Letterprint Ltd, trading as ‘Quentinvest’, (“Quentinvest”,“we”, “us”, “our”) is a provider of stock market advisory and associated financial growth strategies. For more information about Quentinvest, please visit our website: https://www.quentinvest.com/ (the “Website”). 

We take your privacy seriously and are committed to protecting and respecting your personal data. This privacy policy (“Privacy Policy”) sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us. Please read the following carefully to understand how we will use your personal data.  

Our services are intended for individuals over the age of 18, and we do not knowingly collect data relating to individuals under 18. 

1. What personal data do we collect and process, and how do we use it? 

To use our services you must create an account on our website using your name and email address.  

You may provide us with additional personal data depending on your preferences.  We will collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: 

• Identity Data includes name, username or similar identifier, marital status, title, date of birth and gender. 
• Contact Data includes billing address, delivery address, email address and telephone numbers. 
• Financial Data includes bank account and payment card details. 
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. 
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website, your browsing patterns and actions. Please see our cookie policy for further details.  
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. 
• Usage Data includes information about how you use our website, products and services. 
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. 
• Aggregated Data We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. 

Personal data that we do not process:

• Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. 

How we use your personal data: 

Purpose/activity	• To register you as a new customer or user
Type of data	• Identity  • Contact   • Financial   • Device  • Technical
Lawful basis for processing	• Your consent • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

Purpose/activity	• To process in-store purchases and deliver Services including managing payments and collecting money owed to us
Type of data	• Identity   • Contact   • Financial   • Transaction  • Device  • Marketing and Communications
Lawful basis for processing	• Your consent  • Performance of a contract with you   • Necessary for our legitimate interests (to recover debts due to us)

Purpose/activity	• To manage our relationship with you including notifying you of changes to the Website or any Services
Type of data	• Identity   • Contact   • Financial   • Profile   • Marketing and Communications
Lawful basis for processing	• Your consent  • Performance of a contract with you   • Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)  • Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

Purpose/activity	• To enable you to participate in a prize draws, competition or complete a survey
Type of data	• Identity  • Contact  • Device   • Profile   • Marketing and Communications
Lawful basis for processing	• Your consent   • Performance of a contract with you  • Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

Purpose/activity	• To administer and protect our business website, including troubleshooting, data analysis and system testing
Type of data	• Identity   • Contact  • Device   • Technical
Lawful basis for processing	• Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

Purpose/activity	• To deliver content and advertisements to you  • To make recommendations to you about goods or services which may interest you  • To measure and analyse the effectiveness of the advertising we serve you  • To monitor trends so we can improve the Service
Type of data	• Identity   • Contact   • Device   • Content   • Profile   • Usage   • Marketing and Communications
Lawful basis for processing	• Consent   • Necessary for our legitimate interests (to develop our products/Services and grow our business)

2. Who do we share your personal data with?

By using our Website, we may need to disclose your personal data to selected third parties in the following limited circumstances: 

• We share your personal data with our third-party providers, such as software companies we use to run the Website (such as AWS) and service providers and third party platforms who we use for billing (Stripe). We share your personal data with these companies in order to help with the proper functioning of the Website, to analyse and understand your usage of the Website and the services so we can make improvements, and to contact you via email. We may also share your data with marketing companies if you have signed up to receive marketing material from us (including MailChimp and SurveyMonkey). If you would like any more information about the third parties we share your data with, please contact [email protected] 
• We may share your personal data where we have a legal duty to do so, or with our insurance providers or other professional advisers if this is necessary for, for example, obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or exercising or defending legal rights and claims. 
• If you purchase any additional services through the Website, if we process the payment we may pass your payment details to:
  • credit reference agencies to verify your identity and detect and prevent fraud, money laundering or any other criminal activity; and 
  • payment providers to securely process your payments and deal with any refunds or payment-related queries. 

3. Transfers of your personal data 

To deliver our services to you, it is sometimes necessary for us to share your personal data outside the UK. Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/EEA where there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects.  

Where personal data is transferred to a third party for example in the USA, we take steps to ensure we agree standard contractual clauses (SCC’s) with the service provider, as well as undertaking a ‘data transfer assessment’ to ensure any additional safeguards that are required are in place to protect your data.  

4. Cookies and Pixels 

Cookies are small text files containing a string of characters that can be placed on your computer or mobile device that uniquely identifies your browser or device. Some of our third-party service providers may place third party cookies on your device that are necessary in order to help with the proper functioning of the Website and service, such as storing and remembering your log-in details and automatically reporting any bugs or other issues with the Website. For information about the cookies that we use on the Website, please read our Cookies Policy available here: https://www.quentinvest.com/cookie-policy.

