Eucaps Privacy Policy

Version 1 March 2024

At Eucaps, we understand that confidentiality and security of the personal information ("Personal Information") that you share with us is important. We are committed to protecting the privacy of Personal Information, including Personal Information related to individuals who may be clients, employees, agents, job applicants or others inside or outside of Eucaps.

By opening an account at Eucaps or by utilizing the products, services, and applications available through Eucaps, you have consented to the collection, use and disclosure of your Personal Information in accordance with this privacy policy ("Privacy Policy" or "Policy"). We encourage you to read this Privacy Policy carefully.

This Policy is intended to summarize Eucaps’ data protection practices generally and to advise our clients, prospective clients, job applicants, website visitors and other third parties about Eucaps’ privacy policies that may be applicable to them.

This Policy is specifically addressed to those who provide Personal Information to Eucaps or who visit or use Eucaps’ websites, trading platforms, software applications and social media sites.

Who is responsible for your Personal Information?

Eucaps Communication AB is responsible for the Personal Information that we may collect in the manner discussed below. Since Eucaps Communication AB is acting as a tied agent, Placing Corporate Finance AB may also have a responsibility for collecting Personal Information in the manner discussed below. Your Personal Information will be controlled by Eucaps Communication AB and Placing Corporate Finance AB that are providing services or communication to you. In some instances, your Personal Information will be controlled by both entities. Eucaps Communication AB and Placing Corporate Finance AB are collectively called “Eucaps” in this privacy policy.

How do we collect your Personal Information and what Personal Information do we collect?

Eucaps collects Personal Information from you. This may include, among other things, information:

provided during the Eucaps account application process or during use of any of Eucaps’ website applications (for example, your name, email address, telephone number, birth date, tax ID number, investment objectives, biometric information, etc.);
provided when you apply for an employment opportunity with us (for example, your name, contact information and any additional information provided by you in your resume);
acquired as a result of the transactions you conduct through the Eucaps systems or in connection with services offered by Eucaps (for example, if you post content on the Eucaps website);
received from consumer-reporting agencies;
collected through Internet cookies (for further information on our use of cookies, please see our Cookie Policy).

For what purposes will we use your Personal Information?

We may use your Personal Information for the following purposes ("Permitted Purposes"):

To provide services to you in accordance with any agreement(s) you or your organization may have with us, for our own administrative, record-keeping and compliance procedures;
To provide you or your organization with brokerage and other services available on our platforms, and/or to deal with any requests or inquiries you may have;
To pursue legitimate interests, including to carry out, monitor and analyze our business or operations including the activities set out in this Privacy Policy;
To enforce or apply any agreement and/or to protect our (or others') property or rights and to defend any potential claim;
To conduct our recruiting processes (applies only to information submitted for employment applications);
To respond to requests for information from you and to follow up with you afterwards to see if we can provide any further assistance;
To contact you (unless you tell us that you prefer us not to) regarding features and functionality that may be of interest to you;
To enter into or carry out contracts of various kinds;
To conduct monitoring by us or any other person on our behalf using various methods, including: (i) the use of "intelligent" automated monitoring tools; or (ii) through random monitoring of systems, for example systematically via electronic communication recording tools; (iii) specific monitoring of systems for example in relation to investigations, regulatory requests, subject access requests, litigation, arbitration or mediation or; (iv) data tracking, aggregation and analysis tools that pull data from various disparate data sources to draw linkages and/or detect behavioral patterns, interactions or preferences for analysis (including predictive analysis); and/or (v) using other similar monitoring technology that may become available from time to time;
For statistical purposes and for market research and product analysis and to develop and improve our products and services;
For the purposes of preventing and detecting money-laundering, terrorism, fraud or other crimes and/or abuses of our services;
To comply with any legal, regulatory or good practice requirement whether originating from Ireland or elsewhere (including but not limited to, the United States), and to fulfil our obligations under any reporting agreement entered into with any tax authority or revenue service(s) from time to time;
To comply with applicable laws in any country.
To view personalized content and disseminate content using Eucaps services.
To simplify payment processes.
To verify your identity.
To manage customer relationships
To prevent misuse or misappropriation of the payment service
To perform customer analytics, credit assessment, risk analysis, risk management, and business development, and for commercial and marketing purposes, as well as to comply with applicable legal requirements.

We may also process your Personal Information for the following purposes (after obtaining your express consent where such consent is legally required) in accordance with your preferences:

To communicate with you through the channels you have approved to keep you up to date on the latest developments, announcements and other information about Eucaps services, products and technologies;
To conduct client surveys, marketing campaigns, market analysis, or promotional activities;
To collect information about your preferences to create a user profile to personalize and foster the quality of our communication and interaction with you (for example, by way of newsletter tracking or website analytics).

