At Vive Invest, we care about the protection of your data and privacy and how it applies to you, as a user of our website(s). In this Privacy Policy ('Policy'), you can find information about how, whether, and why we collect and use your personal information on our Vive Invest website www.viveapp.com and on our mobile application Vive App. This Policy applies to any personal information that is gathered when you use our services, visit our Website, or otherwise interact with us. We have divided this Policy into different sections. The processing of your personal data complies with the General Data Protection Regulation (GDPR), the Dutch GDPR Execution Act and the Dutch Telecommunications Act.

About us

The data controller for the processing of your personal data is VIVE Invest B.V., registered at the Dutch Chamber of Commerce with registration number 62098896. Our address is Keizersgracht 268, 1016 EV Amsterdam, the Netherlands.

If you have any questions about the processing of personal data resulting after reading our Privacy Statement, you can contact us at privacy@viveapp.com.

Types of personal data we collect

To assess and open Vive Website and Mobile Application accounts, we can collect and use the following personal data:

• First and last name
  
• Date, country and place of birth
  
• Nationality
  
• Gender
  
• Residential address
  
• Telephone number
  
• Email address
  
• Social security numbers and/or other tax identification numbers
  
• Counter IBAN
  
• Device data (such as type of device, operating system, IP-addresses and advertising IDs)
  
• Location data via GPS
  
• Uploaded images/content
  
• Device data of added devices and API-keys
  
• Financial and banking data, product subscriptions and transaction history
  
• Cookies and usage date on how you use our products and services
  
• Correspondence with Vive Invest and support data (telephone, chat conversations and email)
  
• Additional information related to opening an account and creating your personalized investment
  
• Plans such as your knowledge and experience of financial markets, your financial situation, investment situation and preferences and your risk preferences
  
• Marketing data (statistics related to our marketing campaigns and data to measure this)
  

Information about our communication

• When you send us an email, or chat with us online or via social media, we save your correspondence with us if you are already a customer or in the process of becoming one or contacting us to find more about our products and/or services.
  
• Information we collect when you use our Website and/or our mobile application.
  
• When you visit our Website and mobile application or use our services, we may register your IP address, browser type, operating system, referring website, web-browsing behaviour.
  
• We may receive an automatic notification when you open (or open a link from) newsletters from us.
  

Information in relation to social media

Depending on your social network settings, we may receive information from your social network provider. For example, when you sign in for our services using a social network account, we may gather publicly available information you give us access to from your social network profile, including your contact details, interests, and social network.

For more information on the personal data that we receive from your social network provider, and how to change your privacy settings, please refer to the website and the privacy policy given by your social network provider.

Information you choose to share with us

You may also choose to share information with us. For example, when you leave a comment for us on Facebook, fill out a survey, submit a contact or application form, leave a review or submit an entry for a contest or scholarship, you have opted to share personal information with us.

You may also choose to share information with us. For example, when you leave a comment for us on Facebook, fill out a survey, submit a contact or application form, leave a review or submit an entry for a contest or scholarship, you have opted to share personal information with us.

Purposes of processing your data

Vive Invest processes your personal data in accordance with the laws and regulations based on several legal grounds. Vive Invest processes personal data to provide our services. For example, personal data is processed to:

• Comply with legal obligations
  
• To preserve our agreement and to provide our services in a secure manner, we process your personal data. For example, we need your contact information to keep you informed about relevant developments, and we store correspondence data to improve our customer services
  
• To make your user experience easier and more effective, we may assess how you use our services, and combine this data with information collected via your personal account, registration details, cookies, and similar technologies. This combination enables us to, for example, optimize our search algorithms and offer a better customer experience
  
• To create better and personaliszed investment strategies
  
• To process personal information for (direct) marketing purposes. This means we may use your personal information to send you newsletters, emails, promotions, or other marketing communications. We use the results of our analysis to tailor our marketing communications to your specific interests and preferences. For example, if our analysis shows that you may be interested in certain services, we may customize our newsletters and Website with content that is relevant to you. We may use different channels for our marketing communications, such as emails, social media, and your personal online account during different time frames and in recurrent manner.
  
• To initiate and evaluate business relationships. Your personal data will be processed for the entering into agreements and the performance thereof to the point of commercial services and the managing of the business relations which emerge from them, including the performance of activities aimed at the expansion of our client database.

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Vive Invest is allowed to process personal data for this purpose because you gave consent or because Vive Invest has a legitimate interest. The consent can be withdrawn at any moment, and you can object at any moment to the processing of your personal data for direct marketing purposes. The withdrawal of consent or exercise of your right to object does not affect the lawfulness of the processing prior to the moment of withdrawal or exercise of the right to object.

