This Privacy Policy ("Privacy Policy") describes how Grovcap ("Grovcap", "we", "our" or "us") collects, uses, stores, discloses, transfers and otherwise processes personal information in connection with:
- the Grovcap website;
- the ETF Masterclass;
- Investor Pulse;
- Market Signals;
- newsletters;
- educational services;
- research activities;
- user accounts (where applicable); and
- any other websites, products or services that link or refer to this Privacy Policy (collectively, the "Services").
Grovcap recognises the importance of protecting personal information and is committed to processing personal information in accordance with applicable data protection and privacy laws, including, where applicable, the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the UK GDPR, applicable national implementing legislation, and other applicable privacy and data protection laws.
This Privacy Policy explains:
- what categories of information Grovcap may collect;
- how that information may be used;
- the legal bases on which personal information may be processed;
- the circumstances in which information may be disclosed;
- how information is protected;
- how long information may be retained;
- the rights available to individuals under applicable law; and
- how to contact Grovcap regarding privacy-related matters.
This Privacy Policy applies only to the Services identified above. It does not apply to third-party websites, applications, products or services that may be accessible through links provided on the Services. Grovcap is not responsible for the privacy practices of third parties, and users are encouraged to review the privacy policies of those third parties before providing personal information.
By accessing or using the Services, users acknowledge that their personal information may be processed as described in this Privacy Policy. Where applicable law requires consent for specific processing activities, Grovcap will request such consent before undertaking those activities.
Nothing in this Privacy Policy limits any rights that individuals may have under applicable data protection laws.
For the purposes of applicable data protection laws, Grovcap is the controller of personal information processed in connection with the Services, except where this Privacy Policy expressly states otherwise.
Questions regarding this Privacy Policy or Grovcap's privacy practices may be directed to:
Where Grovcap establishes one or more legal entities, this section will be updated to identify the relevant legal entity acting as the data controller for the applicable Services.
Where required by applicable law, Grovcap may appoint a Data Protection Officer or other designated privacy contact. If appointed, the relevant contact details will be published on the Services.
This Privacy Policy applies to the processing of personal information by Grovcap in connection with the Services, regardless of whether such information is collected directly from users, automatically through the operation of the Services, or from other lawful sources.
This Privacy Policy applies to information collected through, or in connection with:
- the Grovcap website;
- the ETF Masterclass;
- Investor Pulse;
- Market Signals;
- newsletters and marketing communications;
- educational materials;
- user accounts (where applicable);
- customer support interactions;
- surveys, questionnaires and research activities;
- events, webinars or similar activities organised by Grovcap; and
- any other products or services that expressly incorporate or reference this Privacy Policy.
This Privacy Policy does not apply to:
- websites, products or services operated by third parties;
- information processed by third parties acting as independent data controllers;
- information processed by financial institutions, brokers, ETF issuers or other organisations whose websites or services may be linked from the Services.
Links to third-party websites are provided solely for convenience. Grovcap does not control and is not responsible for the privacy practices, content or security of third-party websites or services.
Where additional privacy notices apply to specific services, those notices supplement this Privacy Policy. In the event of any inconsistency, the more specific privacy notice will apply to the relevant processing activity.
The categories of personal information processed by Grovcap depend on the Services used and the manner in which users interact with those Services.
Grovcap may process one or more of the following categories of information.
4.1 Contact Information
This may include:
- name;
- email address;
- professional affiliation (where voluntarily provided);
- correspondence with Grovcap.
4.2 Account Information
Where account functionality is available, Grovcap may process information necessary to establish, administer and secure user accounts, including:
- account identifiers;
- authentication information;
- account preferences;
- communication preferences;
- account status.
Passwords or authentication credentials are processed only to the extent necessary to provide secure authentication services and are not accessible in plain text by Grovcap.
4.3 Research Information
Where users voluntarily participate in Investor Pulse or other research activities, Grovcap may process information including:
- investment preferences;
- ETF preferences;
- investment intentions;
- allocation preferences;
- behavioural responses;
- educational responses;
- knowledge assessments;
- demographic bands;
- country or region;
- investing experience;
- survey responses;
- free-text responses voluntarily submitted.
