Privacy Policy

1. PURPOSE OF THIS PRIVACY POLICY

This privacy policy explains what personal data Shojin Property Partners Limited (“SPP”) and Shojin Financial Services Limited (“SFS”) (together “Shojin”, “we”, “our” or “us”) collect, why we collect it, how we use it and your rights to it. By using our services, our website and by providing any personal information to us, we use your personal information as set out in this privacy policy (“Privacy Policy”). Personal information is information relating to an identified or identifiable natural person (“data subject”) who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Please do not provide us with any personal information if you do not want that information to be used by us in this manner. All personal information processed in connection with this Privacy Policy is controlled ether by SPP, a company registered in England and Wales under registration number 09647110 or, if received via our website, by SFS, a company registered in England and Wales under registration number 09697161 which has its. Both companies have their registered office at Suite 1, First Floor, 1 Duchess Street London W1W 6AN . This Privacy Policy applies to all personal information we gather or use in connection with your relationship with us as a customer or potential customer. This includes when you use our website, www.shojin.co.uk and www.portal.shojin.co.uk (the “Site”), services provided by us or others acting on our behalf, and when you interact with us. We will only use your personal information in accordance with this Privacy Policy.

This Privacy Policy should, where relevant, be read together with the Website terms and conditions, and the Equity Terms and Conditions and ISA Terms and Conditions for the relevant project.

Please note that personal information we collect from you may be transferred to and stored in countries outside of the European Economic Area (“EEA”) and may be accessible by us, our service providers and those acting on our behalf outside of the EEA. Countries outside the EEA (such as the United States of America) may not offer the same levels of data protection as the United Kingdom. However we will implement appropriate safeguards to ensure that any of your data transferred outside the EEA will be treated securely and in accordance with this Privacy Policy. By using our services or our Site and by submitting your personal information to us, you agree to your personal information being transferred, stored and processed outside of the EEA. If you have any questions or comments about this, please contact us at [email protected].

2. DATA PROTECTION LAW

Shojin is committed to protecting and respecting your privacy. We collect, store and use personal information in accordance with the Data Protection Act 2018 (the “DPA”) and all other relevant legislation and regulations. For the purposes of the DPA, we are the data controller of any personal information we process about you.

We use up-to-date industry procedures to keep personal data as safe and secure as possible and to protect against loss, unauthorised disclosure or access. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

3. PRIVACY POLICY UPDATES

We may update and amend this Privacy Policy from time to time. By using our services or our Site and providing personal information to us after the date of any amendment you agree to any updated terms and conditions of the Privacy Policy. We reserve the right, in any event, to apply the amended Privacy Policy to information we have already collected. You should read and review our webpage regularly to see if there have been any changes.

4. YOUR RIGHT TO ACCESS YOUR INFORMATION

You have a right under the DPA to access personal information that we hold about you. All requests should be made to [email protected] and must include your name and address and any other information which may identify you. You must also provide a copy of your passport or driving licence so that we can verify your identity. We will not charge you to access this information. You may have the right to object to the processing of your personal data where processing is conducted for legitimate business reasons, direct marketing or profiling. If you exercise this right, then unless we have compelling reasons not to, we shall cease to process your data wherever data protection laws allow. You have a number of rights with regards to your data. In particular you have the right to access and rectify your personal details. If you wish to access your data, you have the right to view or receive a copy of the information in a commonly used format such as a pdf document or an e-mail. Any information which is processed by automated means and is purely required for the performance of a contract, may be transmitted to another data controller if you request it. You may also have the right to ask for the processing of your personal data to be restricted or even erased. Whether or not you exercise the right to erasure, we will erase your personal data in certain situations and particularly when the data is no longer required.

5. COOKIES

Cookies are small files placed on your device when you visit our Site. Cookies are common and we will use them to improve how our Site works by recognising you and your preferences. We will also use cookies to create statistical data which will help us offer relevant products to you. Cookies generally fall into one of the following categories:

strictly necessary cookies which are cookies that are essential to allow you to use a website and its features;
performance cookies which collect information about how visitors use a website to create aggregated, anonymous information that does not identify the visitor;
functionality cookies which allow the website to remember you and provide a more personalised service; and
targeting or advertising cookies which are used to deliver adverts relevant to you.

