EFFECTIVE DATE: 12th May 2021

GoodFi Privacy Notice

At GoodFi we take your privacy very seriously. Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

When we collect and process your personal data we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to any services we provide to individuals in the European Economic Area (EEA).

Who are we?

This privacy notice is issued by GoodFi Limited (GoodFi), a private company limited by guarantee and without a share capital, incorporated and registered in England under company number 13229708. GoodFi operates as a not-for-profit company. More details on GoodFi’s objectives and governance can be found at https://www.goodfi.com/about

Meaning of personal data

Personal data means any information relating to an identified or identifiable individual (known as the data subject). Personal data includes information irrespective of how it is stored. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data. Common examples of personal data include an individual’s name, address, contact information, photograph, IP address and information about the individual such as their age or employment status.

Special category personal data means personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data (when processed to uniquely identify an individual), or data concerning health, sex life or sexual orientation.

Personal data we collect about you

As further explained in this privacy notice, we collect personal data throughout our relationship with you. That data may include:

  • your name and contact information, including email address and telephone number and company details
  • demographic information such as gender, age, date of birth or nationality
  • information you choose to give us relating to:
  • your personal or professional interests, education and employment
  • your experience using DeFi services 
  • your online and social media presence
  • visual images, such as photos you provide to us
  • information about how you use our website (which may include location data associated with your use of the website)
  • your responses to surveys, competitions and promotions

The above list is not exhaustive, and GoodFi may also collect and process other personal data to the extent that this is considered necessary for providing our services or compliance with legal requirements.

How your personal data is collected

We collect most of this personal data directly from you – in person, by email or via our website. However, we may also collect information:

  • from publicly accessible sources such as online directories, social networks and internet searches
  • directly from GoodFi’s third party partners
  • from cookies on our website – for more information on our use of cookies, please see the section headed ‘Cookies’ below

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, eg:

  • where you have given consent;
  • to comply with our legal and regulatory obligations (referred to as ‘legal and regulatory obligations’ below);
  • for the performance of a contract with you or to take steps at your request before entering into a contract (referred to as ‘contractual obligations’ below); or
  • for our legitimate interests or those of a third party (referred to as ‘legitimate interests’ below

A legitimate interest is when we have a reason to use your information in connection with GoodFi’s activities, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The table below explains what we use your personal data for and why.

What we use your personal data for

Our reasons

Delivering our services and offerings to you

Legitimate interests, ie to offer you the benefit of our services and offerings

Preventing and detecting fraud against you or us

Legitimate interests, ie to minimise fraud that could be damaging for you or us

Ensuring our policies are adhered to, eg policies covering security and internet use

Legitimate interests, ie to make sure we are complying with our own internal procedures so we can deliver the best services to you

Operational reasons, such as statistical analysis of our user/member base to, monitoring performance metrics, training and quality control

Legitimate interests, ie to be as effective as we can and continually improve our offerings and reach 

Ensuring confidentiality of information where appropriate

Legitimate interests, ie to protect confidential information, or to comply with legal and regulatory obligations

Preventing unauthorised access and modifications to systems

Legitimate interests, ie to prevent and detect criminal activity that could be damaging for you or us, or to comply with our legal and regulatory obligations

Updating user records

Legitimate interests, ie ensuring that we can keep in touch with our user base, or to comply with contractual, legal or regulatory obligations.

Statutory returns

Legal and regulatory obligations

Ensuring safe working practices, staff administration and assessments

Legal and regulatory obligations or legitimate interests (ie to make sure we are following our internal procedures and working efficiently)

Sending you marketing communications 

Legitimate interests, ie to promote our activities and offerings (see under ‘Marketing’ below for more information)

External audits and quality checks

Legitimate interests, eg to maintain accreditations so we can demonstrate we operate at the highest standards; or to comply with our legal and regulatory obligations

We do not generally anticipate collecting or processing any special category personal data. If we do, we will ensure we are permitted to do so under data protection laws, for example: by obtaining your explicit consent; by confirming that the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or where the processing is necessary to establish, exercise or defend legal claims.

Cookies

What are cookies?

We may collect information using 'cookies'. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both 'session cookies' (which expire once you close your web browser) and 'persistent cookies' (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our website. 

Cookies we use

We may use both ‘first party cookies’, which are created and accessed only by us, and ‘third party cookies’, which may be created and accessed by our partners or service providers. The types of cookies used by our website and what they are used for is outlined below: 

Type of cookie 

More details 

First or third party cookies

Essential Cookies 

These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

First party

Functionality Cookies

These cookies allow our website to remember choices you make when you use the website. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-select your preferences every time you visit the website.

The information collected by these cookies is anonymous and cannot track your browsing activity on other websites.

First party

Analytics and Performance Cookies

These cookies are used to collect information about traffic to our website and how users use our website. The information gathered may include the number of visitors, the websites that referred them to our website, the pages they visited on our website, what time of day they visited our website, whether they have visited our website before, and other similar information. We use this information to help operate our website more efficiently, to gather broad demographic information, monitor the level of activity on our website and to improve it.

We use Google Analytics and Hotjar for this purpose. Google Analytics uses its own cookies.

