Our policies, terms and conditions
Below is our our privacy and data protection policy:
Ethex Investment Club Ltd (‘Ethex’) is committed to protecting and respecting your personal data and privacy. We recognise that your personal data is your property and that you have provided it to us for specific purposes.
We will only process your personal data in the way that you ask us to, and we will give it back to you at any time, unless we are otherwise required by law, the Information Commissioners Office (ICO) guidance or best practice, or in order to perform our contract with you.
1. This policy
This policy, together with our Terms and Conditions for Registered Users, explains how any personal data we collect from you, or that you provide to us, will be processed by us or any processor on our behalf.
This policy applies to our contract with you. You are therefore advised to read it carefully. Terms used within it shall have the meaning(s) given in the Data Protection Act (1998 (Act) and/or the General Data Protection Regulation (Regulation), as applicable.
By visiting our website located at https://www.ethex.org.uk, or by registering with Ethex and placing orders and Bulletin Board postings, you accept and consent to the practices described in this policy.
We may change this policy from time to time by updating this page. You are advised to check back regularly as any changes will be binding when you continue to use the Website after the date of the relevant change.
For more information relating to your rights under this policy, please see section 10.
If you have any queries relating to this policy, please contact us at firstname.lastname@example.org or by calling 01865 403304.
This policy is effective from 25 May 2018.
2. Who we are
We are Ethex Investment Club Limited, The Old Music Hall, 106-108 Cowley Road, Oxford, OX4 1JE. We operate the website and we are the data controller for the purposes of the Act and the Regulation.
We are registered with the Information Commissioners Officer to process your personal data and our registration number is Z3560212.
Your data will be held on our secure servers physically located in the United Kingdom and managed by Bytemark, who are ISO 27001:2013 certified and compliant with GDPR.
By registering with Ethex, placing orders and/or using our Bulletin Boards and/or otherwise using the Website, you expressly consent to:
- provide us with the personal data necessary to allow you to use the Website and make Investments and/or trade investments via our Bulletin Boards.
- The processing of your data by us or those specifically listed third parties, in accordance with this policy.
You may withdraw your consent at any time. However, where withdrawal of your consent prevents us from verifying your identity or otherwise monitoring who you are, we may not be able to provide our services to you.
4. What we collect
We may collect personal information from you, which may be some or all of the following categories: name, address (including postcode), date of birth, current legal gender, email address, nationality, bank account, IP addresses, copies of your passport and/or driving licence, national insurance number, details of share or bond certificate numbers, your investor categorisation, and other information relevant to our services. This information will only be collected when you choose to supply us with the information.
When you send emails or other communications to Ethex, we may retain those communications in order to process your enquiries, respond to your requests and improve our services.
5. How we collect your data
The data listed in section 4 is collected in the following ways:
- By you providing the information – this is any information that you give to us, at our request, when registering with the Website and/or placing an order and/or placing a bulletin board posting and/or signing up to the newsletter and/or communicating with us via telephone or email.
- Information automatically collected – each time you visit our Website, whether through home, work or a public network, your own computer or mobile device, we will automatically collect: your IP address and your URLS and pages you visit.
- Received from third parties – we work closely with Tracesmart Ltd, our anti-money-laundering supplier, to verify your identity; we may also receive information from the businesses (or their third party suppliers) whom you are investing in or trading investments in, pertaining to your order or Bulletin Board posting to allow us to process your order or posting.
- distinguish you from other users;
- optimise your browsing experience;
- make necessary improvements to our Website;
- recognise and count the number of visitors to our Website and see how they move around the Website during use;
- recognise you when you return to our Website and
- record your visit to our website, including any links you may follow.
7. What we do with your data
If you are a Registered User, or an Ethex Bulletin Board User, the personal information about you is primarily necessary to:
- To undertake anti-money laundering checks as required by Her Majesty’s Revenue and Customs under the Money Laundering Regulations.
- To track the progress of your order or bulletin board posting, and keep you updated on the progress of your investment or posting on the Bulletin Board. Sometimes this will require sharing order details with the business in which you are investing.
- To check that your Registered User details are still up-to-date if you have not used the site for a significant period of time.
- To be able to provide you with an Ethex Innovative Finance ISA account (where requested by you).
We will also use the data you provide to notify you about:
- Projects on our Website that are similar to those you have already invested in, or otherwise enquired about and services similar to those you have already used.
- Changes to our website or services.
You will only receive our newsletter if you have explicitly signed up for this.
As a result of a visit to our Website, we may use any data we collect about you to:
- To monitor and improve our website and our services
- To plan and manage Ethex business activities
- To prevent and detect fraud or abuses of our website
To allow us to comply with any requirements imposed on Ethex by law or court order.
8. How and why we disclose your data
We only disclose your personal data to the following third parties and for the following reasons:
- The relevant business in whom you are investing – to enable us to track the progress of your order, or Bulletin Board posting, and to enable the businesses to maintain an up-to-date register of investors.
- Our anti-money laundering specialist, Tracesmart Ltd, trading as LexisNexis – in order for us to be able to verify your identity, where required as part of the investment process
- Our transaction email providers in order for us to be able to send emails and newsletters (where appropriate) to you:
- SendGrid (NB only your email address is passed to SendGrid)
- The Rocket Science Group LLC (Trading as Mailchimp) (only your email address, full name, investor categorisation are passed to Mailchimp)
- Our appointed technology provider, Siftware Ltd – to enable them to develop and maintain aspects of our technology infrastructure, including systems storing data.
- Our appointed IFISA Manager and Receiving Agent - to able them to provide you with an Ethex IFISA account (where appropriate).
- ShareIn Ltd - ISA Manager (your full name, date of birth, residential address(es), national insurance number are passed to ShareIn)
- Woodside Corporate Services Ltd - Receiving Agent (your full name, date of birth, residential address(es), and identity documents (if requested from you for this purpose) are passed to Woodside Corporate Services Ltd)
Our Website may contain links to other websites. Please be aware that we are not responsible for the privacy policies (if any) of such other sites and we would advise you to read the privacy statement of any website that collects personal information from you. These policies may differ from ours and we cannot accept any responsibility or liability in respect of these.
9. Data Security
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. Please contact us if you require more information on these procedures.
Your information will be kept as securely as possible and it will only be kept for as long as is reasonably necessary, unless you have provided us with your consent to use the data for any additional purposes.
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.
10. Your rights
In relation to all of your personal data, you have the following rights (in addition to any rights under the Act or the Regulation):
- Not to process your data for marketing purposes.
- To request a copy of the data we hold about you, how it was obtained, to whom it has been disclosed and how long it will be stored
- To have inaccurate data amended or destroyed.
- To have your data deleted (the right to be forgotten) unless there are lawful reasons for why data must be held.
- To only process your personal data in limited circumstances and for limited purposes.
If you wish to exercise any of your rights at any time, please contact on the details below. We will require you to verify your identity to us before we provide any personal data and reserve the right to ask you to specify the types of data to which your request relates.
Where you wish to exercise any of your rights, they may be subject to payment of a nominal administration fee (to cover our costs incurred in processing your request) and any clarification we may reasonably require in relation to your request. Such fees may be charged where we consider (acting reasonably) that your request is excessive, unfounded or repetitive.
Any data provided to you in accordance with your rights will be in a structured and machine-readable form.
If you have any further queries in relation to this or any other aspect of Ethex, please contact us at:
The Old Music Hall
106-108 Cowley Road
Telephone: +44 (0)1865 403304
The Ethex team are here to help from 9am to 5pm
01865 403 304