Last updated 25 June 2024
Appital GmbH provides its services in investment brokerage in financial instruments within the meaning of Section 2 clause 2 no. 3 of the German Securities Institutions Act (Wertpapierinstitutsgesetz; „WpIG”) as tied agent exclusively for the account and under the liability of AHP Capital Management GmbH, Weißfrauenstraße 12 - 16, 60311 Frankfurt am Main. According to the legal requirements, we are obliged to provide our customers with the following information about AHP Capital Management GmbH and its investment services: MiFID Information
Appital Limited (“Appital”, “us”, “our” or “we”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use our software platform and marketplace (“Platform”) and any other Appital sites (including https://appital.io/) and applications offered or made available by Appital (“Services”) and tells you about your privacy rights and how the law protects you.
We may update the terms of this privacy policy from time to time so please check it regularly for any updates. Your continued use of the Platform and/or Services following any update to this privacy policy will constitute your acceptance of those changes.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1.1. ABOUT US
We are Appital Limited, a company incorporated and registered in England and Wales with company number 11282881 and have our registered address at 222 Regent St., London W1B 5TR.
1.2. PURPOSE OF THIS PRIVACY POLICY
This privacy policy explains how we collect and process your personal data when you use our Platform and Services. Please read this privacy policy carefully as it contains information about:
what personal data we may collect from you; how we will use, store and protect your personal data; and with whom we may share your personal data.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where information relating to identity has been removed (anonymous data).
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
This website is not permitted for use by individuals below eighteen years of age and we do not knowingly collect data relating to such individuals.
1.3. THIRD PARTY LINKS
The Platform and Services 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. If you leave our Platform or Services, we encourage you to read the privacy policy of every website you have visited.
Appital is the data controller and is responsible for any of your personal data that we process. You can contact Appital via the contact details at section 12 below if you have any questions with regards to this privacy policy or our privacy practices.
3.1. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
3.2. 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature on the Platform or Services. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
3.3. We do not collect any special categories of personal data about you (this includes details about your race, ethnicity, religious or philosophical beliefs, sex life, 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.
4.1. We use different methods to collect data from and about you including through:
5.1. Under the applicable data protection laws, we must have a lawful basis in order to process your personal data. The legal bases on which we may process your data are:
5.2. We use the personal data we collect to:
5.3. We also use information that we collect about you for operational purposes, including to:
6.1. We may send marketing communications to you about the Platform and our Services. To opt-out from receiving marketing communications you may contact us at any time at privacy@appital.io. We will process your request to opt-out of marketing within 30 days of receipt.
6.2. Where you opt out of receiving these marketing communications, this will not apply to personal data provided to us as a result of the purposes specified in section 5 above.
7.1. There may be circumstances in which we may also need to share your personal data with certain third parties, including third parties located outside of the United Kingdom and European Economic Area (EEA). The third parties to which we may transfer your personal data include:
7.2. 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.
7.3. We will only transfer your personal data outside the UK or EEA where suitable safeguards have been put in place by the receiving party. These safeguards are intended to ensure a similar degree of protection is afforded to your personal data wherever it may be transferred and include:
If you give us data (including personal data) on behalf of someone else, you confirm that the other person has given you permission to act on his/her behalf and has agreed that you can:
9.1. We are committed to ensuring that your personal data will be treated confidentially and securely. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
9.2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9.3. Although we take all steps reasonably necessary to ensure that your personal data is treated securely, you should be aware that the transmission of information via the Internet is not completely secure and we cannot guarantee the security of your data during its transmission.
10.1. 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 a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
10.2. 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.
10.3. In some circumstances you can ask us to delete your data: see below for further information.
10.4 In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
11.1. You have certain rights in relation to the personal data we process and hold about you. These include:
11.2. If you would like to exercise any of the above rights, please:
11.3. We will respond to requests made by you within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. We will not usually charge a fee for you to exercise any of the rights listed above. 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.
12.1. You should be aware that you have the right to raise any concerns in relation to how we process your personal data to the Information Commissioner’s Office (ICO).
12.2. If you have any questions about this privacy policy or our privacy practices, please contact us using the details below.
Our full details are: