Privacy Policy

Last updated August 19, 2022

1. Introduction

We are committed to protecting and respecting your privacy. This privacy policy sets out how Finanum Limited, trading as Habstash, uses and protects the information you provide to Habstash.

We may amend this policy from time to time by updating this page. We advise you to check this page regularly. We will notify you should there be any significant and material changes to this policy.

2. Types of Information we may collect

We may collect different types of personal data from you as well as from other providers. Personal data means any information about an individual that allows for the identification of that particular individual.

a. Information you give us

We may collect information you provide when you open and maintain an account with us, fill out surveys and feedback forms, correspond with our support team or contact us for any other reason.

The information could include:

  • Identity data such as your name, date of birth and gender;
  • Contact data such as your address, email address and phone number;
  • Registration data such as your username and password;
  • Financial data such as your income, savings, resources and plans;
  • Other data such as your property status and preferences;
  • Profile and Usage data including feedback and survey responses;
  • Marketing and Communications data such as your preferences in receiving marketing from us;
  • Record of our discussions if you contact us or we contact you.

If you give us personal data about other people such as your spouse/partner or family, you confirm that you have relayed this policy to them and they have consented to this policy.

b. Information we collect and receive from other sources

We work closely with third parties such as technical service providers, advertising networks, tracking and analytics providers and may receive the following information about you when you use our website and/or services:

  • Technical data such as your internet protocol (IP) address, your login information, URL addresses, browser information, plug-in types, the operating system and platform, device type, a unique device identifier, mobile device, operating system and browser information.
  • Usage data such as information about how you use our website, tools and services.
  • Profile data such as your preferences, feedback and survey responses.

 c. Cookies

We may employ common tracking technology such as cookies and pixels to understand how you interact with our website and services for the purpose of providing you an optimal experience and relevant marketing content.

3. Why we may need to collect this information

We may use the data collected for various purposes:

  • Providing our services;
  • Maintaining our services including security, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting;
  • To allow you to participate in interactive features of our services when you choose to do so;
  • Providing customer support;
  • Providing you with updates and notices about your account, email instructions;
  • To notify you about changes to our services;
  • To use data analytics to improve our website, products, services, marketing, customer relationships and experiences;
  • To deliver relevant website content and advertisements to you and understand the effectiveness of the advertising;
  • To provide you with news, special offers and information about products and services that may be of interest to you, unless you have opted not to receive such information;
  • Preparing anonymised statistical datasets;
  • To carry out our legal obligations, enforcing our rights arising from any contracts entered into between you and us and other legal uses;
  • To fulfill any other purpose for which you provide it;
  • In any other way we may describe when you provide the information;
  • For any other purpose with your consent.

Where we need to collect personal data by law or under the terms of a contract we have in place with you, and you fail to provide the data requested, we may not be able to perform the services as per the contract and may therefore be unable to provide you the service.

4. Lawful basis for processing

We must have a legal basis for processing your personal data. We will rely on a number of different legal bases depending on the purpose such as:

  • We need to process your personal data in order to perform the services as per the agreement between you and us;
  • We have a legal obligation to process your personal data;
  • We have a legitimate business interest to process your personal data which is not overridden, or unbalanced compared to your interests and/or fundamental rights and freedoms;
  • You have given us your consent to collect your personal information or send you marketing information or to process;
  • We process your sensitive personal data, sometimes known as special category personal data, to adhere to government regulations or guidance.

5. Disclosing your information

We may disclose personal information that we collect, or you provide to third parties under the following situations:

  • Technical and design service providers who help us to provide our services to you;
  • Analytics and search engine providers that assist us in the improvement and optimisation of our website (for example Google Analytics);
  • Marketing partners to allow us to analyse and improve the effectiveness of our marketing and to therefore be able to target or exclude you from specific marketing campaigns as well as target people who have a similar profile to you;
  • Communications services providers to help us send you emails;
  • Financial or property firms that we may partner with to offer you certain products and services;
  • Where we are under a duty to disclose or share your personal information in order to comply with a legal obligation or in order to enforce or apply our terms and conditions, or to protect our rights (and those of our customers), property, or safety;
  • If we sell or buy any business or assets, in which case we may need to disclose your personal information to the prospective seller or buyer or where we transfer or delegate our rights or obligations as allowed under our terms and conditions.

We require all third parties employed to facilitate our services to treat your personal data in accordance with data protection laws. These third parties have access to your personal data only to perform tasks on our behalf and are obligated not to disclose or use it for any other purpose.

6. Storing your information

a. Security

We are committed to ensuring that your data is retained securely by us. We have put in place appropriate security measures to prevent unauthorised access, disclosure, modification, or destruction of your personal data.

Users will be asked to create a password when setting up an account with us. We ask that you keep this password confidential and not share it with anyone.

While we take all reasonable steps to ensure that your personal data is handled with the utmost care, we cannot guarantee that the storage and transmission of such information, either by email or via our website is absolutely secure.

b. Data Transfer

We may need to transfer your personal data to third parties based outside the United Kingdom or European Economic Area (EEA) in order for us to provide our services. 

