PRIVACY POLICY

Effective date: 06 November, 2024

1. ABOUT THIS PRIVACY POLICY

This Privacy Policy explains how Spyentist Ltd, operating Good Investor Club ("Good Investor Club", "GIC", "we", "us" or "our"), collects, uses, stores, shares and otherwise processes personal information.

Good Investor Club is a private membership community and events platform for investors and investment professionals.

This Privacy Policy applies to individuals who interact with Good Investor Club, including where you:

  • visit our website;

  • apply for membership of Good Investor Club;

  • become or remain a member;

  • purchase a ticket for a Good Investor Club event;

  • register for, RSVP to or attend a Good Investor Club event;

  • attend a Good Investor Club event as an invited guest without being a member;

  • join an event waiting list;

  • participate in an event as a speaker, panellist or other guest;

  • subscribe to our news, updates or other communications;

  • communicate with us; or

  • otherwise interact with Good Investor Club or our services.

Certain Good Investor Club events are open only to members, while others may be open to invited guests, ticket purchasers or other non-members. Attendance at an event does not, by itself, make you a Good Investor Club member.

2. WHO WE ARE

Good Investor Club is operated by Spyentist Ltd, a company incorporated in England and Wales with company number 15776138.

For the purposes of applicable data protection law, Spyentist Ltd is the controller responsible for the personal information described in this Privacy Policy.

Our registered office is:

20 Jesmond Way, Stanmore, Middlesex, HA7 4QR

If you have questions about this Privacy Policy or how we collect and use your personal information, please contact us at:

Email: hello@goodinvestor.club

3. THE PERSONAL INFORMATION WE COLLECT

The personal information we collect depends on how you interact with Good Investor Club.

3.1 Membership applications and member profiles

When you apply for membership or provide information relating to your membership, we may collect:

  • first name;

  • last name;

  • preferred full name;

  • email address;

  • telephone number;

  • country;

  • country of residence;

  • city or town of residence;

  • the name of your organisation, family office, investment company, fund or other affiliated organisation;

  • information about your professional or investment role;

  • information about the asset classes in which you invest;

  • information about your investment interests;

  • information about your total investable assets, generally collected in ranges rather than precise amounts;

  • information about your target annual investment deployment, generally collected in ranges rather than precise amounts; and

  • other information you voluntarily provide to us.

Depending on the membership category for which you apply, we may also collect information reasonably necessary to understand your investment activity, professional role, institutional affiliation or suitability for membership.

3.2 Membership and event information

If you become a member or interact with our events, we may collect or create information relating to:

  • your membership status and membership category;

  • event registrations and attendance;

  • event preferences;

  • communications and correspondence with us;

  • introductions or connections facilitated through Good Investor Club;

  • feedback you provide about our membership, events or services; and

  • information reasonably necessary to administer or curate our membership community and events.

3.3 Ticket purchasers, event attendees and invited guests

If you purchase a ticket, register for, RSVP to or attend an event, whether or not you are a member, we may collect:

  • your name;

  • email address;

  • telephone number;

  • professional title and organisation;

  • membership status, where relevant;

  • event registration and attendance information;

  • payment and transaction information where you purchase a ticket;

  • dietary or accessibility requirements voluntarily provided by you;

  • communications relating to the event;

  • photographs, video or other recordings where photography, filming or recording takes place; and

  • other information reasonably necessary to organise, administer or deliver the event.

3.4 Payment information

Where you pay a membership fee or purchase an event ticket, payment information may be processed by our third-party payment providers.

We do not intend to store complete payment-card details ourselves. We may retain transaction records and information reasonably necessary for accounting, tax, payment administration, fraud prevention and record-keeping.

3.5 Communications and marketing preferences

We may collect information about whether you have chosen to receive newsletters, news, updates, event invitations or other marketing communications from us.

