Privacy & Cookie Policy

Introduction

Welcome to Pynk!

Our 'Crowd Wisdom' system combines our crowd, experts and A.I. to make smarter investment decisions. We’re here to build a Pynker future, because we’re all PYNK on the inside.

We work hard to protect your personal information and ensure your information is kept private and secure. The following privacy policy outlines the types of personal information that Pynk collects through our website and our web application.

This privacy policy is issued on behalf of the Crowdsense Limited so when we mention ”Pynk”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Crowdsense Ltd responsible for processing your data. Crowdsense Ltd is the controller and responsible for this website for the purposes of the Data Protection Act 1998. Crowdsense Ltd is a private limited company, registered in England. Its registered company number is 11339494, and its registered office is at 20-22 Wenlock Road, London, England, N1 7GU.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the above postal address or the following e-mail address: hello@pynk.io.

Privacy is important to Pynk. We will never rent or sell your personal information to anyone. If you have any questions or if you believe that Pynk has not adhered to this privacy policy, please pop us a message at hello@pynk.io.

Why we have a Privacy Policy

We are committed to respecting and protecting your privacy. This Privacy Policy sets out the type of information we collect from you and what we do with that information.

Information we may collect about you

You may give us information about yourself by accessing our website www.pynk.io and beta.pynk.io, by using the service (on the website or web application) or by corresponding with us by phone, e-mail or otherwise.

We ask our users for no more personal information than necessary.

Pynk needs to collect personal information from our users and prospective users in order to provide services to you and fulfill our legal obligations.

The “Know Your Client” information forms we ask clients to complete elicit only the information we need for contractual, regulatory and income tax requirements including: name, address, phone numbers, email addresses, birth date, government issued identifiers for tax and national insurance reporting purposes, asset holdings and values, investment knowledge and objectives. We also collect your current account information and optional beneficiary information (e.g. spouse’s name and occupation, children’s and dependents’ names and ages).

Our application forms for our accounts elicit only the information needed to register these accounts with the government including: government issued identifiers, spouse’s or designated beneficiary’s name, birth date and address. We do not disclose any non-public personal information to any third party except as required by law or as outlined in this notice. We also collect your responses to a risk questionnaire and other regulatory questions that we are required by law to collect.

Marketing Communications: From time to time, we may obtain your consent to send you email, SMS text messages and other communications about Pynk products, services, or events that may be of interest to you. You can opt-out of receiving marketing and promotional email from us by following the unsubscribe instructions contained in each of our email communications. Please note that you will continue to receive email regarding your account and transactions with us. Alternatively, you can unsubscribe from any of our marketing communications by contacting us at hello@pynk.io

Employment: If you inquire about or apply for a job with Pynk, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related information). We use this information for the purpose of processing and responding to your application for current and future career opportunities.
Technical Information: IP address and login details, details about the device you are using to access this website.
Sensitive Information: We may on occasion ask you to provide sensitive personal data as defined in the Data Protection Act 1998. Where we does so, we will request your explicit consent for the use of such sensitive personal data.

Information you give us on sign up

This is information necessary to provide the basic Pynk service (to fulfil the contract between us) and to comply with regulatory obligations to ‘Know Your Customer’ (KYC):
• First and last name
• Email
• City and Address
• Date of birth
• Nationality

In addition, we may ask you for:
• Gender
• Education Levels

You may also indirectly provide us with information through your consents, preferences and feedback.

Information you may provide us upon request

This is information we may request from you to perform our regulatory obligations as part of the KYC process:
• Identity documents and address proof — for example, a picture of your passport or driving licence

Others we share your data with

We use service providers that we can fulfil the contract we have with you. With that in mind we use certain trusted service providers and these providers will each handle your personal data in accordance with their own Privacy Policy. The most important service providers are highlighted below:

When you use the Website, the Apps, Newsletters and interact with our Services, we may use technology such as that provided by Google Analytics, Active Campaign, Vyper, Facebook, LinkedIn and/or Countly to collect information about your visit to our Website and use of the App and/or Newsletters. In essence, these tools enable us to analyse how you and others interact with our Website, Apps and Newsletters. The information we collect may include:

• your IP address;
• the type of browser you use (e.g. are you using the Chrome or Safari browser?);
• the number of sessions per browser on each device;
• the type of device (eg Samsung) and operating system (eg Android) you are using;
• referrer information;
• time zone;
• if you opened our newsletters;
• user preferences; and
• which pages you visited.

We may share anonymised usage data which does not identify you specifically with third parties. We may combine your data with those of other users of our Website, Apps and Newsletters and share this information in aggregated and anonymised form with third parties to help us improve the design and delivery of our software tools, increasing the effectiveness for all users and to allow us to monetize our Website, Apps and Newsletters, which enables us to provide our Services to you.

NAME OF THIRD PARTY & WHY WE WORK WITH THEM

Google Analytics - To monitor Website performance and user experience.
Google Apps for Work - To process emails.
SendGrid - To provide you with our Newsletters and improve the user experience.
Active Campaign - To provide you with our Newsletters and improve the user experience.
Countly - To monitor Apps performance and user experience.
Vyper - To track your referrals in our Newsletter Contest.
One Signal - To send notifications to our subscribers only.

Aggregated and Prediction Data — we may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and non-personally identifiable information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes. This is not considered personal data under GDPR as it can’t be used to directly or indirectly identify you.

