Privacy Policy

We last updated our Website Privacy Policy below on 15 August 2022.

Thank you for visiting our website (our Site).

We collect information from visitors to our Site so that we can make improvements to our Site and business and to your user experience when visiting our Site.

We have privacy notices that apply to you, depending on how you interact with us. Please see in particular:

Staff and Job applicants. See here for further information about your privacy rights and how the law protects you as a member of staff or a job applicant.
Vendors/service providers. See here for further information about your privacy rights and how the law protects you.
Shareholders and potential Shareholders. See here for further information about your privacy rights and how the law protects you.
Customers and Loan Applicants. See here for further information about your privacy rights and how the law protects you.

This Privacy Policy applies to visitors to our Site and are referred to in this Privacy Policy as you and your. We are committed to ensuring a safe digital experience for you and we want you to know that we respect your privacy.

This Privacy Policy explains our approach to personal information that we collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information or share it. It also explains your rights with respect to our processing of your personal information.

Please note that this Privacy Policy should be read in conjunction with our Terms and Conditions and Cookie Policy.

Who are we and what do we do? 

Our Site is operated by COIN FinTech Limited (we, us or our) who is the data controller. COIN FinTech Limited registered in England & Wales with registered no. 13354651. Our registered office is at 78a Luke Street, Shoreditch, London EC2A 4XG. We are authorised by the Financial Conduct Authority (No. 950762).

What personal information do we collect and how do we use it

Our primary goal in collecting personal information from you is to: (i) help us improve our Site and services and to develop new services; (ii) investigate or settle inquiries or disputes including monitoring the use of our copyright/IP protected materials; (iii) comply with applicable laws, court orders, other judicial process and the requirements of regulators and our internal policies; (iv) enforce our agreement with you; (v) protect the rights, property and safety of us and third parties, including our other visitors to our Site; (vi) provide support for the provision of our Site and services; and (vii) use as otherwise required or permitted by law.

When you access our Site, we and our technology, website and social media host partners can see:

What you click

What you view
How long you spend on pages
Your country or region
Your unique advertising or other identification numbers allocated to your browser or device
Your device and internet connection details eg the type of device you are using, IP address and details about your internet connection
If you linked to our Site, the last website you visited
If you open an email from us, that you have opened it and what links you have clicked on
Information you tell us if you message us.

How is the information used? 

The information is used:

to enable the Site to operate;
to provide user functionality; and
for user insight and analysis.

This information is also used for the following business administration and legal compliance purposes:

to enforce our legal rights;
to protect the rights of third parties; and
in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

Whist we may not know who you are from this data, we may be able to connect it with other information we hold about you.

We analyse this information together with other personal information that we observe about you from your interactions and use of our Site and any email/text communications we have with you. We use technologies to collect personal information from your devices to monitor traffic and volume to our site and to access information regarding your experiences with our Site and your contact preferences.

Who do we share your personal information with for this purpose? 

We will share the information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities where legally required to do so.

What is our legal basis? 
It is for legitimate purposes and to expand and develop our services.

In particular, we use your personal information for the following purposes:

Your feedback about our services: 
From time to time, we may contact you to invite you to provide feedback about our Site and services in the form of online, postal or telephone surveys. We use this information to help understand how you use our Site and services, to maintain and improve the quality of services provided, to upgrade our Site and to view trends in product offerings and develop further products and targeted offers and services. We also use your feedback to monitor the quality of our services

Who do we share your personal information with for these purposes? 
We will share the information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities where legally required to do so. We may use a third- party service providers to assist us with customer surveys and feedback requests.

What is our legal basis? 
It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.

Marketing communications: 
Where you have consented to receive such marketing communications in the tick box on sign-up, we use information that we observe about you from your interactions with our Site and/or with our services, our email/text communications to you and/or your email address or telephone number, to help connect with you, share information about our products and services and to send you targeted marketing communications.

Who do we share your personal information with for these purposes? 
We will share the information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities where legally required to do so.

What is our legal basis? 
Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, we will only share your personal data with third parties where you have consented to us sharing your data or where we may rely on another lawful right to do so.

Security and Protection: 
We may share your personal information with our third-party agents and contractors for the purposes of enabling them to provide data analysis, customer support, storage and other services to us (for example, our accountants, professional advisors, IT and communications providers) and any entity we may appoint from time to time to evaluate the effectiveness of the Site. These third parties will be subject to appropriate confidentiality arrangements and they will only use your personal information as described in this Privacy Policy. We will also share information with others:

to the extent required by law;
if we restructure our business or we sell or buy any business or assets, in which case we may need to disclose your personal information to the prospective buyer for due diligence purposes; and
if we or substantially all of our company assets are acquired by a third party, in which case the personal information held by us about you will be disclosed to the third-party buyer.

Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details if you have provided them.

Your Rights 
You have the following rights in relation to the personal information we hold about you:

Your right of access 
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information. If you require additional copies, we may need to charge a reasonable fee.

Your right to rectification 
If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal information with others, we’ll let them know about the rectification where possible. Where it is possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to erasure 
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure (where possible). Where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to restrict processing 
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. Where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to data portability 
You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

Your right to object 
You can ask us to stop processing your personal information, and we will do so, if we are:

relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
processing your personal information for direct marketing.

Your right to withdraw consent 
If we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time

Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

How to contact us? 
If you have any questions about this Privacy Policy or want to exercise your rights, please send an email to contact@eldens.co.uk or write to us at:

ELDENS Limited 
29 Curzon Street 
Mayfair 
London W1J 7TL

How do we obtain your consent? 
Where our use of your personal information requires your consent, you can provide such consent:

at the time we collect your personal information following the instructions provided; or
by informing us by e-mail or post using the contact details set out in this Privacy Policy.

Our use of cookies and similar technologies 
Our Site uses certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our to find out more about the cookies we use and how to manage and delete cookies.

Storage and Sharing of Personal Information and International Data Exports 
We store some personal data in data centres in the United Kingdom.

In order to provide you with the services via the Site, we may need to share your personal data with third party service providers. This may involve transferring your data outside the UK and the European Economic Area (EEA). Whenever we transfer your personal data outside the EEA, we ensure that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Where we use service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (including “model clauses”).

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield framework which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your data out of the EEA.

How long do we keep your personal information for? 
We keep your personal information for a period of 1 year from the date of our last interaction with you or such longer period as is required by law or regulation.

If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it shortly afterwards.

Confidentiality and security of your personal information 
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. Our security measures include the use of a hardware firewall to prevent unauthorised access. We may share your personal information with our third-party agents and contractors for the purposes of enabling them to provide data analysis, customer support, storage and other services to us (for example, our accountants, professional advisors, IT and communications providers) and any entity we may appoint from time to time to evaluate the effectiveness of the Website. These third parties will be subject to appropriate confidentiality arrangements and they will only use your personal information as described in this Privacy Policy. We will also share information with others:

to the extent required by law, for example if we are under a duty to disclose your personal information in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights;
if we restructure our business or we sell or buy any business or assets, in which case we may need to disclose your personal information to the prospective buyer for due diligence purposes; and
if we or substantially all of our company assets are acquired by a third party, in which case the personal information held by us about you will be disclosed to the third-party buyer.

Although we exercise adequate care and security there remains a risk that information transmitted over the Internet and stored by computer may be intercepted or accessed by an unauthorised third party.

Changes to this Privacy Policy 
To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will (if we have your contact details) notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to understand how we use your personal information.

IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE SITE.