Remarketing 

We use remarketing in order to promote our Services to you in a personalised way. For example, we use Google Analytics/Google Adwords to build remarketing lists and Facebook ads technology (including the Facebook pixel and custom audiences) to show you ads on other platforms and re-engage you with our Websites and services. 

Facebook conversion 

We also use the Facebook Pixel to ensure that our Facebook Ads match the potential interest of users and are not annoying. With the help of the Facebook Pixel, we can track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion”). 

Due to the marketing tools used, your browser automatically establishes a direct connection with the Facebook server as soon as you have agreed to the use of cookies requiring your consent. Through the integration of the Facebook pixel, Facebook receives the information that you have called up the corresponding website of our internet presence or clicked on an advertisement from us. If you are registered with a Facebook service, Facebook can assign the visit to your account. 

The processing of this data by Facebook takes place within the framework of Facebook’s data policy. Special information and details about the Facebook pixel and its functionality can also be found in the Facebook help area. 

We are jointly responsible with Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (Facebook) for the collection and transfer of data in this process (“joint controllership”). This applies to the following purposes: 

• The creation of individualised or suitable ads, as well as for their optimisation 
• Delivery of commercial and transaction-related messages (e.g. via Messenger) 

The following processes are therefore not covered by joint controllership: 

• The process that takes place after the collection and transmission is within the sole responsibility of Facebook. 
• The preparation of reports and analyses in aggregated and anonymity form is carried out as a Processor and is therefore within our responsibility. 

We have concluded a corresponding agreement with Facebook for joint controllership, which can be accessed here: https://www.facebook.com/legal/controller_addendum. This agreement defines the respective responsibilities for fulfilling the obligation under the UK GDPR with regard to joint controllership. 

The contact details of the Controller and the data protection officer of Facebook can be found here: https://www.facebook.com/about/privacy. 

We have agreed with Facebook that Facebook can be used as a contact point for the exercise of data subject rights. Without prejudice to this, the jurisdiction of the Rights of Data Subjects is not limited. 

Further information on how Facebook processes personal data, including its legal basis and further information on the rights of data subjects can be found here: https://www.facebook.com/about/privacy.

We transfer the data within the scope of joint controllership based on the consent pursuant to Art. 6 (1) f UK GDPR. 

5. Third party websites 

Our Website may contain links to third party websites. If you follow a link to a third-party website, please note that this Privacy Policy does not apply to that website. We are not responsible or liable for the privacy policies or practices of any third-party websites, so check their policies before you submit any personal data to those websites.  

6. Data security 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. 

7. Data retention 

We store your personal data in line with legal, regulatory, financial, and good-practice requirements and we will generally keep your personal data for up to a maximum period of six years following the end of our relationship. For further details regarding how long we keep each specific category of personal data, please contact us [email protected] 

8. Your rights 

As a result of us collecting and processing your personal data, you have the following legal rights: 

• to access personal data held about you; 
• to request us to make any changes to your personal data if it is inaccurate or incomplete; 
• to request your personal data is erased where we do not have a compelling reason to continue to process such data in certain circumstances; 
• to receive your personal data provided to us as a data controller in a structured, commonly used and machine-readable format where our processing of the data is carried out by automated means, and it is based on: (i) your consent; (ii) our necessity for performance of a contract to which you are a party to; or (iii) steps taken at your request prior to entering into a contract with us; 
• to object to, or restrict, our processing of your personal data in certain circumstances; 
• if we ever use your personal data for direct marketing, you can ask us to stop, and we will comply with your request; 
• if we use your personal data on the basis of having a legitimate interest (as set out in the table above), you can object to our use of it for those purposes, giving an explanation of your particular situation, and we will consider your objection; 
• to object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you; and 
• to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) or any other Supervising Authority in the EEA. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

To exercise any of your rights set out above, including to withdraw your consent where we have stated we are processing your personal data based on your consent, please contact us at [email protected]  

9. Contacting us and changes to your personal data 

If you have any questions, comments and requests about this Privacy Policy or your personal data, please contact us at [email protected]  

Please keep us informed of any changes to your personal data at any time by updating your details in the Website. 

10. Changes to our privacy policy 

Any changes we may make to this Privacy Policy in the future will be displayed on the Website and, where appropriate, notified you by email. Please check back regularly to keep informed of updates or changes to this Privacy Policy. 

This Privacy Policy was last updated on 03 May 2022.