Business Transfers — in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets. If Pynk (Crowdsense Ltd) or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

Why we need your personal data

We limit the use of data where possible and try our best to use what is strictly needed at any given time. We collect and process your data for one or more of the following reasons:

To fulfil our contract with you

Where necessary, we use your personal data to provide you with our products and services in line with our overall contract. We process and use your personal data to provide you with a personalised service and/or the product or service you have requested, to fulfil your other requests, process your order(s) and as otherwise may be necessary to perform or enforce the contract between us.

We are required to do so by law or regulation

We are required to process and store some of your data in order to fulfil our regulatory obligations. This may include the information we need to establish your needs and requirements and/or to provide you with a personalised recommendation or advice. We may capture and share your personal data with organisations who can confirm your identity and provide information which helps prevent fraud or other financial crimes. We may also be required to share your personal details where requested by legal authorities or with the Financial Ombudsman.

You have provided us with your consent

Where you have given your informed consent, we will process your data in accordance with the permission you have given us and this Policy. You may withdraw your consent at any time.

How long we keep your personal data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes, and we may also use such data to enable us to respond to any future complaints, or to share information with the Financial Conduct Authority who regulate us.

We will only send your data outside of the European Economic Area (‘EEA’) to:

• Follow your instructions
• Comply with a legal duty
• Work with our suppliers who help us to run your accounts and services
• If we do transfer your personal information outside the EEA to our suppliers, we will make sure that it is protected to the same extent as in the EEA. We’ll use one of these safeguards
• Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA
• Put in place a contract with the recipient that means they must protect it to the same standards as the EEA
• Transfer it to organisations that are part of Privacy Shield where possible. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA

Your Legal Rights

Under certain circumstances, you have rights under the data protection laws in relation to your personal data.
• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c)where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

How to complain

Please let us know if you are unhappy with how we have used your personal information. You can contact us using by calling live chat, email, or via secure messaging.
You also have the right to complain at any time to the Information Commissioner’s Office. Find out on their website how to report a concern https://ico.org.uk/. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

How You Accept This Policy

By using and continuing to use the Pynk websites, mobile apps and/or services, or otherwise providing us with personal information (such as an email address) you agree to the terms and conditions of this privacy policy and any updates thereto. This policy may change from time to time. This is our entire and exclusive privacy policy and it supersedes any earlier version. Our Terms and Conditions take precedence over any conflicting privacy policy provision.

Changes to the Policy

We may modify this privacy policy over time without prior notice by posting a new version of this privacy policy, which is your responsibility to review. Any changes to the privacy policy will be reflected on this page and will become effective immediately upon posting. We encourage you to periodically review this privacy policy to stay informed about how we are protecting the personally identifiable information we collect. If changes to the privacy policy are material, we will do our best to notify you via email or through a notification on the site or app. Please check the effective date below to determine if there have been any changes since you have last reviewed the Betterment privacy policy.

Children

Our service is not directed towards anyone under the age of 18. If a parent or guardian becomes aware that his or her child under the age of 18 has created an account with Pynk and/or provided us with personally identifiable information, please contact us at hello@pynk.io. Additionally, if we become aware at any point that a child under the age of 18 is using our service, we will terminate his or her account.

Cookie Policy

Cookies are small data files of information that a website or mobile application transfers to your hard drive or mobile device to store and sometimes track information about you. Although cookies do identify a user’s device, cookies do not personally identify users.
Additionally, mobile devices may use other tracking files which are similar to cookies (for example iOS devices use Apple’s ‘identifier for advertisers’ (IDFA) and Android devices use Google’s Android ID). In the context of tracking within an App, the concept of a cookie will include an IDFA and an Android ID for the purpose of this Cookie Policy.

Why do we use cookies?

Our website and App use cookies to distinguish you from other users. This helps us to improve our website and App and to provide you with a good experience when you browse our website or use our App.

What types of cookies we use?

We may use the following cookies:

1. Strictly necessary cookies: these are cookies that are required for the operation of a website and App, such as to enable you to log into secure areas.
2. Performance cookies: these types of cookies recognise and count the number of visitors to a website and users of an App and to see how users move around in each. This information is used to improve the way the website and App work.
3. Functionality cookies: these cookies recognise when you return to a website or App, enable personalised content and recognise and remember your preferences.
4. Targeting cookies: these cookies record your visit to a website or App, including the individual pages visited and the links followed.

Generally, the strictly necessary cookies and some performance and functionality cookies only last for the duration of your visit to a website or expire when you close an App: these are known as ‘session cookies’. The functionality cookies and some targeting and performance cookies will last for a longer period of time: these are known as ‘persistent cookies’.

Third party cookies

Some of the persistent and session cookies used by our website and App may be set by us, and some are set by third parties who are delivering services on our behalf. For example, we use Google Analytics to track what users do on the App so we can improve the design and functionality.

Blocking cookies

Most websites, mobile devices and apps automatically accept cookies but, if you prefer, you can change your browser, device or app settings to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser or device. To block the IDFA on your iOS mobile device, you should follow this path: Settings > General > About > Advertising and then turn on ‘Limit Ad Tracking’. To block Android ID on your Android device, you should follow this path: Google Settings > Ads and then turn on ‘Opt out of interest-based ads’.

Please note however, that (as with other websites and apps) by blocking or deleting cookies used on our website or App you may not be able to take full advantage of our website or App.

CrowdSense Limited is a company registered in England and Wales (No. 11339494).
DISCLAIMER: Please remember that the past performance may not be indicative of future results. Different types of investment involve varying degrees of risk, and there can be no assurance that the future performance of any specific investment, investment strategy, or product made reference to directly or indirectly on this site, will be profitable, equal any corresponding indication historical performance level(s), or be suitable for your portfolio.