Privacy Policy

1. PURPOSE OF THIS POLICY

1.1 This notice (Privacy Policy) applies to information Investor Pointe (UK) Limited or any of its subsidiaries or affiliates (collectively referred to as Investor Pointe, or Group), and its or their officers, holds about you as a user or prospective user of our software products and services, as a visitor to our website, or as a representative of a current or prospective client.

1.2 This Privacy Policy also covers our website and any personal data we collect when you use it. Our website is operated using third-party hosting and marketing infrastructure; where this involves a transfer of personal data outside the UK or EEA, the safeguards described in clause 7 apply. Some links on our website may lead to third-party websites with their own Privacy Policies, which you should read carefully.

1.3 Wherever we have said “we”, “our” or “us”, we mean Investor Pointe. "You" or "your" refers to you as a user or prospective user of our products and services, a representative of a current or prospective client, a visitor to our website, or an officer or contractor of Investor Pointe.

1.4 This Privacy Policy explains what information Investor Pointe collects about you and individuals connected to your business, how we will use that information, who we will share it with, the circumstances in which we will share it, and the steps we take to keep it private and secure. It continues to apply even after your relationship with us ends. It should be read alongside any other documentation relating to our products and services (such as customer contracts, subscription terms, terms of use and terms of service) as these may include provisions relating to the use and disclosure of information. Where there is any conflict between this Privacy Policy and any other document in relation to data protection, the terms of this Privacy Policy shall prevail, although its contents are not contractual.

1.5 An “individual connected to your business” could be any guarantor, a director, officer or employee of a company, partners or members of a partnership, any substantial owner, controlling person or beneficial owner, trustee, settlor or protector of a trust, account holder of a designated account, recipient of a designated payment, your attorney or representative (e.g. authorised signatories), agent or nominee, or any other persons or entities with whom you have a relationship that is relevant to your relationship with us. Whenever we say “you”, “individuals connected to your business” should be read as included as well.

1.6 For the purpose of this Privacy Policy, Investor Pointe (UK) Limited (registered in England and Wales under company number 11706620) acts as data controller. We are registered with the UK Information Commissioner's Office (ICO) under reference ZA793320. We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, and, where applicable, the EU General Data Protection Regulation (EU GDPR). Other entities in our Group may also process personal data from time to time.

1.7 Please ensure that any relevant individuals are made aware of this Privacy Policy and the individual rights and information it sets out, prior to providing their information to us or our obtaining their information from another source. If you, or anyone else on your behalf, has provided or provides information on an individual connected to your business to us (or any member of the Group), you or they must first ensure that you or they have the authority and appropriate legal basis to do so.

2. INFORMATION WE COLLECT

2.1 This Privacy Policy is concerned with personal information (also called personal data) we collect about you. Personal data means any data by which you as an individual can be directly or indirectly (e.g. if several pieces of data are combined) be identified. Data which is completely anonymised or de-personalised will not count as personal data.

2.2 Some of the personal data we hold about you will have been supplied by yourself. Other personal information may come from your financial advisor, solicitors, broker, employer or other intermediary, other members of the Group or other sources you’ve asked us to obtain information from. We might also get some of it from publicly available sources.

2.3 Where we provide our products and services to clients, we may process personal data (including data relating to our clients' investors and end-users) on our clients' behalf and on their instructions. In those circumstances we act as a processor, and that processing is governed by our agreement with the relevant client rather than by this Privacy Policy.

2.4 In addition to the above, in relation to the Website we may also collect:

2.4.1 information that you provide to us, such as when you fill out a contact or web form or if you register to receive alerts or updates;

2.4.2 information that we obtain or learn, such as information about the browser or device you use to access this site, how you use this site and the pages you visit, traffic and location data;

2.4.3 information you provide to us if you experience problems when using the Website. We may also ask you to complete surveys for research purposes, although you don’t have to respond to these; and

2.4.4 if we have an existing relationship with you, and we are able to identify you from information obtained or provided by your use of the site, we may associate those sets of information, for example to enable us to respond to a query you have submitted.

2.5 Please note that the Website is not designed or intended for children and we do not knowingly collect data relating to children.

2.6 Where we are required to collect personal data by law, or under the terms of a contract with you, and you do not provide that data when requested, we may be unable to perform the contract, onboard you, or meet our regulatory obligations (for example anti-money-laundering and know-your-customer requirements). We will tell you at the point of collection where the provision of data is mandatory and the consequences of not providing it.