Where legally required, with regards to marketing-related communication, we will only provide you with such information after you have opted in or had an opportunity to object and we will also provide you with the opportunity to opt out at any time if you do not wish to receive further marketing-related communication from us. We like to keep our clients, personnel and other interested parties informed of company developments, including news relating to Eucaps that we believe is of interest to you. If you do not wish to receive publications or details of events or seminars that we consider may be of interest to you, please let us know. Where legally required, we will not use your Personal Information for taking any automated decisions affecting you or creating profiles other than described above.

Depending on which of the above Permitted Purposes we use your Personal Information for, we may process your Personal Information on one or more of the following legal grounds:

Because processing is necessary for the performance of your instruction or other contract with you or to take steps prior to entering into any such contract;
To comply with our legal obligations (for example, to keep pension records or records for tax purposes);
Because processing is necessary for the purposes of our legitimate interest or those of any third-party recipients that receive your Personal Information, provided that such interests are not overridden by your interests or fundamental rights and freedoms.

In addition, the processing may be based on your consent where we have expressly sought, and you have expressly given that to us.

If you have previously used a Eucaps user account or Eucaps services, Eucaps might hold saved data about you for the purposes of, for example, customer management, documentation requirements, or similar approved purposes. Eucaps will use any such information to verify your identity and to facilitate your use of a Eucaps user account or Eucaps services. Eucaps may also use electronic communications (communications via channels such as SMS and email) in its contacts with you. Eucaps may disclose information to other service providers, in particular Trulioo and Interactive Brokers, which can also use this information in the manner and for the purposes described here. For administrative purposes, data may also be disclosed to the online merchant where you made your purchase. In addition, information may be disclosed in connection with the transfer of a claim to parties.

What Personal Information?

Personal data means any kind of information that directly or indirectly can be linked to you. The following are examples of personal data that Eucaps processes about you or your representatives:

Contact information – name, postal address, email address, telephone number, etc.
Corporate and or identity number
Payment information – card number, invoice information, etc.
Financial information – includes information on possible payment defaults (used in cases where there is a credit check)
Item information – information about the purchases you make
Historical information – information about previous purchases, how you have previously complied with the terms of payment, any rejections, etc.
Information about your computer/device – IP address, language settings, browser settings, etc.
Publicly available information on the internet

It may also include corporate and personal identity numbers are used for identification and as customer numbers in Eucaps’s computer system.

Who we share your Personal Information with, and in what circumstances.

We share your Personal Information in the following circumstances:

We may share your Personal Information between the Eucaps Communication AB and Placing Corporate Finance AB on a confidential basis as allowed by applicable law or where required for the purpose of providing products or services and for administrative, billing and other business purposes;
We instruct service providers outside of Eucaps (including cloud service providers such as AWS or brokerage service providers such as Interactive Brokers), domestically or abroad, to process Personal Information for the Permitted Purposes on our behalf and in accordance with our instructions and based on our legitimate interest to provide, maintain, and improve our products and services. For example, if you choose to subscribe to any services provided by a third-party provider listed on the Eucaps website, we may disclose such information to service providers as necessary for them to provide the services that you have requested. Eucaps generally requires these service providers to not use Eucaps client information that they receive other than to carry out the purposes for which the information was disclosed. If required by law, Eucaps will retain control over and will remain responsible for your Personal Information and will use appropriate safeguards to ensure the integrity and security of your Personal Information when engaging service providers;
We may share your Personal Information with companies providing services in the areas of fraud and crime prevention and with companies providing similar services, including financial institutions such as credit reference agencies and regulatory bodies;
We may disclose information about you to any broker, investment firm, depository, stock exchange, clearing or settlement system, account controller or other participant in the relevant system, to counterparties, dealers, custodians, intermediaries and others where disclosure is reasonably intended for the purpose of effecting, managing or reporting transactions in connection with the provision of our services or establishing a relationship with a view to such transactions;
We may share data provided to us for employment applications with third parties to assist us with the conduct of our recruitment processes;
Consistent with applicable law, we may share your Personal Information with courts, law enforcement authorities, regulators or attorneys or other parties for the establishment, exercise or defence of a legal or equitable claim or for the purposes of a confidential alternative dispute resolution process;
We may also use aggregated Personal Information and statistics for the purpose of monitoring website usage in order to help us develop our website and our services.

