Privacy Policy

Owner and Data Controller

Investlinx Investment Management Limited
Ella House, 40 Merrion Square, Dublin
D02 NP96, Ireland

Owner contact email: info@investlinx-etf.com

Types of Data collected

Investlinx Investment Management Limited of Ella House, 40 Merrion Square, Dublin, Ireland (the Company, we, us or our) is committed to protecting and respecting your privacy. This privacy statement (Statement) is intended to ensure that you are aware of how we, as a controller, process your personal data, in accordance with applicable data protection laws, including the EU General Data Protection 2016/679 (GDPR), Data Protection Act 2018, EU Privacy and Electronic Communications Directive 2002/58/EC, and any national implementing laws, as amended or updated from time to time.

It is important that you read this Statement carefully, and any other privacy statements that we may subsequently provide to you, so that you are aware of and understand how and why we are processing your personal data.

SCOPE OF STATEMENT

This Statement applies to visitors to our website (www.investlink-etf.com) (the Website). This Statement should be read in conjunction with our Cookie Policy, which is accessible here: Cookie Policy – Investlinx (investlinx-etf.com). It applies to all personal data collected, maintained, transmitted, stored, retained, or otherwise used (i.e. processed) which is collected by us via the Website or through our email alias (info@investlinx-eft.com), regardless of the media on which that personal data is stored.

WHAT IS PERSONAL DATA?

‘Personal Data’ is defined as any data relating to a living individual who can be identified directly from that data or indirectly in conjunction with other information. There are circumstances where we invite or request individuals to provide us with their personal data through our Website. We will collect some or all of the categories of data set out in the ‘Purposes and Basis for Processing’ section of the Statement below.

HOW IS YOUR PERSONAL DATA COLLECTED?

We collect personal data about you which you volunteer when you sign up to our mailing list, sign up to receive marketing emails, or by making enquiries via info@investlinx-eft.com. In addition to the information you provide to us, we collect certain additional information when you visit the Website, as explained in more detail in our Cookie Policy.

Purpose and Basis for Processing

We will hold, process and may disclose the personal data provided by you for the purposes and on the legal basis set out in the table below.

Category of Personal Data	Purpose for Processing	Legal Basis
Contact / identifying details including name, address, email address, and any other information you provide to us via online forms or using our email alias.	We will collect and store your email address, and any other personal details you elect to disclose to us, in order to respond to your enquiries.	Our legitimate interests in managing our business (including business administration). Processing is necessary for compliance with a legal obligation to which the Company is subject.¹
	We will collect and store these details in order to add you to our marketing mailing emails list / send you direct marketing communications.	Your consent where required. Our legitimate interests in managing our business operations where relevant (including business development).
	Communicating with you about investment opportunities.	Our legitimate interests in managing our business (including business administration). The processing of this data is necessary for performance of our contract with you (i.e. processing carried out in anticipation of entering into a contract).
Device and Browser Information (e.g. device characteristics, device signals, usage information, information from cookies and other tracking technologies, information, information about the network you are connected to, IP addresses, etc.)	Monitor and analyse web traffic / carry out analytics using cookies and other tracking technologies.	Your consent.
	To improve our Website and to make sure it works correctly.	Our legitimate interests in optimising the functionality of our Website.
We may also need to use the personal data collected via our website for the purposes of establishing, exercising or defending legal proceedings.

Please note that you have a right to object to processing of your personal data where that processing is carried on for our legitimate interest.
We do not intend to process any special categories of personal data relating to you via the Website.

Please note that where legal or regulatory obligations are cited as a legal basis for processing personal data, examples of such legal obligations include, but are not limited to; our obligations under the Companies Act 2014 and the Taxes Consolidation Act 1997.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you by updating this Statement and we will explain the legal basis which allows us to do so.

Recipients of Your Personal Data

Where this is relevant to their roles, Company staff and in some cases, third parties will have access to your personal information. It may also be necessary, from time to time, for us to disclose your personal data to third parties or agents, including without limitation to the following third parties or agents, and others as may be required:

Third parties to assist in the administration, processing and management of certain activities pertaining to the provision of past, current and prospective services, including this Website.
Individuals or companies employed by the Company to carry out specific services, functions or consultancy work including external reference agencies;
Regulatory bodies to whom are obliged or required to disclose information including the Courts and Court-appointed persons;
Insurance or assurance companies;
Legal advisors;
Potential purchasers or bidders;
Relevant Government departments and agencies; and
Other support service providers necessary to assist the Company with the above.

