business Data)

  • To respond to communications including customer support or other enquiries requesting information. We may also intercept, record and/or monitor any communication(s) (including telephone calls, video calls or other electronic communications) between you and us. We may do so such monitoring and recording to resolve queries and for the purposes of ensuring security, staff training and complying with our regulatory and legal responsibilities. In the case of communications by email you should note that, as emails are not encrypted (and may therefore be intercepted by third parties) and as the identity of the sender cannot be confirmed, you must NOT provide your security details by email. (Contact and Communication Data, Business Data).

  • Together with entities under common ownership of Republic, to manage intragroup business operations and for internal reporting, monitoring and administration. (Identity Data, Transaction Data, Contact and Communication Data, Usage Data, Profile Data, Business Data)

We also have a legitimate interest in communicating with you and others (including entities under common ownership of Republic), facilitating communications between you and others (including entities under common ownership of Republic), publicising our business, supporting industry research, and making sure that marketing, advertising, PR, and content we provide is effective, so we may use your Personal Data:

  • To enable us to conduct surveys and analysis, aggregate user profiles, identify other potential customers, or enable us or third-party academics to conduct research. (Identity Data, Contact and Communication Data, Transaction Data, Usage Data, Profile Data, Business Data)

  • To advertise, publicise and promote our business (including the business of Republic and entities under common ownership of Republic), and to measure, understand, or improve the effectiveness of advertising we provide to you and others. (Contact and Communication Data, Transaction Data, Usage Data, Profile Data, Business Data)

  • In the case of individuals or businesses that have indicated an interest in Republic Europe or the businesses fundraising on the Platform, to contact you to provide you with information about us, entities under common control of Republic, or fundraising businesses (fundraising with us or under common ownership of Republic), and on other selected products and services that we think may be of interest to you (unless you have asked us not to do so). (Contact and Communication Data, Usage Data, Profile Data, Business Data)

  • To create and share informative content about our business or the industry in which we operate, including contacting you about reports we publish and new products we launch. (Contact and Communication Data, Business Data)

  • In the case of our commercial and investment partners providing goods or services to investors or entrepreneurs, to pass on information in relation to those goods or services. (Business Data, Transaction Data, Contact and Communication Data, Usage Data)

  • In the case of journalists who are working in the sector in which we operate or related sectors, to provide you with news and updates about our business, businesses that are fundraising on the Platform and other relevant industry information. (Contact and Communication Data, Business Data)

  • In the case of referred investors, to inform the party that has referred you that you have joined Republic Europe. (Contact and Communication Data)

  • In the case of investors who have completed investments in fundraising businesses, to enable those businesses to contact you with news of developments in the business and keep you informed as to your investment. (Contact and Communication Data)

We may seek your consent to collect biometric Identity Data when we are unable to verify your identity with other Identity Data you provide. We will not collect or use this sensitive or special category Identity Data without seeking your consent first.

In certain other circumstances we may seek your consent to use your Personal Data. In this case we will ask you to confirm your agreement to your Personal Data being processed for a specific purpose, either through the Platform or by another means.

5. Transparency and choice

Members of the Platform can manage the kinds of notifications received from us by visiting the “Notifications” tab in your Republic Europe account on the Website, and (if applicable) the settings menu of our App. To unsubscribe from emails you can also use the ‘unsubscribe’ link on the emails we send you. For non-members of the Platform, please notify us using the contact details below if you no longer wish to receive our updates.

You may choose which categories of cookies and other similar technologies that we use when you interact with the Platform, for more information see the “Cookie Preferences” linked at the foot of this page.

6. Accuracy and retention of Personal Data

If you see that any of your Profile Data that is included in the “Profile” section of your Republic Europe account is inaccurate, please revise or update it using the Website. Alternatively, if you believe that any of the Personal Data we hold about you is inaccurate, you may notify us using the contact details below in order to correct it.

It is your responsibility to ensure that any Personal Data you have provided to us remains accurate and to notify us (either through the Website or using the contact details below) if there are any changes in your Personal Data.

We will retain your Personal Data to fulfil the purposes outlined in this Privacy Notice as long as you use the Platform, and for at least six years after that to comply with the legal and regulatory recordkeeping obligations we have.

7. Information that we share

Any Personal Data that we collect will not be disclosed to any third parties by Republic Europe except under the following circumstances:

  • We may disclose certain of your Personal Data if we, in good faith, believe that we are required to do so by law, regulation or the order of court or other legitimate government body or arbitration panel. This includes, among other things, any Personal Data that may be requested by tax authorities or by regulators.

  • We may tell you in one of the agreements that you enter into with us (for example the Membership Agreement that you will enter into when signing up to the Platform, the Engagement Letter and Campaign Terms & Conditions that you will enter into when you wish to raise funds for your business, or the Investment Agreement that you will enter into when making an investment) or otherwise on the Platform that we will disclose certain of your Personal Data in connection with a transaction you conduct through the Platform. We may also tell you how we will use or disclose your Personal Data when you provide information to us in certain other circumstances (for example if we are collecting information about a potential fundraise on behalf of a fundraising business).

