Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as “controller” of that personal information for the purposes of those laws.
Key Terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our
Indie Duo OÜ
Personal information
Any information relating to an identified or identifiable individual
Special category personal information
Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Genetic and biometric data
Data concerning health, sex life or sexual orientation
Personal Information We Collect About You
Your name and contact information, including your address, email address, telephone number, account name, social security number, drivers license number, and other similar identifiers;
Information to enable us to check and verify your identity, e.g., your date of birth;
Your gender information, if you choose to give this to us;
Location data, if you choose to give this to us;
Information to enable us to review your investment portfolio, e.g., assets and allocations, holding company information and entity ownerships information
Familial information, such as marital status, offspring, etc.
Your billing information, transaction and payment card information;
Your personal or professional interests;
Your professional or employment-related information
Your professional online presence, e.g., LinkedIn profile;
Your contact history, purchase history, and saved items;
Information from accounts you link to us, e.g., Google, Facebook and others;
Information to enable us to undertake credit or other financial checks on you;
Information about how you use our website, IT, communication and other systems;
Your responses to surveys, competitions, and promotions.
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA); and
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
This personal information is required to provide products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and services to you.
Personal Information We Collect About Others
We collect personal information from contact information you share with us through our website or within your estate planning documents. When sharing this information with us, you are asserting that you have obtained the consent of that individual to share their Personal Information with us. We use information we have collected from you on behalf of someone else in accordance with this policy.
We do not knowingly collect, share, or sell any Personal Information from any person under the age of 18. We restrict the use of any data you submit regarding minors to the specific business purpose of our products and services.
How Your Personal Information is Collected
We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website and apps. However, we may also collect information:
From publicly accessible sources;
Directly from a third party, e.g.,:
Credit reference agencies;
Customer due diligence providers;
Payment processors
Banking institutions
From a third party with your consent;
From your use of our website, including but not limited to keystroke and page specific input data;
From cookies on our website; and
Via our IT systems.
How and Why We Use Your Personal Information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.,:
To provide you with services necessary to meet our obligations per the terms of our website
To comply with our legal and regulatory obligations;
For the performance of our contract with you or to take steps at your request before entering into a contract;
For our legitimate interests or those of a third party; or
Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
What we use your personal information for
Our reasons
To provide products and services to you
For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or Indie Duo OÜ.
To prevent and detect fraud against you or Indie Duo OÜ.
Conducting checks to identify our customers and verify their identity; Screening for financial and other sanctions or embargoes; Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator
To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodies
To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g., policies covering security and internet use
For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training, and quality control
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information
For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems
For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records
For the performance of our contract with you or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns
To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration, and assessments
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services and those of selected third parties to:
existing and former customers;
third parties who have previously expressed an interest in our services;
third parties with whom we have had no previous dealings.
For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers
Credit reference checks via external credit reference agencies
For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services
External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts
For our legitimate interests or those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards.
To comply with our legal and regulatory obligations.
The above table does not apply to special category personal information, which we will only process with your explicit consent.
Promotional Communications
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
You have the right to opt out of receiving promotional communications at any time by:
contacting us
using the ‘unsubscribe' link in emails or ‘STOP' number in texts
updating your marketing preferences on our website
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who We Share Your Personal Information With
We routinely share personal information with:
Companies within the Indie Duo OÜ group;
Third parties we use to help deliver our products and services to you, e.g., payment service providers;
Other third parties we use to help us run our business, e.g., marketing agencies or website hosts;
Third parties approved by you, e.g., social media sites you choose to link your account to third party payment providers, attorneys, accountants, tax advisors, wealth managers;
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. Additionally, we limit the information we share with service providers to only the personal information that is necessary to fulfill our service obligation to you and deliver our products and services to you that are purchased through our website. We may also share personal information with external auditors.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where Your Personal Information is Held
Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: “Who we share your personal information with”).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring your personal information out of the EEA”.
How Long Your Personal Information Will Be Kept
We will keep your personal information while you have an account with us or we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:
To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly;
To keep records required by law.
We will not retain your personal information for longer than necessary. Different retention periods apply for different types of personal information.
Transferring Your Personal Information Out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.,:
With our offices outside the EEA;
With your and our service providers located outside the EEA;
If you are based outside the EEA;
Where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and UK data protection law.
