1. Introduction
ImVivo ("we", "our", or "us") is committed to safeguarding the privacy and security of your personal information. This Privacy Policy describes how we collect, process, store, and disclose your data when you access or use our website, platform, and related services. We process personal data in accordance with applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
2. Information We Collect
We may collect the following categories of personal data:
2.1 Information You Provide Directly
- Identity Data: Full name, date of birth, nationality, government-issued identification documents;
- Contact Data: Email address, telephone number, residential address;
- Financial Data: Bank account details, payment card information, source of funds documentation;
- Profile Data: Username, password, investment preferences, trading experience, risk tolerance;
- Communication Data: Records of correspondence, support tickets, feedback, and survey responses.
2.2 Information Collected Automatically
- Technical Data: IP address, browser type and version, operating system, device identifiers, screen resolution;
- Usage Data: Pages visited, time spent on pages, navigation paths, click patterns, feature usage;
- Transaction Data: Details of trades executed, deposits, withdrawals, account balances, order history;
- Location Data: Approximate geographic location derived from your IP address.
3. How We Use Your Information
We process your personal data for the following purposes:
- To create, verify, and administer your account on our Platform;
- To facilitate and execute financial transactions on your behalf;
- To comply with our legal and regulatory obligations, including anti-money laundering (AML) and know-your-customer (KYC) requirements;
- To provide customer support and respond to your enquiries;
- To improve, personalise, and optimise the functionality of our Platform;
- To detect, prevent, and investigate fraud, security breaches, and other prohibited activities;
- To send you service-related communications, including account notifications and security alerts;
- To conduct research, analytics, and statistical analysis to enhance our services;
- To deliver marketing communications where you have provided your consent or where we have a legitimate interest to do so.
4. Legal Basis for Processing
We rely on the following legal bases for processing your personal data:
- Contractual Necessity: Processing required to perform our contractual obligations to you;
- Legal Obligation: Processing necessary to comply with applicable laws and regulations;
- Legitimate Interests: Processing for purposes that are in our legitimate business interests, such as fraud prevention, platform improvement, and direct marketing, provided these interests are not overridden by your rights;
- Consent: Where required, processing based on your freely given, specific, informed, and unambiguous consent.
5. Data Sharing and Disclosure
We may share your personal data with the following categories of recipients:
- Service Providers: Third-party vendors who assist us in operating our Platform, including payment processors, cloud hosting providers, analytics services, and customer support tools;
- Regulatory Bodies: Financial regulatory authorities, tax authorities, and law enforcement agencies as required by law;
- Professional Advisers: Lawyers, auditors, and accountants who provide professional services to us;
- Business Transfers: In connection with any merger, acquisition, reorganisation, or sale of assets, your data may be transferred to the relevant parties.
We do not sell your personal data to third parties for their marketing purposes.
6. International Data Transfers
Your personal data may be transferred to, stored in, and processed in countries outside the United Kingdom or European Economic Area. Where such transfers occur, we ensure that appropriate safeguards are in place, including Standard Contractual Clauses approved by the relevant authorities, to protect your data in accordance with applicable data protection laws.
7. Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, regulatory, accounting, or reporting requirements. Upon expiration of the applicable retention period, your data will be securely deleted or anonymised. Retention periods vary depending on the category of data and the purpose of processing, but we typically retain account data for a minimum of five (5) years following account closure, in accordance with regulatory requirements.
8. Data Security
We implement robust technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include, but are not limited to, 256-bit SSL/TLS encryption, multi-factor authentication, regular security assessments, access controls, and employee training. However, no method of transmission over the internet or electronic storage is entirely secure, and we cannot guarantee absolute security.
9. Your Rights
Under applicable data protection legislation, you may have the following rights:
- Right of Access: The right to obtain confirmation of whether we process your personal data and to request a copy of such data;
- Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
- Right to Erasure: The right to request deletion of your personal data in certain circumstances;
- Right to Restriction: The right to request that we restrict the processing of your data in certain situations;
- Right to Data Portability: The right to receive your personal data in a structured, machine-readable format;
- Right to Object: The right to object to processing of your data based on legitimate interests or for direct marketing;
- Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us using the details provided below.
10. Third-Party Links
Our Platform may contain links to external websites or services that are not operated by us. We have no control over the content, privacy policies, or practices of these third-party sites. We encourage you to review the privacy policy of every external site you visit. ImVivo accepts no responsibility or liability for the privacy practices of any third-party websites.
11. Children's Privacy
Our Platform and services are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected personal data from a child, we will take prompt steps to delete such information from our records.
12. Changes to This 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 notify you of any material changes by posting the updated policy on our Platform with a revised "Last updated" date. We encourage you to review this policy periodically.
13. Contact Us
If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us:
Email: [email protected]
Address: 30 Stamford St, London SE1 9LQ, United Kingdom
UK Phone: +44 204 638 3445
AU Phone: +61 2 7248 9809
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you believe your data protection rights have been infringed.