  • We may disclose certain of your Personal Data to third party service providers solely in the course of their provision of services to Republic Europe, and will take reasonable precautions to ensure that these service providers are obliged to keep your Personal Data secure and confidential, in compliance with relevant legal requirements and security standards.

  • We may share your Personal Data with other entities under common ownership of Republic that are either subject to this Privacy Notice or follow practices at least as protective as those described in this Privacy Notice.

  • We may disclose certain of your Personal Data to third party academics to conduct research.

  • In the event that we intend to enter into a major corporate transaction, such as a sale of control of our or another business on a stock exchange, we may disclose certain of your Personal Data to potential buyers, underwriters or advisors. If we do this, we will take reasonable precautions to ensure that the recipients of your Personal Data are obliged to keep it secure and confidential, in compliance with relevant legal requirements.

  • We may, from time to time, expand, reduce or sell our business, and this may involve the transfer of certain divisions or the whole business to other parties. Your Personal Data will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Privacy Notice, be permitted to use your Personal Data for the purposes for which it was supplied by you.

When disclosing your Personal Data to third parties, we may transfer your Personal Data outside the UK and European Economic Area. When we do so, we will take steps to ensure that the transfer is protected by safeguards provided under EU and UK law, such as the standard contractual clauses and UK IDTA.

8. Your rights

You may have the right to request the following actions regarding your Personal Data, which will be fulfilled in accordance with applicable data protection law:

  • If you wish to raise an objection to the processing of your Personal Data or wish it to be deleted you may do so by notifying us using the contact details below. It may be possible for us to restrict processing of your Personal Data, or to delete it so long as we can still comply with our legal, regulatory and contractual obligations.

  • If you wish to object to direct marketing please notify us using the contact details below or, in the case of emails, if you are a user of the Website you can go to the “Notifications” section of your account settings and you may also use the ‘unsubscribe’ feature which you can find on our emails. To ensure that we respect your request we may retain your contact details on a suppression list.

  • Where we have processed information with your consent then you may notify us using the contact details below to withdraw that consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.

  • If you would like to receive a portable copy of the Personal Data you have provided to us, please notify us using the contact details below.

  • If you have created a Republic Europe account, you can see the Profile Data we hold about you in the “Profile” section of your account on the Website. If you wish to see a copy of all of your Personal Data that we hold, please notify us using the contact details below. A request for a copy of your Personal Data will generally be fulfilled free of charge, but we may charge a reasonable fee if the request is manifestly unfounded, excessive, or repetitive, or if you request multiple copies of the same information.

  • If you have concerns about how we collect and use your data, please contact us at eur-support@republic.com. If you are dissatisfied with our response, you may have the right to raise your concern with the UK Information Commissioner’s Office.

9. Security of your Personal Data

We endeavour to take all reasonable steps to protect your Personal Data, including the use of encryption technology, which you can read more about here. We also require that all Republic Europe employees undergo mandatory data protection training. However, we cannot guarantee the security of any Personal Data you disclose online. In using the Platform, you accept the inherent security implications of engaging in transactions online over the internet, and you agree that you will not hold us responsible for any breach of security unless we have been grossly negligent or in wilful default.

10. Revisions

From time to time we may update this Privacy Notice. We will post any Privacy Notice changes on this page and, if the changes are significant, we will provide a more prominent notice (such as a Platform notification).

11. Communicating with us

If you wish to make a notification to us, or have any questions about this Privacy Notice, you can reach us by sending a letter to:

Data Protection Team
Seedrs Limited (trading as Republic Europe)
Stylus Building, 112-116 Old Street
London EC1V 9BG
United Kingdom

or by sending an email to dataprotection@republic.com.

Investing involves risks, including loss of capital, illiquidity, lack of dividends and dilution, and should be done only as part of a diversified portfolio. Please read the Risk Warnings before investing. Investments should only be made by investors who understand these risks. Tax treatment depends on individual circumstances and is subject to change in future.

This webpage has been approved as a financial promotion by Seedrs Limited (trading as Republic Europe) ("Republic Europe"), which is authorised and regulated by the Financial Conduct Authority with firm reference number 550317. It is not intended to be a promotion of any individual investment opportunity and is not an offer to the public. The summary information provided about investment opportunities on this webpage is intended solely to demonstrate the types of investments available on the Republic Europe platform, and any investment decision should be made on the basis of the full campaign. Full campaigns are available to investors who have become authorised to invest on the Republic Europe platform. All investment activities take place within the United Kingdom, and any person resident outside the United Kingdom should ensure that they are not subject to any local regulations before investing.

Republic Europe does not make investment recommendations to you. No communications from Republic Europe, through this website or any other medium, should be construed as an investment recommendation. Further, nothing on this website shall be considered an offer to sell, or a solicitation of an offer to buy, any security to any person in any jurisdiction to whom or in which such offer, solicitation or sale is unlawful. Republic Europe does not provide legal, financial or tax advice of any kind. If you have any questions with respect to legal, financial or tax matters relevant to your interactions with Republic Europe, you should consult a professional adviser.