At AAAreserve.com (a website related to Arc Fiduciary Ltd), we aim to be open and transparent about how we treat your personal data. We are committed to safeguarding the privacy of all visitors to our website (Guests) and users who have registered an account with us (Registered Users).
Please read this policy carefully as it sets out the basis on which we collect, process, use and store your personal data whether you are a Guest or a Registered User.
This policy affects your legal rights and obligations so please read it carefully. If you have any questions, you can contact us at email@example.com or by post at the address set out below.
1. Who we are
We are AAA Reserve (a trading name of Arc Fiduciary Ltd) (we, us and our). We provide a platform via our website, accessible via https://www.AAAreserve.com/ (our Website). Our registered address is 28 Esplanade, St Helier, Jersey, JE2 3QA. Our registered company number is 125328.
The data controller in respect of your personal data is AAA Commercialisation Ltd. We are registered with the Information Commissioner’s Office.
2. Personal data we collect
We collect, process, store and use the following kinds of personal data:
You do not need to provide us with any personal data as a Guest. However, even as a Guest we may collect the information set out in paragraph 3 and you may agree to receive Marketing Communications in accordance with paragraph 4.
(b) Registered Users
When you create an account with us, you provide us with your name, email address, date of birth, address and time at the address. We require this information, so we can identify you properly manage your account. We will also store any content and documents you may upload to the Website (for example documents provided for identification purposes).
We may also request other information about you that we require to assess your knowledge and experience in the investment field, financial information, and investment objectives. We require this information so that we can better manage your account.
All personal data that you provide to us must be true, complete and accurate. You must not register under someone else’s name. If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this. In addition, we may search at fraud prevention agencies for information on you as part of our due diligence to ensure we comply with anti-money laundering legislation.
(c) When you contact us
When you contact us by email or post we may keep a record of the correspondence and we may also record any telephone call we have with you.
3. Data we automatically collect
When you use our Website, we, or third parties on our behalf, automatically collect and store information about your device and your activities. This information could include (a) your computer or other device’s unique ID number; (b) your IP address; (c) technical information about your device such as type of device, web browser or operating system; (d) your preferences and settings such as time zone and language; and (e) statistical data about users’ browsing actions and patterns. We collect this information using cookies in accordance with paragraph 8 below and we use the information we collect on an anonymous basis to improve our Website and the services we provide, and for analytical and research purposes.
4. Marketing Communications
If you opt in to receive marketing communications from us you consent to the processing of your data to send you such communications, which may include newsletters, blog posts, surveys, information about new features or products relevant to our service, changes to this policy and our Terms and Conditions. We retain evidence of the details of your consent.
You can choose to no longer receive marketing communications from us by contacting us at firstname.lastname@example.org or clicking unsubscribe from a marketing email. We shall therefore retain your personal data in our records for marketing purposes until you notify us that you no longer wish to receive marketing emails from us.
5. Use of your personal data
If you have provided any personal data to us, we shall only use it in accordance with this policy.
(b) Registered Users
You consent to the lawful processing of your personal data to provide you with the services you have requested from us.
We may also use your personal data for our legitimate interests, including dealing with any customer services you require, for regulatory and legal purposes (such as anti-money laundering), for audit purposes and to contact you with information about your account and to tell you about changes to this policy and our Terms and Conditions.
6. Who do we share your data with?
We may share your personal data with any service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including payment providers, IT service providers, accountants, auditors and lawyers.
If you have consented to receive marketing communications, we use the following third-party marketing services; Mailchimp, Mailchimp Mandrill, Pipedrive, Zoho CRM and SharpSpring. These services enable us to analyse the use of these communications.
Under certain circumstances we may have to disclose your personal data by law, because the police or other law enforcement agency has asked us for it – for example, as part of anti-money laundering processes or protect a third party’s rights, property, or safety or to enforce our Terms and Conditions.
We may also share your personal data in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.
7. Where we hold and process your personal data
Some or all of your personal data may be stored or transferred outside of the European Union (the EU) for any reason, including for example, if our email server is located in a country outside the EU or if any of our service providers are based outside of the EU. We shall only transfer your personal data to organisations that have provided adequate safeguards in respect of your personal data.
A cookie is a small text file containing a unique identification number that is transferred (through your browser) from a website to the hard drive of your computer. The cookie identifies your browser but will not let a website know any personal data about you, such as your name and/or address. These files are then used by websites for a number of reasons, including to identify when users revisit that website. For more information about cookies, you can visit www.allaboutcookies.org
We also use Google Analytics to monitor how our Website is used. Google Analytics collects information anonymously and generates reports detailing information such as the number of visits to our Website, where visitors generally came from, how long they stayed on our Website, and which pages they visited. Google Analytics places several persistent cookies on your computer’s hard drive. These do not collect any personal data. If you do not agree to this you can disable persistent cookies in your browser. This will prevent Google Analytics from logging your visits.
Below is a list of cookies used on our website:
Google Analytics (third party): This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.
Google Analytics (third party): The main purpose of this cookie is performance. It stores and update a unique value for each page visited.
Google Analytics: The main purpose of this cookie is performance it is used to throttle the request rate - limiting the collection of data on high traffic sites. It expires after 10 minutes.
Google Analytics: Contains campaign related information for the user. If you have linked your Google Analytics and AdWords accounts, AdWords website conversion tags will read this cookie unless you opt- out.
We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures. All information you provide to us is stored on our secure servers. Any payment transactions are encrypted using SSL technology.
Where we have given, or you have chosen a password which enables you to access parts of our Website, you are responsible for keeping this password confidential.
However, no system can be completely secure. Therefore, although we take steps to secure your personal data, we do not promise that your personal data that you provide to us will always remain secure.
10. Your rights
You have the right to obtain from us a copy of the personal data that we hold for you, and to require us to correct errors in the personal data that we process for you if it is inaccurate or incomplete. You also have the right at any time to require that we delete your personal data. To exercise these rights, or any other rights you may have under applicable laws, please contact us at email@example.com.
Please note, we reserve the right to charge an administrative fee if your request is manifestly unfounded or excessive.
If you have any complaints in relation to this policy or otherwise in relation to our processing of your personal data, you should contact the UK supervisory authority: the Information Commissioner, see www.ico.org.uk.
Except where we are required to retain your personal data for taxation or accounting purposes, we may retain your personal data for as long as you remain a Registered User and for up to 18 months thereafter in order to comply with our obligations under the Terms and Conditions, for audit purposes and to respond to any queries you have about your account.
If you have consented to receive marketing communication, we may retain your email address until you opt out of receiving such communications.
If you are a Guest who has contacted us with a question or comment, we may retain your personal data for up to 6 months following such contact to respond to any further queries you might have.
If any provision of this policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties and all other provisions shall remain in full force and effect.
This policy shall be governed by and construed in accordance with the law of England and Wales, and you agree to submit to the exclusive jurisdiction of the English Courts.
We may change the terms of this policy from time to time in response to your feedback and suggestions, changes imposed by third party suppliers or the decisions or orders of courts, the Financial Conduct Authority or other authorities, and/or the need to improve or correct problems in the operation of the Website or changes to applicable law.
We will summarise any such changes at the top of this policy. We will try to give 30 days' notice of when changes take effect, by email and/or in your account if you are a Registered Use, except where changes do not materially adversely affect you or are beneficial. If you continue to use the Website after the time we state the changes will take effect, you will have accepted the changes.
Last updated: May 2018