3.6 Website and technical information

When you use our website, we or our service providers may automatically collect certain technical information, which may include:

  • IP address;

  • device information;

  • browser information;

  • pages viewed;

  • referring URLs;

  • approximate location;

  • dates and times of website visits; and

  • information collected through cookies and similar technologies.

Where applicable, further information about cookies and similar technologies will be provided through our Cookie Policy or cookie notice.

4. HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information for the following purposes.

4.1 To assess membership applications

We use information provided in membership applications to:

  • review and assess applications;

  • determine whether an applicant meets our membership criteria;

  • understand an applicant's investment profile and interests;

  • maintain an appropriately curated membership community;

  • determine the appropriate membership category;

  • communicate the outcome of an application;

  • request additional information or clarification where necessary; and

  • prevent fraudulent or inappropriate applications.

Information about investable assets and target annual investment deployment may be used to help us understand whether an applicant meets the criteria for a particular membership category and whether Good Investor Club is appropriate for that applicant.

4.2 To administer membership

If you become a member, we may use your information to:

  • administer and maintain your membership;

  • verify your membership status;

  • communicate with you about your membership;

  • collect and administer membership fees;

  • provide membership benefits;

  • maintain records relating to your use of membership benefits; and

  • respond to questions or requests.

4.3 To curate our membership community and events

Good Investor Club brings together investors and investment professionals in private, curated settings.

We may use information about your professional role, investment interests, asset classes, investment activity and general investment profile to:

  • determine whether particular events may be relevant to you;

  • curate invitations and attendee groups;

  • understand the composition of attendees at an event;

  • facilitate relevant introductions and connections;

  • provide a relevant membership experience; and

  • improve the quality and relevance of our membership community and events.

We do not sell individual members' detailed financial information.

We will not publicly disclose your individual investable-asset range or target annual investment deployment without your permission, except where disclosure is required by law or otherwise permitted under applicable law.

4.4 To organise and administer events

We may use personal information relating to event attendees, ticket purchasers and invited guests to:

  • process ticket purchases and registrations;

  • confirm and administer attendance;

  • communicate event details;

  • notify you about changes to an event;

  • manage guest lists and event capacity;

  • manage waiting lists;

  • provide relevant information to venues and service providers where necessary to deliver an event;

  • administer payments and accounting;

  • provide catering or accommodate dietary or accessibility requirements voluntarily provided by you;

  • manage event safety and security;

  • respond to questions and requests; and

  • analyse and improve our events.

4.5 To communicate with you

We may use your contact information to send you:

  • information about your membership application;

  • membership administration communications;

  • event invitations and logistics;

  • ticket confirmations and event information;

  • important changes to our services, membership or policies; and

  • other communications reasonably necessary to provide or administer our services.

4.6 To send marketing communications

Where permitted by applicable law, we may send you newsletters, news, updates, event announcements and other information about Good Investor Club and related services.

Where required by applicable law, we will obtain your consent before sending marketing communications.

You can unsubscribe from marketing emails at any time by using the unsubscribe link included in our communications or by contacting us at [PRIVACY CONTACT EMAIL].

Opting out of marketing communications will not prevent us from sending you non-marketing communications relating to your application, membership, ticket purchase, event registration, payment or other transaction.

4.7 To operate and improve our business

We may use personal information to:

  • operate, maintain and improve our website and services;

  • analyse membership and event activity;

  • understand the effectiveness of our communications;

  • improve our events and member experience;

  • protect our business, members and users;

  • prevent fraud and misuse;

  • investigate complaints or disputes; and

  • comply with legal, regulatory, accounting and tax obligations.

Where appropriate, we may use aggregated or anonymised information that does not identify individual members or attendees.

5. INFORMATION ABOUT INVESTABLE ASSETS AND INVESTMENT ACTIVITY

We recognise that information about an individual's wealth, investable assets and investment activity may be sensitive from a personal and commercial perspective.