3. HOW WE WILL USE PERSONAL DATA

3.1 We will only use your personal information when the Law allows us to. Most commonly, we will use your personal information in the following circumstances:

3.1.1 where we need to perform the contract we have entered into with you;

3.1.2 where we need to comply with a legal or regulatory obligation;

3.1.3 where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests;

3.1.4 where we need to protect your interests (or someone else’s interests); and

3.1.5 where it is needed in the public interest or for official purposes (such as compliance with a court order or regulatory direction).

3.2 Based on the reasons for using your data noted in 3.1 above, the purposes for which we use your information as an employer, officer or contractor commonly include:

3.2.1 paying you, providing you with benefits which may include pension, private health insurance, life insurance or permanent health insurance and administering the contract we have entered into with you (contractual performance);

3.2.2 deducting tax and social security contributions (legal obligation);

3.2.3 determining the terms on which you are appointed and about your continued engagement (legitimate interests); and

3.2.4 updating you as to relevant board meetings and providing you with information about the performance of Bite Products (legitimate interests; legal obligation).

3.3 In addition, in relation to the Website we may use information provided or obtained to:

3.3.1 respond to your queries and reports (for example, if you’ve asked a question or submitted a report via the Website);

3.3.2 provide you with information, products or services you have requested or which we think may interest you, unless you tell us otherwise;

3.3.3 carry out our obligations from any contracts entered into between you and us;

3.3.4 allow you to participate in any interactive features of the Website;

3.3.5 notify you about changes to the Website;

3.3.6 provide you with alerts or updates where you’ve consented to receive these by registering on the Website. You can opt out of these at any time by clicking the “unsubscribe” link at the bottom of each email we send you;

3.3.7 ensure site content is presented in the most effective manner for the device you’re accessing it from (e.g. your mobile phone, personal computer or other electronic device); and

3.3.8 detect and prevent misuse or abuse of the Website or our services.

4. INFORMATION ABOUT THE WEBSITE

4.1 We may collect information about your computer (or mobile device), including, where available, your email address and device and browsing information including your IP address, operating system and browser type for system administration or for our own commercial purposes (which may include sharing this data with certain vendors in order to provide certain functionality on our website, analysing which pages you visited and for other purposes).

4.2 We use cookies and similar technologies to distinguish you from other users of this site, to improve your experience when accessing this site and to improve the site. Detailed information on the cookies we use and the purposes for which we use them are set out in our Cookie Policy on the Website.

5. WHO WE MIGHT SHARE YOUR PERSONAL DATA WITH

5.1 We may share relevant personal information of yours with other parties where it is lawful to do so, including where:

5.1.1 it is necessary to comply with our contractual obligations or with your instructions;

5.1.2 we have a public or legal duty to do so (e.g. to assist with detecting and preventing fraud, tax evasion and financial crime or compliance with a court order);

5.1.3 we are obligated to in connection with regulatory reporting, litigation or asserting or defending legal rights and interests;

5.1.4 Investor Pointe has a legitimate business reason for doing so (for example, to manage risk, or to enable another business to provide you with services you have requested);

5.1.5 we work with third parties who perform AML, KYC or other regulatory-related outsourced services on behalf of or directly for Investor Pointe; and

5.1.6 we have asked you if we can share it, and you gave consent.

5.2 Parties we might share your personal information with can include (without limitation):

5.2.1 fund managers, brokers, sponsors and market makers, registrars and listing agents;

5.2.2 any trustees, beneficiaries, administrators or executors;

5.2.3 people who give guarantees or other security for any amounts you owe us;

5.2.4 banks you instruct us to make payments to and receive payments from;

5.2.5 third parties who manage the investments on our behalf, including investment managers, letting agents and stockbrokers;

5.2.6 third parties who host the Website or provide services related to it, including IT security providers;

5.2.7 other financial institutions, lenders and holders of security over any property or assets, tax authorities, stock market authorities, trade associations, credit reference agencies, payment service providers and debt recovery agents;

5.2.8 any people or companies where required in connection with potential or actual corporate restructuring, merger, acquisition or takeover, including any transfer or potential transfer of any of our rights or duties under our agreement with you;

5.2.9 law enforcement, government, courts, dispute resolution bodies, our regulators, auditors and any party appointed or requested by our regulators to carry out investigations or audits of our activities;

5.2.10 other parties involved in any disputes, including disputed transactions;

5.2.11 fraud prevention agencies who’ll also use personal data to detect and prevent fraud and other financial crime and to verify your identity;

5.2.12 anyone who provides instructions to us on your behalf (e.g. under a power of attorney, solicitors, intermediaries, investment managers, etc);

5.2.13 anybody else that you instructed us to share your information with; and

5.2.14 insurers who may provide cover for your investments with us.

5.3 We might share aggregated and/ or anonymised or de-personalised data with third parties for analytics, marketing and research purposes. Where we do so, we will ensure that neither you nor any other person will be identifiable from the data.