CROSS-BORDER DATA TRANSFERS

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may be processed by personnel operating outside the EEA who work for us, or for one of our suppliers who act on our behalf. To the extent that personal data is transferred outside the EEA, the Company will enter into data transfer agreements, which incorporate the European Commission approved standard contractual clauses, to ensure that relevant personal data is appropriately safeguarded.

DATA RETENTION

We will store your personal data only for as long as necessary for the purposes outlined above; as required by law or regulatory guidance to which we are subject, and for the exercise or defence of legal claims that may be brought by or against us. For further information concerning our data retention practices please see the Contact Us section below.

IF YOU FAIL TO PROVIDE PERSONAL DATA

If you fail to provide us with certain personal data, we may not be able to respond appropriately to queries you send us via info@investlinx-eft.com. Certain functionality may also be unavailable on the Website. Please note that we will tell you when we ask for information that is a statutory or contractual requirement or needed to comply with our legal obligations.

Security and Storage of Personal Data

We are committed to protecting the security of your personal data. We have security measures in place to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, or inappropriately altered or disclosed. In addition, we limit access to your personal information (in both electronic and paper form) to those who have a legitimate and justifiable reason to process that information. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website. Any transmission of personal data is at your own risk. Once we receive your personal data, we use appropriate security measures to seek to prevent unauthorised access or disclosure.

AUTOMATED DECISION-MAKING

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. [We do not envisage that any decisions will be taken about you using automated means, without human involvement in the decision-making process, however we will notify you in writing if this position changes.]

YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

You have the right to request access to, rectification, or erasure of your personal data, or restriction of processing or to object to processing of your personal data, as well as the right to data portability. The following is a summary of what these rights involve:

The right of access enables you to receive a copy of your personal data.
The right to rectification enables you to ask us to correct any inaccurate or incomplete personal data.
The right to erasure enables you to ask us to delete your personal data in certain circumstances, for example where it is no longer necessary for us to process it.
The right to restrict processing enables you to ask us to halt the processing of your personal data in certain circumstances, for example if you want us to verify its accuracy or our legitimate interests in processing it.
The right to object enables you to object to your personal data being processed on the basis of our legitimate interests (or those of a third party). Where we use your personal data for direct marketing purposes, you can always object and opt-out of future marketing messages using the unsubscribe link in such communications.
The right to data portability enables you to ask us to transmit the personal data, that you provided to us, to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party.

In the event that we request, and receive, your consent to process your personal for a specific purpose, you have the right to withdraw your consent at any time. Your withdrawal of consent will not affect the lawfulness of our processing based on consent before its withdrawal. If you wish to exercise this or any of the above rights, please see Contact Us below.
We will respond to your request within one month. That period may be extended by two further months where necessary, taking into account the complexity and number of requests. We will inform you of any such extension within one month of receipt of your request. We may request proof of identification to verify your request. We have the right to refuse your request where there is a legal basis to do so, or if it is manifestly unfounded or excessive, or to the extent necessary for important objectives of public interest.
Please note that these rights are not absolute and may be subject to statutory exemption and/or limitation.
If you have an issue with the way in which your data is being processed, please contact us in the first instance. You also have the right to lodge a complaint with the Office of the Data Protection Commission (DPC) at any time. Contact details of the DPC are available here.

CONTACT US

If you have any questions about how we handle your personal data, or if you want to exercise any of your rights, please contact info@investlinx-etf.com. All requests will be dealt with promptly and efficiently.

CHANGES TO THIS STATEMENT

We reserve the right to change this Statement from time to time at our sole discretion. If we make any changes, we will post those changes here and update the “Last Updated” date at the bottom of this Statement. However, if we make material changes to this Statement, we will notify you by means of a prominent notice on the Website or by email] prior to the change becoming effective.

Last Updated: 20/04/2023

PRIVACY POLICY