We collect this information primarily for the purposes of:

  • assessing eligibility for membership;

  • understanding the composition of our membership community;

  • determining appropriate membership categorisation;

  • curating relevant events and experiences;

  • understanding general investment interests and capacity; and

  • administering and improving our membership services.

We generally collect investable assets and target annual investment deployment in broad ranges rather than requesting precise financial figures.

Unless you separately provide permission or disclosure is required or permitted by law, we will not publicly publish or disclose your individual financial information.

We may use aggregated or anonymised information about our membership base, provided that the information does not reasonably identify you.

6. OUR LEGAL BASES FOR PROCESSING

Where UK GDPR, EU GDPR or similar data protection laws apply, we process personal information only where we have a valid legal basis.

Depending on the circumstances, this may include the following.

6.1 Contract and steps taken at your request

We may process information where necessary to:

  • assess an application at your request;

  • administer your membership;

  • process a ticket purchase;

  • register you for an event; or

  • otherwise provide services you have requested.

6.2 Legitimate interests

We may process information where necessary for our legitimate interests, provided that those interests are not overridden by your rights and interests.

Our legitimate interests may include:

  • operating and developing a curated investor community;

  • assessing membership suitability;

  • administering and improving events;

  • maintaining the security and integrity of our services;

  • communicating with members, applicants and attendees;

  • facilitating relevant introductions;

  • preventing fraud and misuse;

  • managing our business; and

  • protecting our legal rights.

6.3 Consent

In some circumstances, including certain marketing activities where required by law, we may rely on your consent.

Where we rely on consent, you may withdraw your consent at any time.

Withdrawal of consent will not affect the lawfulness of processing carried out before consent was withdrawn.

6.4 Legal obligations

We may process information where necessary to comply with a legal obligation.

7. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

Good Investor Club does not sell, rent, trade or provide your personal information to third parties for their own commercial, marketing or advertising purposes.

We do not sell or provide:

  • member lists;

  • attendee lists;

  • email addresses;

  • telephone numbers;

  • individual investment information;

  • investable-asset information;

  • target annual investment deployment information; or

  • other personal information,

to sponsors, commercial partners, advertisers or other third parties for their independent use.

We will not provide another member, event attendee, sponsor, commercial partner or other third party with your personal contact details merely because you are a member of Good Investor Club or have attended one of our events.

7.1 Service Providers

In order to operate Good Investor Club, we may use carefully selected service providers that process personal information on our behalf and under our instructions.

These may include:

  • website and hosting providers;

  • application-form providers;

  • membership-management providers;

  • customer relationship management providers;

  • email and communications providers;

  • payment processors;

  • ticketing providers;

  • IT, security and technical service providers;

  • professional advisers, including lawyers, accountants and insurers; and

  • event venues, restaurants and event-management providers where information is reasonably necessary to organise and deliver an event.

We only provide such service providers with the information reasonably necessary for them to provide services to us or to you.

Where appropriate, we require service providers that process personal information on our behalf to handle that information in accordance with applicable data protection laws and appropriate contractual or other safeguards.

For example, we may provide a venue or restaurant with an attendee's name or dietary requirements where reasonably necessary to organise an event. This does not permit the venue or restaurant to use that information for its own independent marketing or commercial purposes.

7.2 Introductions Between Members and Participants

Good Investor Club may facilitate introductions between members or event participants.

However, we will not provide your email address, telephone number or other personal contact details to another member, attendee, sponsor or other third party without your permission.

Where we believe that an introduction may be relevant, we may ask whether you would like to be introduced before sharing your contact details or facilitating the connection.

You may, of course, voluntarily share your own contact information with another person at an event or through an introduction.

7.3 Legal and Regulatory Requirements

We may disclose personal information where we are required or permitted to do so by applicable law, including where disclosure is reasonably necessary:

  • to comply with a legal obligation;

  • to respond to a valid request from a court, regulator or government authority;

  • to establish, exercise or defend legal claims;

  • to investigate or prevent fraud, misuse or security issues; or

  • to protect the rights, property, safety or security of Good Investor Club, Spyentist Ltd, our members, attendees or others.