We will take all reasonable steps to ensure that your personal data is treated securely and in accordance with this privacy policy. 

c. Data Retention

We will retain your personal data for as long as is necessary for the purposes set out in this privacy policy, including for the purposes of satisfying any legal, accounting or reporting requirements. We will retain and use your personal data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our services, or we are legally obligated to retain this data for longer time periods.

7. Your rights

You may exercise certain rights regarding your personal data as stated below.

a. The right to be informed

You have the right to know what personal data we hold about you, for what purpose and how we process it, as detailed in this privacy policy.

b. The right of access

You have the right to request access to your personal data and obtain a copy of the information held on you.

c. The right of rectification

You have the right to have inaccurate personal data rectified, or incomplete data completed respectively.

d. The right to erasure

You have the right to request erasure of your personal data. We are however required to balance this right with our obligations under law and regulation with respect to record retention.

e. The right to object

You have the right to object to the processing of your personal data when this is based on a legitimate interest. You also have the right to object to the processing of your personal data for direct marketing purposes. However, if there is an overriding reason why we need to use your personal data, we may not be able to accept your request.

f. The right to restrict processing

You have a right to request restriction of processing of your personal data under certain circumstances. In this case, we will not process your personal data for any purpose other than storing it.

g. The right to data portability

You have the right to request the transfer of your personal data to you. Subject to rules and regulations, you have the right to be provided a copy of your personal data in a structured, commonly used, machine-readable format.

h. The right to withdraw consent

You have the right to withdraw consent at any time where we rely on consent to process your personal data. Note, this will not affect lawfulness of any processing carried out before you withdraw your permission. If you withdraw your consent, we may not be able to provide you our services.

i. The right to withdraw consent to marketing

By providing us with your personal information upon signing up for our services, you agree that we can use your information for marketing purposes. We will not disclose your information to third parties for marketing purposes without your permission. You have the right to withdraw consent at any time by clicking on the unsubscribe links on any marketing emails we send you.

j. The right to lodge a complaint

Should you have any complaints about how we process your data, you can contact us by emailing us at [email protected]. You also have the right to contact the relevant data protection authority, which for the United Kingdom is the Information Commissioner’s Office.

Your ability to exercise these rights will depend on a number of factors. In some cases, we will not be able to agree to your request (for example, if we have a legitimate reason for not doing so).

To exercise any of your rights set out above, you can email us at [email protected].

8. Cookies

a. What are cookies?

Cookies are text files with small pieces of data including an anonymous unique identifier, which are used to identify your device. Cookies are sent to your browser from a website and stored on your device. We use cookies on our website and may use similar tracking technologies such as pixels, beacons, tags and scripts.

b. Purpose of cookies 

Cookies can track activity on our website such as how long a visitor spends on our website, which pages he or she visits and which buttons are clicked on. Cookies collect this information and share it with us, the website owner. The information helps us to improve our website and deliver a more optimal experience when you visit our website.  

c. Types of cookies we use 

We may use the following types of cookies: 

  • Necessary

These cookies are used for activities that are strictly necessary to operate or deliver the service you requested from us and, therefore, do not require you to consent. 

  • Basic Interactions & Functionalities

These cookies enable basic interactions and functionalities that allow you to access selected features of our service and facilitate your communication with us. 

  • Experience Enhancement

These cookies help us to provide a personalised user experience by improving the quality of your preference management options, and by enabling the interaction with external networks and platforms. 

  • Measurement

These cookies help us to measure traffic and analyse your behavior with the goal of improving our service. 

  • Targeting & Advertising

These cookies help us to deliver personalised marketing content to you based on your behaviour and to operate, serve and track ads. 

The cookies mentioned above may be either ‘session’ cookies or ‘persistent’ cookies. Session cookies only last for the duration of your visit to a website and expire once you close your browser, while persistent cookies remain on your device and browser for an extended period of time until you erase them or they expire.

d. Third party cookies

We use third party cookies on our website, specifically for the purpose of measurement, targeting and advertising. For example, we use: 

  • Facebook Ads

To understand the effectiveness of our advertising on Facebook and the demographics of users clicking on our ads.

  • Google Ads

To understand the effectiveness of our advertising by tracking how many users click through to our website from a particular ad and the profiles of these users. 

  • Google Analytics

Allows us to observe how many users are visiting our website, which pages they are visiting, how long they are spending on our website and how many visitors are signing up for our services.  

  • Hotjar Analytics

Enables us to understand how our users interact with our website and get your feedback through tools such as heatmaps, session recordings, and surveys.  

  • Twitter Ads

To understand the effectiveness of our advertising on Twitter and what kinds of users are interested in our services. 

e. Managing Cookie Settings 

You can manage your cookie settings through our pop-up cookie banner that appears when you first visit the website. 

You can also manage third party cookies by changing your browser settings on your device. Please note that by blocking cookies you may be not be able to fully use our services. 

9. Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy policy. You should exercise caution and review the privacy policy applicable to the relevant website.

10. Contact Us

If you have any questions about this privacy policy, please contact us by emailing us at [email protected].