Our Site may use any of these types of cookies.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

COOKIE TYPE PURPOSE
ASP.Net_SessionId - Performance Enhances user experience by remembering session history.
ASPXAUTH - Strictly Necessary Records users authentication session
_culture Strictly - Necessary Assists recognising user’s nationality and language preferences, login, token, username recognition and encoding.
RequestVerificationToken - Strictly Necessary Part of a mechanism to protect against cross site scripting attacks
ARRAffinity - Performance Enhances user browsing experience – part of load balancing setup
cookie-policy - Strictly Necessary Tracks presentation of the cookie information advice

Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services. These third party cookies are likely to be performance cookies or targeting cookies.

Google Analytics – a web analytics service provided by Google, LLC. Google Analytics uses analytical, performance or targeting cookies to help analyse how you use the website and compile reports on your activity for us.

Any information generated by the cookie about your use of the website (including your IP address) will be transmitted to, and stored by, Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on your activity for us and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

HubSpot - the HubSpot tracking code is embedded in the code of our website, which collects information about your use of our website and investor portal. We use this information to optimise our operations and increase their effectiveness. Information on the data collected by our partner can be found here: https://legal.hubspot.com/privacy-policy.

Some of our cookies will remain on your device between your browsing sessions.

Most web browsers automatically accept cookies. You can configure your web browser to accept or reject cookies, or to notify you when a cookie is set on your computer (check the ‘Help’ menu of your browser to learn how to change your cookie preferences). You can disable our cookies by changing the settings on your browser. However, you may not be able to take full advantage of the functionality of our Site if you disable cookies.

For additional information about cookies, please visit:

6. HOW WE COLLECT PERSONAL INFORMATION

We may collect and/or receive personal information from you when you:

fill in forms on our Site, including when you register, create or modify an online account with us;
communicate with us, such as by mail, telephone, in writing or through our Site or social media;
use or access our Site; or
enter into any agreements with us or any group or associated companies or individuals;
respond to surveys or questionnaires we ask you to complete.

We may also collect your personal information from publicly available information such as information on third party sites or from our business partners.

7. WHAT TYPES OF PERSONAL INFORMATION WE COLLECT

The types of personal information we receive, store and use may include:

your title, name, gender, address, telephone numbers, email address and date of birth;
your passport number and driving licence number;
your site account information (including your SFS username and password);
your bank account details, debit card numbers and transaction and credit information;
information about your interactions you may have with us and our staff, including interactions via email, telephone or through our Site such as your IP address; and
information regarding your personal or professional interests, demographics, experiences with our products, and contact preferences in order to provide you with further products and services or information about our products and services.

8. HOW AND WHY WE USE PERSONAL INFORMATION

Under data protection law we can only use your personal information if we have a proper reason for doing so. Most commonly, we will use your personal information in the following circumstances:

to comply with our legal and regulatory obligations;
for the performance of our contract with you or to take steps at your request before entering into a contract;
for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. These legitimate interests include:

to provide our products and services to you;
for purposes related to providing our products and services to you, including verifying and authenticating your identity, processing your payments, completing transactions and processing your purchasing requests;
to develop new products and services;
to provide the products services available throughout our website;
to provide special offers and other related services to you;
to improve and tailor our products and services;
for our own internal record-keeping requirements;
to protect your account and prevent unauthorised access to your account;
for marketing purposes, such as sending you email newsletters with our and our partners’ latest offers, information, promotions or products and services or other information we think you may find interesting or for customer satisfaction purposes in accordance with this Privacy Policy;
for market research, analysis, testing, monitoring, risk management and administrative purposes;
to contact you, for example, to send service communications through our Site, email or any other medium such as to notify you to check your dashboard when financial transfers have been made on your behalf; and

where you have given use specific and informed consent.