You can find out more information about Google Analytics cookies at https://support.google.com/analytics/answer/6004245 and about how Google protects your data at https://policies.google.com/privacy]
Hotjar uses its own cookies. You can find out more information about Hotjar cookies at https://help.hotjar.com/hc/en-us/articles/115011789248-Hotjar-Cookies and https://www.hotjar.com/legal/policies/privacy/

Third party

Social media cookies

These cookies are used when you share information using a social media sharing button or "like" button on our website or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter. The social network will record that you have done this.
We use the following social media cookies to better understand to show us how visitors found and explored our site, and how we can enhance their experience. It provides us with information about the behaviour of our visitors (e.g. how long they stayed on the site, the average number of pages viewed) and also tells us how many visitors we have had.

Twitter
https://twitter.com/en/privacyhttps://help.twitter.com/en/rules-and-policies/twitter-cookies 

Linkedin
https://www.linkedin.com/legal/cookie-policy

Facebook Pixel
https://en-gb.facebook.com/business/help/471978536642445?id=1205376682832142
https://en-gb.facebook.com/policy.php

Third party

How to disable cookies and consequences of doing so

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser. Many browsers are set to accept cookies until you change your settings. If you do not accept our website’s cookies, you may experience some inconvenience in your use of the website. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our website. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.

Pixel tags 

We and our service providers may also use pixel tags (which are also known as web beacons and clear GIFs) on our website and in our marketing emails to track the actions of users on our website and how people interact with our marketing emails (eg whether they open and/or forward those e-mails). Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages and in e-mails. We may use the information collected via these pixel tags to measure the success of marketing campaigns and compile statistics about usage of the website and engagement with our emails, so that we can manage our content more effectively and make it more relevant to you.

Third party links and integrations

Our website may include links to third party websites and third party plug-ins or integrations. Clicking on those links or enabling those connections may allow third parties to collect or share your personal data. We do not control those third party websites or services and we are not responsible for how they collect or use your personal data. When you leave our website, we encourage you to read the privacy policy of every third party website or service you visit.

Marketing

We may use your personal data to send you updates by email about our activities and offerings. We have a ‘legitimate interest’ in using your personal data for marketing purposes (see section above headed ‘How and why we use your personal data’). 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 at hello@goodfi.com;
  • using the ‘unsubscribe’ link in emails; or
  • updating your marketing preferences via our website (if this function is applicable to you).

We will always treat your personal data with the utmost respect and will never share it with other organisations for marketing purposes without your explicit consent.

Who we share your personal data with

We routinely share personal data with:

  • third parties we use to help deliver our services and run our organisation, eg marketing and communications service providers, website hosts, IT and data analytics service providers, our bank or other financial services providers, and professional services providers such as our lawyers and accountants
  • third parties specifically approved by you, eg social media channels or other third party services you choose to link your account

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you. 

We may also need to:

  • share personal data with external auditors, eg in relation to industry accreditations or the auditing of our accounts or operations; or
  • disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

Where your personal data is held

Personal data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).

Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.

How long your personal data will be kept

We will keep your personal data for as long as required to continue providing services you have requested, and thereafter only for as long as is necessary (eg to respond to any questions, complaints or claims made by you or on your behalf) and in compliance with data protection laws. 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.

Transferring your personal data out of the UK and EEA

To deliver our services to you, it may sometimes be necessary for us to share your personal data outside the UK/EEA, eg with service providers located outside the UK/EEA; if you are based outside the UK/EEA; or where there is a European and/or international dimension to the services we are providing to you. 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.

Adequacy decision

We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include all EEA countries, Gibraltar, 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 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 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. To obtain a copy of the standard data protection contract clauses and further information about relevant safeguards, please contact us.

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, eg 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.

Further information

If you would like further information about data transferred outside the UK/EEA, please contact us.

Your rights

You have the following rights, which you can exercise free of charge:

  • Access: The right to be provided with a copy of your personal data
  • Rectification: The right to require us to correct any mistakes in your personal data
  • Erasure (also known as the right to be forgotten): 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, eg 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: The right to object at any time to your personal data being processed for direct marketing (including profiling); or in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests
  • Automated 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. GoodFi does not currently engage in such automated decision making but should it do so you have the right to object

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.

If you would like to exercise any of those rights, please:

  • email, call or write to us—see ‘How to contact us’ below; and
  • provide enough information to identify yourself and any additional identity information we may reasonably request from you;
  • let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine operational 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.

How to complain

Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have. You also have the right to lodge a complaint with the Information Commissioner or any relevant European data protection supervisory authority. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

Changes to this privacy notice

This privacy notice was last updated on the ‘Effective date’ indicated at the top of the page. We may change this privacy notice from time to time—when we do we will inform you via our website or by email.

How to contact us

You can contact us by post, email or telephone if you have any questions about this privacy notice or the information we hold about you, to exercise a right under data protection law or to make a complaint. Our contact details are as follows:

Post: GoodFi, AW Offices, Argyle House, 29-31 Euston Rd, London NW1 2SD

Email: hello@goodfi.com


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