You may object or revoke your consent for receiving marketing communications at any time, by following the instructions in the relevant marketing communication or by sending an email to privacy@viveapp.com

Legitimate and legal interests

In many cases, we are legally required to store certain data about you, for example to verify your identity, for research and to create personalized investment plans.

We can also process certain data when we have a legitimate interest to do so. For example, to prevent and combat misuse, to research and analyze the use of our products and services for marketing purposes, for information and system security or to share certain data with governmental institutions.

Disclosing or sharing data with third parties

General

We reserve the right to release personal information without your consent or without consulting you, when we deem it necessary to comply with our legal obligations, to enforce our terms and conditions, to protect the security of our Website and application, or to prevent fraud.

To be able to provide our services, we share certain personal data with third parties. We keep the sharing to a minimum and ensure these third parties will handle your personal data with the same care as we do. This means, among other things, we sign Data Processing Agreements. The third parties or categories of third parties with whom we share data are: Onfido Limited, VWD, Auth0 and Northern Trust.

Governmental institutions

To comply with laws and regulations we can share data with the concerned institutions. For example, the Tax Authorities can request financial data and we can share data with the Dutch Central Bank for participating in the Deposit Guarantee Scheme. Next to this, Vive Invest can have a statutory or legal obligation to share personal data with investigating authorities to prevent and combat misuse, fraud and crimes.

Security and retention

Vive Invest takes the safeguarding of your information very seriously. Vive Invest will take appropriate technical and organizational measures to protect your personal data against loss or unlawful use. These measures include but are not limited to: facilities protected by appropriate security measures, encryption of devices, version tracking and access to our databases is limited to key personnel and IP addresses and use of it is logged. Personal identifiable information and account activity are also protected through the use of user names and passwords. In order to help maintain the security of your information, you should protect the confidentiality of your user name and password.

How long we keep your personal data

We will hold all the data for so long as we have an obligation to the Customer to provide the Services, and thereafter until such time as we delete the Customer's account in accordance with our Customer Terms and Conditions.

Your personal information will be deleted on one of the following occurrences: - deletion of your personal information by you (or by another person engaged by the Customer); or - receipt of a written request by you (or another person engaged by the Customer) to us

For a large amount of data, we are legally obliged to retain this for a minimum of 5 to 7 years after ending the customer relationship. After this period, we don't store your personal data longer than legally allowed and no longer than necessary for the purposes the data was collected for.

We are able to store personal data for longer periods with a valid legal ground, or when the data is sufficiently (for example) pseudonymised or anonymised.

Your Rights

You can request access to or a copy of your personal data collected by us. You may also request the rectification and removal of personal data or the restriction of the processing of your personal data, if there is a reason for doing so. You also have the right to data portability. You also have the right to object to a processing on grounds relating to your particular situation or against the processing of your personal data for direct marketing purposes. More information on your rights is available at: https://autoriteitpersoonsgegevens.nl.

To exercise your right(s), please send us an email at privacy@viveapp.com or mail us: VIVE Invest B.V., Keizersgracht 203, 1016 DS Amsterdam, The Netherlands.

Revoking & limiting consent

When you have provided us with permission to process personal data, or when we process your personal data based on legitimate interests, you are able to revoke this permission in an easy manner or ask us to limit the use of your data. Revoking your permissions does not mean that stored data is deleted.

Direct marketing & usage data

If you do not want your data to be used for direct marketing activities and analysis of the usage of our products and services, you can let us know via the VIVE app anytime. Next to this, our communication via email contains the possibility to unsubscribe from these messages.

GPS and image and content access

While using the VIVE app, you can provide permission to process location data. If you no longer want us to use location data, you can revoke these permissions easily. This permission is also offering the possibility to protect your account, sending, for example, notifications when there is a login from an unknown location. You'll find these settings in the VIVE app. You can revoke provided permissions at any given moment.

Images and content that you use to personalise your VIVE account can be easily changed in the VIVE app.

Cookies

For more information on how to delete cookies, please see our Cookie Statement.

Modifications to this Policy

This Policy is effective as of 23 of October 2018. We reserve the right to alter or otherwise make changes to this Policy. Notices may be by email to the last email address you provided us, by posting notice of such change on our Site or the Optimizely Service, or by other communication channels. You consent to receiving notices in these ways. We reserve the right to determine the form and means of providing notifications to you, consistent with applicable law. Changes take effect as soon as the Policy is posted.

Questions or complaints

If you have any question or complaints about the processing, please send an email to us at privacy@viveapp.com . If you feel that your rights have been violated, you may also make a complaint with the Autoriteit Persoonsgegevens, the Dutch Data Protection Authority (www.autoriteitpersoonsgegevens.nl). For more information on the protection of personal data, please consult the website of the Autoriteit Persoonsgegevens.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at privacy@viveapp.com