We use the personal information we collect and receive to help us understand your needs and to help us provide you with a better service. In particular, we collect, store and process your personal information for the following reasons:

to provide our products and services to you;
for purposes related to providing our products and services to you, including verifying and authenticating your identity, processing your payments, completing transactions and processing your purchasing requests;
to provide special offers and other related services to you;
to improve and tailor our products and services;
for our own internal record-keeping requirements;
to protect your account and prevent unauthorised access to your account;
for marketing purposes, such as sending you email newsletters with our and our partners’ latest offers, information, promotions or products and services or other information we think you may find interesting or for customer satisfaction purposes in accordance with this Privacy Policy (see below);
for market research, analysis, testing, monitoring, risk management and administrative purposes; and
to contact you, for example, to send service communications through our Site, email or any other medium such as to notify you to check your dashboard when financial transfers have been made on your behalf.

9. HOW WE SHARE PERSONAL INFORMATION

We may disclose personal information we collect or receive:

to you or people acting on your behalf;
to companies within the SPP group, partners and joint ventures and other companies under common control (collectively, “Affiliates”) for the purposes described in this Privacy Policy and always in accordance with the terms of this Privacy Policy;
to third parties who provide a service to, or perform a function for, us or you or who are otherwise appointed by us in connection with the services we offer you including those who are acting as our agent or sub-contractor, including, without limitation, data processing service providers and our legal and professional advisors;
to any third party which acts, from time to time, as the depositary or custodian for any money which you deposit using the Site, or as custodian and holds the legal title to any share or instrument which you may invest in through SFS or by using the Site;
to third party investee companies in connection with your investment, details of which will be stated on your application;
to any third party which acts, from time to time, as SFS’s principal for the purposes of regulation and authorisation under the Financial Conduct Authority;
to any third party which acts, from time to time, as the payments processor for transactions carried out on or through the Site. For example, any payment transactions you make through the Site will be made through Share In Ltd (a company registered in Scotland, with company registration number SC408803) (“ShareIn”). ShareIn acts as a data controller in respect of any bank account details provided and this personal data will be subject to ShareIn’s privacy policy, available at [insert link to ShareIn privacy policy].;
to third parties in connection with a proposed or actual financing, securitization, insuring, merger, restructure, sale, acquisition, assignment or other disposal of all or part of our business or assets or the assets of any Affiliate or to anyone to whom we may transfer our rights and/or obligations for the purposes of evaluating and performing the proposed transaction; and
to third parties, including the Financial Conduct Authority, law enforcement officials, law courts and government and other regulatory authorities: (a) if we believe disclosure is required by any applicable law, regulation or legal process (such as to respond to subpoenas or judicial orders); or (b) to protect and defend our rights, or the rights or safety of third parties, including to defend against legal claims.

10. MARKETING COMMUNICATIONS

We will only send you marketing communications by electronic means (e-mail or text) if those communications relate to goods, services or opportunities which are the same or similar to those that you have previously purchased or expressed an interest in or if you have given clear and explicit consent to us contacting you in this way. We will only permit third parties to send you marketing communications by electronic means if you have consented to this. During your Site account set-up process you will be able to opt-in to receiving marketing communications from us and/or third parties. You can change your marketing preferences at any time by clicking on the ‘unsubscribe’ link at the bottom of emails sent to you by us, or by contacting us at [email protected].

11. STATISTICAL INFORMATION

We may aggregate information about you with information about other users of our Site to create statistical data about users. This is statistical data that is not intended to identify you and we may distribute any such aggregate information to third parties we work with.

12. THIRD PARTY LINKS

Our Site may contain links to enable you to visit third-party sites, mobile sites and mobile applications. Please note that we do not have any control over these third-party sites, mobile sites or mobile applications. Therefore, we are not responsible for the protection and privacy of any information that you provide whilst visiting such sites. Such sites are governed by their own privacy policies and not this Privacy Policy.

13. DATA STORAGE

Your personal information will be stored and used in accordance with this Privacy Policy. We will take all steps reasonably necessary to keep your personal information secure. You should be aware that transmission of information via the internet is not entirely secure and we cannot guarantee the security of any data you transmit to our Site via the internet. We will retain your personal information and other information which we have collected or received to the extent required by applicable laws and as we may require for operational and legal purposes. We may retain your data for up to six years following the date of your last investment or the date you close your account (whichever is the later). We will not retain your personal information for longer than necessary for the purposes set out in this policy.

14. HOW TO COMPLAIN

We hope that we can resolve any query or concern you may raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

15. CONTACTING US

If you have any questions or comments about this Privacy Policy, you can contact us at [email protected].

Updated December 2019