Otherwise, we will only disclose your Personal Information when you direct us or give us permission to do so, when we are allowed or required by applicable law or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.

Eucaps may also disclose Personal Information to partners who provide payment options in Eucaps or other companies in the Eucaps group of companies, who may also use this Personal Information in the manner and for the purposes described here.

Your Personal Information may be used for the purposes of identification, customer surveys, newsletters, and statistics. The data may also be used for mailings by a postal service, SMS, and email. The data may further be used to analyze purchasing or usage patterns to provide you with relevant information and to improve the website, payment solutions, and payment processes. Processing for the purpose of improving solutions and processes can include processing in which your Personal Information, will be transferred to other companies and to third-party providers to be included as data for analysis. Personal Information may also be combined with data from other records, such as a credit data register.

If all or part of Eucaps’ business operations are sold or integrated with another business, your Personal Information may be disclosed to our advisors, any buyer, and the buyer’s advisor and be forwarded to the new owner.

By using Eucaps, you agree to our use of your Personal Information in the way described here, including any transfer to another company or to a state outside the EU (European Union)/EEA (European Economic Area), as well as to the ability to use your data for electronic communications.

Personal Information about other people that you provide to us.

If you provide Personal Information to us about someone else (such as one of your directors or employees or someone with whom you have business dealings), you must ensure that you are entitled to disclose that Personal Information to us for processing as described in this Privacy Policy.

Keeping Personal Information about you secure

To the extent required by law, we will take appropriate technical and organizational measures to keep your Personal Information confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to Personal Information. Personal Information may be kept on our Information Technology systems, those of our contractors or in paper files.

Transferring your Personal Information outside the European Economic Area ("EEA"),

For Personal Information subject to the General Data Protection Regulation (EU) 2016/679 ("GDPR") we may transfer your Personal Information outside the EEA for the Permitted Purposes as described above. This may include countries that do not provide the same level of protection as the laws of your home country (for example, the laws within the EEA). We will ensure that any such international transfers are made subject to appropriate or suitable safeguards if required by the GDPR or other relevant laws. You may contact us at any time using the contact details below if you would like further information on such safeguards.

With respect to persons covered by GDPR, in case Personal Information is transferred to countries or territories outside of the EEA, that are not recognized by the European Commission as offering an adequate level of data protection, we have put in place appropriate data transfer mechanisms to ensure Personal Information is protected.

Updating your Personal Information

If any of the Personal Information that you have provided to us changes, for example if you change your email address or if you wish to cancel any request that you have made of us, please let us know by contacting Eucaps. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient, or incomplete Personal Information that you provide to us.

How long do we retain your Personal Information?

We retain your Personal Information in an identifiable form in accordance with our internal policies which establish general standards and procedures regarding the retention, handling, and disposition of your Personal Information. Personal Information is retained for as long as necessary to meet legal, regulatory, and business requirements. Retention periods may be extended if we are required to preserve your Personal Information in connection with litigation, investigations, and proceedings.

Further rights for persons or information covered by GDPR

With respect to residents of the EEA, you have several legal rights under GDPR in relation to the Personal Information that we hold about you. These rights include:

Obtaining information regarding the processing of your personal information and access to the personal information that we hold about you. Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information, (in particular, information that is subject to legal professional privilege);
Requesting that we correct your personal information if it is inaccurate or incomplete;
Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information, but we are legally entitled to retain it;
Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request;
Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so;
Obtaining computerized personal information collected from you in a structured, commonly used, and technological format (right to data portability).

We have designated a Data Protection Officer ("DPO") to enhance and promote compliance with and understanding of privacy and data protection principles. If you wish to do any of the above, please send an email to Eucaps.

We may request that you prove your identity by providing us with a copy of a valid means of identification for us to comply with our security obligations and to prevent unauthorized disclosure of data. We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your data and for any additional copies of the Personal Information you request from us.

We will consider any requests or complaints that we receive and provide you with a response in a timely manner. If you are not satisfied with our response, you may take your complaint to the relevant privacy regulator. We will provide you with details of your relevant regulator upon request

Updates to this Privacy Policy

This Privacy Policy was last updated on the date indicated at the top of this Policy. We reserve the right to update and change this Privacy Policy from time to time, for example, in order to reflect any changes to the way in which we process your Personal Information or changing legal requirements. In case of any such changes, we will post the changed Privacy Policy on our website or publish it otherwise. The changes will take effect as soon as they are posted on our website.

How to contact us

We welcome your views about our website and our Privacy Policy. If you have any questions about this Policy, please contact the Data Protection Officer or Eucaps via email.