Privacy Policy

Last updated February 2023

VOYCAP Limited, a company registered in England and Wales, number 12732903, referred to as “VOYCAP,” "we", "us" or "our" in this document, which describes information we collect and how it is used, and applies to all persons that VOYCAP engages with, referred to as “you.” The VOYCAP platform is intended for use by adults over the age of 18 and we do not knowingly collect information on individuals below the age of 18.

Contact details.

If you have any questions about this privacy policy or our privacy practices, please contact us by writing to us at the following address: VOYCAP Limited, 20-22 Wenlock Road, London, N1 7GU, England. You can also contact us by emailing support@voycap.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.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.

1. Information That We Collect

Personal data, or personal information, refers to any information about an individual from which that person can be identified. We may also collect Personal Data about you from publicly available sources for the purposes of completing anti-money laundering, AML, and know-your-client, KYC, checks that are required by regulated financial services firms.

We also collect, use, and share Aggregated Data (such as statistical or demographic data) for any purpose. Aggregated Data could be derived from your personal data, but is not considered personal data in law, as this data will not directly or indirectly reveal your identity.

We do not collect any special categories of Personal Data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to arrange with you. In this case, we may have to cancel or suspend our services.

Third-party links

This platform may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or their handling of your data. When you leave our platform, we encourage you to read the privacy policy of the websites you visit.

2. Data Protection Principles

VOYCAP is committed to protecting the privacy and security of your Personal Data. VOYCAP is a "data controller", meaning that we are responsible for deciding how we hold and use your Personal Data. We will comply with data protection law, which says that Personal Data must be:

• Used lawfully, fairly and in a transparent way
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
• Relevant to the purposes we have told you about and limited only to those purposes
• Accurate and kept up to date
• Kept only as long as necessary for the purposes we have told you about
• Kept securely

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender. This could include photographs of forms of identification and proof of address.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data (which may include bank account details).
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this platform.
• Profile Data includes your username and password, your transactions, your interests, preferences, feedback, and survey responses.
• Usage Data includes information about how you use our platform, products, and services.
• Communications Data includes your preferences for receiving messages from us.

Cookie Preferences

Cookies are text files containing small amounts of information, which your computer or mobile device downloads when you visit a website. When you return to websites - or visit websites that use the same cookies - they recognise these cookies and therefore your browsing device.

The type of cookies used on VOYCAP can be put into 1 of 4 categories, based on the International Chamber of Commerce guide to cookie categories: Strictly Necessary, Performance, Functionality & Profile and Targeting.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Forum discussions

Our Site offers forums for community discussions. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal data from our forums, contact us at support@voycap.com. In some cases, we may not be able to remove your personal data, in which case we will let you know if we are unable to do so and why.

4. Lawful basis for processing

We only process your data (which may include providing it to a third party) where we have identified a valid lawful basis to do so. The valid lawful basis we rely on are as follows:

• Contractual obligation – Where processing is necessary to comply with our obligations arising out of a contract, for example, taking payment.
• Legitimate Interest – Where we use legitimate interests, we will record our decision on making this decision. We rely on legitimate interest where processing of the data we hold about you does not, in our opinion, affect your rights or freedoms and is proportionate to our interests e.g., obtaining your feedback on our service.
• Consent – We will seek to obtain your consent to process your data outside our contractual obligations (see above) unless we have identified a Legitimate Interest (see above).

Referrals

If you choose to use our referral service to tell a contact about Our Site, we will ask you for your contacts' name and email address. You must have consent from your contact to provide this information to us. We will automatically send your contact a one-time email invitation to visit the site. VOYCAP stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program. Your contact may contact us at support@voycap.com to request that we remove this information from our database.

5. How we use your personal data

We will use your personal data in the following circumstances:

• Where we need to comply with a legal obligation
• Where we need to enter or perform a contract with you
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• Where you authorised us to do so

Note that we may process your personal data for more than one lawful purpose depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data, where more than one ground has been set out in the table below.

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 that is compatible with the original purpose. If you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the details at the beginning of this document.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of your personal data

We will keep your information within the organisation except where disclosure is required or permitted by law, or when we use third party service providers (data processors) to supply and support our services to you. Where we use third party processors, we have contracts in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

Please see below the list which sets out the categories of recipients of personal data.

Service providers who may receive your personal data

• IT Support Services
• Marketing Support Services
• Anti-money laundering Service Providers
• Email Provider
• Secure document disposal service
• Banks
• Government Agencies, such as HM Revenue and Customs
• Online payment providers
• Accountants
• Solicitors
• Advisors

If you opt to proceed with investment opportunities we match via our platform, your Personal Data may also be shared with the relevant company or their professional representatives. Your Personal Data may also be shared with any company that you contact directly. We have no responsibility or liability for how your Personal Data is handled by companies you provide your data to via our platform (or directly).

We may also share personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International Transfers

Your data is stored by us and our processors in the UK or in another country in accordance with the applicable data protection laws.

8. Payments

Please refer to our terms and conditions of service for details of the payments we may take from you or process.

We use a third-party payment provider to take payments from you. The following additional terms apply to our payment provider.

9. Connected third party services

Where you have used a third-party social media account to set up or login to your VOYCAP account, we may receive data from, or share data with, those third-party social media platforms. Their privacy policies will apply in addition to this privacy policy and shall take precedence if their terms conflict with this policy.

10. Data Security

All information you provide to us via email, or Our Site is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of Our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. The security of your personal data is important to us. When you enter sensitive information (such as bank account information) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on Our Site, you can contact us at support@voycap.com

Payment security

All payments made to VOYCAP are processed via external payment providers conforming to the highest level of security. Any payment provider we use has been audited by a PCI-certified auditor and is certified to PCI Service Provider Level 1. This is the most stringent level of certification available in the payments industry.

Security audits

We use recognised and accredited third parties to perform regular penetration tests of our platform and internal networks across our offices. Any output is reviewed and prioritised with high importance.

Third party security

Like many businesses, we use certain third parties to support the services we provide to our users. We constantly review the security and suitability of any third parties as part of our ongoing processes.

Staff training

VOYCAP employees are required to undertake cybersecurity awareness training and acknowledge and be compliant with internal security processes across hardware and software. These are reviewed and updated regularly.

11. Data Retention

By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.

Otherwise, we will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for more than six years in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us using the contact details in Section 1.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

12. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data (though please note that your rights may be limited under certain circumstances). For example, you may have the right to:

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 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:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• 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.
• 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 using the details provided at the start of the policy.

No fee usually required.

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 could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond.

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