Privacy Policy

This privacy policy (the “Policy”) describes how Leverage Shares Management Company Limited and its affiliated companies (“Leverage Shares”, “the Firm”, “the Company”, “we”, “us” or “our”) collect, use and disclose personal information we receive when you use our website incomeshares.com (the “Site”) or otherwise interact with us, whether online or offline. For the purposes of this Policy, Leverage Shares acts as a data controller of the personal information we hold about you.

Leverage Shares will use your personal data only for the purposes and in the manner set forth in this Policy which describes the steps taken to ensure our processing of your personal data is in compliance with the General Data Protection Regulation 2016/679 which came into force on the 25th May 2018 (EU), and the Data Protection Act 2018 (UK) (together “GDPR”).

If you have any questions about this Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us as follows:

By email: [email protected]

By post:

Leverage Shares Management Company Limited
2 Grand Canal Square
Grand Canal Harbour
Dublin 2
Ireland

You may provide us with personal information directly, including when you:

• use the Site or our services;
• sign up to receive our newsletter;
• participate in one of our surveys;
• submit a request for information through the Site; or
• communicate with us (whether online or offline).

These categories of personal information you provide may include:

• contact details, such as your name, email address and/or telephone number;
• correspondence and communications data, including any personal information contained in your correspondence and communications with us;
• marketing data, such as your marketing preferences and whether you are a private investor, professional investor, institutional investor or acting in another capacity.

We will indicate where the provision of certain personal information is required to provide specific services. If you choose not to provide such personal information, we may not be able to offer the requested services.

When subscribing to our ETP Alerts service, you voluntarily provide:

• Mobile telephone number
• Alert type preferences (price movement/volume spike thresholds)
• Operational update subscription status

This data collection is strictly limited to what is necessary for delivering requested SMS services. You may withdraw consent for SMS processing at any time. Your mobile telephone number will be used solely for the purpose of sending ETP Alerts and operational notifications. We will not use your mobile number for any other marketing purposes unless you provide explicit additional consent.

We also collect, store and use information about your use of the Site, and about your computer, tablet, mobile or other device through which you access the Site. This includes the following information:

• Technical Data – including the Internet protocol (IP) address, browser type, internet service provider, device identifier, your login information, time zone setting, browser plug-in types and versions, preferred language, activities, operating system and platform, and geographical location; and
• Usage Data – including the full Uniform Resource Locators (URL), clickstream to, through and from the website, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), date and time pages are accessed, website navigation and search terms used, [interaction with marketing emails].

We primarily collect personal data referred above directly from you. However, subject to the relevant conditions, we may also obtain your personal data from the following third parties:

• client due diligence and search information providers;
• publicly available sources, such as Trade Registries or Companies House;
• analytics providers; and
• social media networks, such as LinkedIn.

We may anonymise and aggregate any of the personal data we collect about you to remove any direct identifiers. Such anonymised data may be utilised for various purposes, including testing our IT systems, research, data analysis, improving the Site and our services and developing new products and features. We may also share such anonymised data with third parties.

As a data controller, we will only use your personal information if we have a legal basis for doing so. The table below sets out the purposes for which we use your personal information as well as the legal bases which we rely on to process your personal information.

ETP Alerts are sent based on your selected preferences, such as price movements, volume spikes or operational notifications. The frequency of alerts depends on market conditions, product-specific developments and your alert settings. You can adjust the frequency or opt-out at any time through your account settings or by contacting us.

We disclose personal information with the following recipients to achieve the purposes set out above or as otherwise described below:

• Service providers - we may share your personal information with third parties that perform services for us or on our behalf, which may include providing data hosting, website hosting, email marketing, customer relationship management, client due diligence and analytics services;
• Professional advisors - we may share your personal information with our lawyers, accountants, insurers and other professional advisors to the extent we need to (for example, to defend ourselves against legal claims);
• Law enforcement, regulators, governmental authorities and other parties for legal reasons - we may share your personal information with third parties if we are legally required to do so, or if we believe, in good faith, that such disclosure is necessary to comply with a legal obligation or request, to enforce our terms and conditions or to protect the rights, property or our safety, or the safety of our users, a third party, or the public;
• Other members of the Firm - we may share your personal information with our affiliates (for example, where they provide services on our behalf) or where such sharing is otherwise necessary to achieve the purposes set out above;
• ETP Alerts service providers We partner with reputable telecom providers or equivalent service providers to deliver ETP Alerts. These providers are contractually obligated to maintain the confidentiality and security of your mobile number and are prohibited from using it for any other purpose;

In addition, we may share your personal information with other third parties if you have provided your consent for us to do so.