7.4 Sponsors and Commercial Partners

Sponsors and commercial partners may support or participate in Good Investor Club events.

However, we do not provide sponsors or commercial partners with our member or attendee database, member lists, attendee lists or personal contact details for their independent marketing, advertising or commercial purposes.

Sponsors and commercial partners may meet and interact with members and attendees directly at events.

If you independently choose to provide your personal information to a sponsor, commercial partner or other third party, that party's own privacy policy and practices will apply to its use of your information.

We are not responsible for the privacy practices of third parties to whom you voluntarily provide your information directly.

8. INTERNATIONAL TRANSFERS

Good Investor Club operates internationally and may host events in multiple countries.

Our service providers may also process information in countries outside the United Kingdom or the country in which you live.

Where applicable data protection laws require safeguards for international transfers of personal information, we will take appropriate steps to provide those safeguards.

9. HOW LONG WE KEEP YOUR INFORMATION

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy.

In determining retention periods, we may consider:

  • whether you have an active application or membership;

  • the nature and sensitivity of the information;

  • the purposes for which the information was collected;

  • legal, accounting and regulatory requirements;

  • the potential need to establish, exercise or defend legal claims; and

  • our legitimate business needs.

We may retain limited information about unsuccessful, rejected or withdrawn applications for a reasonable period in order to administer our application process, maintain appropriate records, prevent fraud and respond to legal issues.

We may retain information relating to ticket purchases and payments for periods required by applicable accounting, tax or legal requirements.

We may retain certain information for longer where required or permitted by law.

10. SECURITY

We take reasonable technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration and disclosure.

However, no method of transmitting information over the internet or storing information electronically is completely secure.

We therefore cannot guarantee absolute security.

11. PHOTOGRAPHY, FILMING AND RECORDING AT EVENTS

Photography, filming or other recording may take place at certain Good Investor Club events.

Where photography, filming or recording is planned, we may provide notice through the event invitation, registration process, joining instructions, signage at the event or otherwise.

Where appropriate, photographs or recordings may be used for legitimate Good Investor Club purposes, including event promotion, editorial content, website content and marketing.

Where you have concerns about being photographed or filmed, you should contact us before the event or speak to a member of the Good Investor Club team at the event.

We may take reasonable steps to accommodate such requests, but cannot guarantee that incidental capture of every attendee can be avoided.

Certain events may be designated as private, off-the-record or subject to specific photography or recording restrictions. In those circumstances, additional event rules may apply.

12. YOUR RIGHTS

Depending on the laws that apply to you, you may have rights in relation to your personal information.

These may include the right to:

  • request access to your personal information;

  • request correction of inaccurate or incomplete information;

  • request deletion of your personal information in certain circumstances;

  • object to certain processing;

  • request restriction of certain processing;

  • request portability of certain information;

  • withdraw consent where processing is based on consent; and

  • complain to a relevant data protection authority.

To exercise your rights, please contact us at hello@goodinvestor.club.

We may need to verify your identity before responding to certain requests.

13. CHILDREN

Good Investor Club is intended for adults.

We do not knowingly collect personal information from children.

14. THIRD-PARTY WEBSITES AND SERVICES

Our website, emails or other communications may contain links to third-party websites or services.

We are not responsible for the privacy practices of those third parties.

We encourage you to review the privacy policies of third parties before providing them with personal information.

15. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time.

When we make material changes, we will update the effective date above and may provide additional notice where appropriate.

16. CONTACT US

If you have questions, concerns or requests regarding this Privacy Policy or our handling of your personal information, please contact:

Spyentist Ltd
Company number: 15776138
Registered in England and Wales

Registered office: 20 Jesmond Way, Stanmore, Middlesex HA7 4QR

Email: hello@goodinvestor.club