If you would like further information please contact us (see ‘How to contact us' below).
Your Rights Under the GDPR
Access
The right to be provided with a copy of your personal information (the right of access).
Rectification
The right to require us to correct any mistakes in your personal information.
To be forgotten
The right to require us to delete your personal information—in certain situations
Restriction of processing
The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data.
Data portability
The right to receive the personal information 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 information being processed for direct marketing (including profiling);
in certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual 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.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner's Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please email us as referenced below in “How to contact us”.
Your Rights Under the PDPA
Access
The right to be provided with a copy of your personal information (the right of access).
Rectification
The right to request us to correct any error or omission in your personal information.
Withdrawal
The right to require us to delete your personal information—in certain situations.
Restriction of processing
The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data.
If you would like to exercise any of those rights, please email us as referenced below in “How to contact us”.
Your Rights Under the PDPO
Access
The right to be provided with a copy of your personal information (the right of access).
Rectification
The right to request us to correct any error or omission in your personal information.
Withdrawal
The right to require us to delete your personal information—in certain situations.
Restriction of processing
The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data.
If you would like to exercise any of those rights, please email us as referenced below in “How to contact us”.
Use of cookies and similar technologies
Cookies are small text files placed on your computer or other device by websites that you visit. Cookies are widely used in order to make websites and other applications work, or work more efficiently, and help them remember certain information and recognize your internet browser. Cookies may last until you close your browser (“session” cookies) or over repeat visits (“persistent” cookies).
We use cookies and similar technologies to:
Assist you in efficiently and safely navigating and experiencing our services;
Enable you to register, login, provide feedback and otherwise interact with our services;
Store and honor your preferences and settings;
Measure and analyze usage and performance data; and
Assist us with promotional and marketing efforts (including interest-based advertising).
If you access any of our services subject to a subscription agreement or other contract between us and your organization, cookies and similar technologies will be used as necessary for the performance of that contract and for our legitimate business operations related to providing the service.
We use the following types of cookies
Strictly necessary cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work.
Performance cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site.
Functionality cookies: These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.
Targeting cookies: These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. If you do not allow these cookies, you will experience less targeted advertising.
Social media cookies: These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies, you may not be able to use or see these sharing tools.
Anonymized analytical cookies: These cookies ensure that anonymous data about your surfing behavior is collected every time you visit the website. This way we can see how visitors use the website and improve on that basis. We use anonymized analytical cookies for:
tracking the number of visitors to our web pages;
tracking the amount of time each visitor spends on our web pages;
keeping track of the order in which a visitor visits the different pages of our website;
assessing which parts of our site need updating;
measuring and optimizing the performance of our marketing campaigns;
redirecting traffic from different channels.
Details about the cookies set by our websites and by third parties, including service providers acting on our behalf, are listed directly on the site or in the cookie control tool made available on the site.
How to manage cookies and interest-based advertising
You can manage the use of certain types of cookies, including targeting cookies used for personalized advertising, also known as interest-based advertising (IBA), by amending your cookies settings in the cookie control tool made available on the site. You also may be able to block or delete cookies by selecting the appropriate settings on your browser privacy preferences menu.
You can also opt out of IBA by turning off targeting cookies used for IBA via the consumer choice tools created under self-regulation programs in many countries, such as the US-based YourAdChoices, the Canada-based AdChoices or the EU-based Your Online Choices. We adhere to the Digital Advertising Alliance Self-Regulatory Principles for Interest-Based Advertising.
Certain content and features in our services depend on cookies to function. For example, authentication cookies are used to identify and recognize registered users and to enable them to gain access to requested content or features. If you choose to block cookies, you cannot sign in or use certain content or features. If you choose to delete cookies, any settings and preferences dependent on those cookies will be lost.
Use of web beacons and other technologies
Some of our websites, applications and electronic communications contain electronic tags known as web beacons, gifs or pixel tags, unique identifiers and similar technologies that help deliver cookies, measure online activity, provide more relevant advertising, or analyze the effectiveness of our promotional campaigns or other operations.
Keeping Your Personal Information Secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized 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
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
Changes to This Privacy Notice
How to Contact Us
Please contact us by email at info@fff.vc if you have any questions about this privacy policy or the information we hold about you.
Do You Need Extra Help?
If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).