There may be occasions where we need to transfer your personal data to third-party service providers located outside the European Economic Area (“EEA”) or the United Kingdom.

Such transfers outside the EEA will only take place where either (i) the Commission has decided that such third country ensures an adequate level of protection; or (ii) we have provided appropriate safeguards, and on the condition that enforceable rights and effective legal remedies are available for you.

Such transfers outside the UK will only take place where either (i) the UK’s Information Commissioner’s Office has decided that such third country ensures an adequate level of protection; or (ii) we have provided appropriate safeguards, and on the condition that enforceable rights and effective legal remedies are available for you.

This may include, for example, entering into standard contractual clauses with the recipients of your personal data.

You have the following rights in respect of the personal information we hold about you under applicable data protection law:

• Right of access - You have the right to obtain access to your personal information;
• Right of portability - You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person;
• Right to rectification - You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay;
• Right to erasure - You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified;
• Right to restriction - You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you;
• Right to object - You have a right to object to the processing we carry out on the basis of legitimate interests in certain circumstances. You can also object to our direct marketing activities for any reason by clicking the "unsubscribe" link set out in any marketing communication or contacting us using the contact details set out below;
• Right to withdraw consent - If you have provided consent to any processing of your personal information, you have the right to withdraw that consent (without affecting the lawfulness of our processing prior to you having withdrawn your consent).
• Right to lodge a complaint - You have the right to lodge a complaint with the relevant supervisory authority if you believe our processing of your personal information violates applicable data protection law. In Ireland, this is the Data Protection Commission (www.dataprotection.ie). In the UK, this is the Information Commissioner's Office (www.ico.org.uk).

Please note that not all of the above rights are absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply.

Regarding SMS services, you may:

• Access full message transmission logs via data subject access request;
• Request immediate pseudonymization of mobile number;
• Object to processing for specific alert types while maintaining others;
• Receive information about how automated alert triggers are determined;

You can opt-out of receiving ETP Alerts at any time by replying 'STOP' to any alert message or by managing your preferences in your account settings. Opting out will not affect other communications you have consented to receive.

If you wish to exercise one of these rights, please contact us using the contact details set out above.

We will retain your personal information only for as long as necessary to fulfill the purposes for which we collected it.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, as well as the applicable legal, regulatory, tax, accounting or other requirements.

We employ suitable technical and organisational security measures, including encryption, to safeguard personal data against unauthorised use, loss, alteration, or destruction, whether online or offline. When third parties process data on our behalf, we ensure they implement appropriate security measures to prevent unauthorised disclosure of personal data.

We implement additional security measures specifically for SMS data, including encryption of mobile numbers in transit and at rest. Access to SMS data is restricted to authorized personnel only.

We use cookies and similar technologies to distinguish you from other users of the Site. For more information on cookies and the purposes for which we use them, please contact us at [email protected].

The Site may, from time to time, contain links to websites of our business partners, advertisers, affiliates or third parties. Please be aware that these websites maintain their own privacy policies, and we do not bear responsibility or liability for their policies. Before providing any personal information on these websites, we recommend reviewing their privacy policies. If you follow a link to any third-party website, you do so at your own risk. We encourage you to be aware when you leave our Site and to read the privacy statements of each website that collects personal information.

Our Site and services are not directed at children under the age of 18, and we do not knowingly collect personal information from children under 18. If you believe we have inadvertently collected information from a child under 18, please contact us immediately so we can delete such information.

Our Site and services are not directed at children under the age of 18, and we do not knowingly collect personal information from children under 18. If you believe we have inadvertently collected information from a child under 18, please contact us immediately so we can delete such information.