Privacy Policy

Last updated: Apr 11, 2023

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Stackr Website and Apps and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. 

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.

  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Stackr Cayman Limited, Artemis house, 67 Fort Street, PO Box 2775, Grand Cayman, KY1-1111, Cayman Islands.

  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

  • Country refers to: Cayman Islands

  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

  • Personal Data is any information that relates to an identified or identifiable individual.

  • Website refers to Stackr, accessible from https://www.gostackr.com
  • Stackr Application refers to the client application accessible from app.gostackr.com or via the offical apps available on the Google Play Store or  the Apple App Store.
  • Service refers to the Website and Stackr Application.

  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

  • Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collect

Identity Data

Such as your name, date of birth, marital status, social security number, biometric identifiers, and other data on government-issued identification documents;

Contact Data

Such as your email address, mailing address, and telephone number;

Financial Data

Such as your bank account and payment card details, and information about your income, account balances, financial transaction history, credit history, tax information, and credit scores;

Profile Data

Such as your username and password, your knowledge assessment results, your interests, preferences, feedback, and survey responses;

Additional Data You Provide

Such as via focus groups, survey responses, contests/sweepstakes, customer support, or other means.

Transactional Information

When you receive, submit, or complete a transaction via the Services, we collect information about the transaction, such as transaction amount, type and nature of the transaction, and time and date of the transaction.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies: Cookies: What Do They Do?.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies

    Type: Session Cookies

    Administered by: Us

    Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

  • Cookies Policy / Notice Acceptance Cookies

    Type: Persistent Cookies

    Administered by: Us

    Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

  • Functionality Cookies

    Type: Persistent Cookies

    Administered by: Us

    Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.

  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

  • To manage Your requests: To attend and manage Your requests to Us.

  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
  • Protect or exercise our legal rights or defend against legal claims: including to enforce and carry out contracts and agreements; and

  • Comply with applicable laws and legal obligations: such as compliance obligations associated with being a regulated financial institution.

  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Information We Collect from Other Sources

Vendors and Business Partners

We collect information about you from companies that we do business with, such as name, contact data, inferences about your preferences and attributes, as well as inferred fraud risk, from identity verification and fraud prevention partners.

Connected Services

If you link, connect, or log in to your Stackr Account with a third-party service (e.g., Google, Apple), the third-party service may send us information such as your profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.

Publicly Available Data

Includes contact information, your interactions with our social media platforms, and other information from publicly available sources, such as public websites.

Advertising Data

We collect information in connection with our ad campaigns that surfaced on other platforms, such as the ads you clicked on and other interactions with our ads.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Deleting of Your Account and Personal Data 

The complete deletion of your account can be undertaken after registration but before submittal of the Application. Whilst your account is still in the application process you can delete your account from within the app, to do so follow the instructions below:

  • Open the App on your phone or through a web browser at https://app.gostackr.com 
  • If the app is still in the application process, you will be automatically routed to the applicaption form 
  • Here you will see a trashcan Icon on the top right of the screen, press this icon to initiate the deletion of your account
  • You will be presented with a dialogbox with some additional information about deleting your account
  • To delete the account you will need to type in the word “confirm” and submit the request
  • The deletion is immediate and all related data is deleted at this point including registration details, a logon to the application will need a new signup.   

For Accounts where the application has already been submmitted a request to deactivate the account can be submitted to privacy@gostackr.com, the request can take up to 14 days to process, however not all data will be deleted as some data is crucial to continue operating your account where applicable and other data is required to be kept under laws governing Stackr Cayman Ltd and its Master Trust. Please refer to the section “Retention of your personal Data“.  

Automatic Deletion of Account Registrations

Accounts registered on the App but not having  completed the application form within a 45 sequential day period will be completely deleted from the App, this includes the registration information as well as any details that may already have been inputted into the application form. During the 45 day period the registered user may be notified or reminded via email about completing their account,  and a final reminder sent out 3 days before deletion of the account to inform them thereoff. The registered email address will be kept on record for another 365 days to ensure no spammers are continuessly registering and deleting accounts. 

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Authorized third-party vendors and service providers

We share information about you with third-party vendors and service providers who perform services for us, such as identification verification, fraud prevention, advertising, mailing services, tax and accounting services, contest fulfillment, web hosting, and analytics services. We use an identification verification service provider to determine whether a selfie you take matches the photo in your government-issued identification. With your consent, we may record your voice and send this data to our third-party partner to authenticate you and to help prevent fraud. The information collected from your photo and your voice by our third-party vendors may include biometric data.

Companies in which you hold securities

Stackr may provide your name, address, email address, and securities positions to requesting companies in which you hold securities.

Substantial corporate transactions

We may share information about you in connection with a substantial corporate transaction, a merger, consolidation, reorganization, financing, change in control or acquisition of all or a portion of our business by a third party, or in the unlikely event of a bankruptcy or similar proceeding.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

What data breach procedures we have in place

In the event that a data breach occurs, our breach response team will be mobilized imediately to prevent any additional data loss. We will move quickly to identify the cause of the breach, secure our systems and fix any vulnerabilities that may have caused the breach. The service may be made unavailable for the duration of time whilst the cause of the breach has not yet been determined and whilst fix is applied to the vulnerabilities.

Once the service is secured a full investigation will take place into what data was breached, on what parts of the service and how access was gained. If your data has been breached we will inform you through one of our communication channels of the breach and the severiety of the breach.    

Country Specific Privacy Policy DisclosuresSouth Africa

Protection of Personal Information Act, 2013 (POPI) You acknowledge that by using the Website and by using the Service you will be providing the Company with personal data, which may be protected by data protection legislation, including inter alia, the Protection of Personal Information Act, 2013 (POPI). You authorise us to process all such personal data and to transmit any such personal data to any Affiliate (which Affiliate may also process such personal data) for the purposes of performing the Contract and in furtherance of Easy Equities legitimate interests including statistical analysis, marketing of our services and credit control. You also authorise us to process and transmit your personal data in the manner contemplated below in this Statement of Privacy. For purposes of this Statement of Privacy, “Affiliate” means any member of the Company’ group of companies, including without limitation, any subsidiary, sub-subsidiary, holding company, fellow subsidiary of any holding company of the Company. You authorise Us to furnish information, which may be protected by data protection legislation, including inter alia, POPI, regarding your Account and trading history to any person we reasonably determine to be seeking Financial Data (including other companies) in good faith for any lawful purpose.

Children’s Privacy

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

  • By email: privacy@gostackr.com
Privacy Policy for Stackr
Stackr

$380M Group Assets Under Management