6. RETENTION OF PERSONAL DATA

6.1 Investor Pointe keeps personal data only for as long as it is necessary for the specific purpose the data was collected for or as long as we are required by applicable laws and regulation. When determining how long to retain personal data, we consider its nature and sensitivity, the purposes for which we process it, the duration of our relationship with you, whether we can achieve those purposes by other means, and any applicable legal or contractual obligations. For example, we generally retain accounting and tax records for at least six years in line with UK requirements.

6.2 We may keep personal data likewise for longer periods where we have a legitimate interest for doing so, for instance to address complaints, assert or defend our rights in litigation or other dispute resolution procedures or to respond to requests from regulators or assist judicial authorities.

6.3 Where personal data is no longer required and we are not required to retain it, we will securely delete, anonymise or destroy it, or return it to you.

6.4 Where we share your personal data with third parties, the retention of that data by those third parties is governed by their own Privacy Policys and applicable law.

7. INTERNATIONAL TRANSFERS OF PERSONAL DATA

7.1 We operate internationally and may transfer your personal data to, and store it in, countries outside the United Kingdom and the European Economic Area (EEA), including to other companies in our Group. Our Group includes entities in the United States, and we use service providers (including analytics and hosting providers) that may process data outside the UK and EEA.

7.2 The United States is not currently subject to a UK data protection adequacy decision. Where we transfer your personal data to our group entities or service providers in the United States, or elsewhere outside the UK or EEA, we put in place appropriate safeguards, in particular the UK International Data Transfer Agreement (or the UK Addendum to the EU Standard Contractual Clauses), together with any additional measures required to protect your data. Where we transfer EEA-origin personal data, we rely on the EU Standard Contractual Clauses.

7.3 You may request further information about the safeguards we apply, or a copy of the relevant transfer.

8. INDIVIDUALS’ RIGHTS

8.1 As an individual or “data subject”, you have certain rights in relation to your personal data. These rights include:

8.1.1 the right to access information we hold about you and to obtain information about how we process it;

8.1.2 the right to object to and withdraw your consent to Investor Pointe’s processing of your information. This right can be exercised at any time. However, Investor Pointe may continue to process your personal information if there is another legitimate reason or legal obligation for doing so. Please also note that depending on which kind of processing you object to, Investor Pointe may no longer be able to perform its contractual obligations with you;

8.1.3 in some circumstances, you have the right to receive certain information you have provided to us in an electronic format and/ or request that we transmit it to a third party;

8.1.4 the right to request that we rectify information we hold about you if it is inaccurate or incomplete;

8.1.5 in some circumstances, you have the right to request the erasure and deletion of personal data we hold. We may however continue to retain it if we are entitled or required by law to do so;

8.1.6 the right to object to, and to request that we restrict, our processing of your information in some circumstances. Please note that despite this general right, we may be entitled under law to continue processing the information and/ or to refuse that request.

8.2 You also have the right to complain to the UK supervisory authority for data protection, the Information Commissioner's Office (ICO), at https://ico.org.uk or on 0303 123 1113. We would ask that you raise any concern with us first so we can try to resolve it.

8.3 You may also be able to seek a judicial remedy through the courts of England and Wales if you consider that your data protection rights have been infringed, or to challenge a decision of the Information Commissioner's Office.

8.4 You also have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Where we carry out any such automated decision-making, you may request human intervention, express your point of view, and contest the decision.

9. CHANGES TO THIS NOTICE

9.1 We may update this Privacy Policy from time to time. Any changes will be posted on this page and, where appropriate, we will notify you. Please review it periodically. This Privacy Policy was last updated June 2026.

10. MISCELLANEOUS

10.1 Please ensure that any data you give us or ask third parties to provide to us is up to date, accurate and complete in all respects. Please inform us about any changes as soon as reasonably possible.

10.2 We use a range of measures to keep information safe and secure which may include encryption and other forms of security. We require our staff and any third parties who carry out any work on Investor Pointe’s behalf to comply with appropriate compliance standards including obligations to protect any information and applying appropriate measures for the use and transfer of information. If you wish to know more about our data protection measures, please contact us (details provided below).

10.3 This Privacy Policy is governed by the laws of England and Wales, and is subject to the non-exclusive jurisdiction of the courts of England and Wales.

11. CONTACT US

For any further questions or queries in relation to this Privacy Policy, please get in touch with your usual contact or write to: Data Protection Officer, c/o Investor Pointe (UK) Limited, 123 Buckingham Palace Rd, London SW1W 9SH, United Kingdom or email: dataprotection@investorpointe.com.

This Privacy Policy was last updated June 2026.