Participation in research activities is voluntary unless expressly stated otherwise.
4.4 Technical Information
Grovcap may automatically collect technical information relating to the operation of the Services, including:
- browser type;
- browser version;
- operating system;
- device type;
- language settings;
- screen resolution;
- referring URLs;
- pages viewed;
- session information;
- approximate geographic region derived from network information;
- diagnostic information necessary to maintain the Services.
4.5 Usage Information
Grovcap may process information concerning how the Services are used, including:
- pages visited;
- lesson progression;
- interactions with educational content;
- participation in research activities;
- newsletter engagement;
- aggregated usage statistics.
Such information helps improve the functionality, reliability and effectiveness of the Services.
4.6 Cookies and Similar Technologies
Grovcap may collect information through cookies, pixels, local storage, software development kits (SDKs) and similar technologies.
Further information is provided in the Cookie Policy.
4.7 Communications
Where users communicate with Grovcap, we may process:
- customer support requests;
- feedback;
- survey responses;
- emails;
- other communications voluntarily submitted.
Communications may be retained where reasonably necessary to:
- respond to enquiries;
- improve services;
- investigate complaints;
- establish, exercise or defend legal claims;
- comply with legal obligations.
4.8 Information We Do Not Intentionally Collect
Unless expressly required for a particular Service, Grovcap does not intentionally request or require users to provide:
- government-issued identification numbers;
- passport information;
- banking credentials;
- brokerage account credentials;
- payment card information;
- tax records;
- portfolio balances;
- trading account passwords.
Users should not submit sensitive personal information unless specifically requested by Grovcap for a clearly identified purpose.
Grovcap may obtain personal information from one or more of the following sources, depending on the manner in which the Services are used.
5.1 Information Provided Directly by You
Grovcap may collect personal information that you voluntarily provide when you:
- visit or interact with the Services;
- create or manage an account;
- subscribe to newsletters or other communications;
- participate in Investor Pulse, surveys, questionnaires or research activities;
- contact Grovcap by email or other communication channels;
- submit feedback, comments or support requests;
- register for webinars, events or similar activities; or
- otherwise communicate with Grovcap.
You are responsible for ensuring that information you voluntarily provide is accurate, complete and up to date.
5.2 Information Collected Automatically
When you access or use the Services, Grovcap may automatically collect certain technical and usage information using cookies, server logs and similar technologies.
This information may include:
- IP-derived geographic region;
- browser and device characteristics;
- operating system;
- referring websites;
- pages visited;
- lesson progression;
- interactions with educational content;
- timestamps;
- session identifiers;
- diagnostic information;
- performance information.
Automatically collected information assists Grovcap in:
- operating the Services;
- maintaining security;
- detecting misuse or fraud;
- improving performance;
- understanding how the Services are used;
- developing new features.
5.3 Information from Service Providers
Grovcap may receive information from service providers acting on its behalf, including providers of:
- authentication services;
- cloud infrastructure;
- hosting;
- email delivery;
- analytics;
- customer support;
- website performance monitoring.
Such providers process information only in accordance with contractual arrangements and applicable law.
5.4 Publicly Available Information
Where permitted by applicable law, Grovcap may obtain limited information from publicly available sources.
Such information may be used to:
- verify business enquiries;
- improve communications;
- prevent fraud;
- maintain the security and integrity of the Services.
Grovcap does not use publicly available information to create investment profiles of individual users.
5.5 Information Generated Through Your Use of the Services
Certain information is created through your interaction with the Services.
Examples include:
- lesson completion history;
- research participation history;
- educational progress;
- learning preferences;
- feature usage;
- communication preferences.
Such information enables Grovcap to improve the educational experience, evaluate the effectiveness of educational materials, and produce aggregated statistical insights.
Grovcap processes personal information only where there is a lawful basis for doing so and only for purposes that are compatible with the collection of that information.
Depending on the Services used, personal information may be processed for one or more of the following purposes.
6.1 Providing the Services
Including:
- providing access to the Services;
- administering user accounts;
- authenticating users;
- maintaining platform functionality;
- providing customer support;
- responding to enquiries.
6.2 Delivering Educational Services
Including:
- providing ETF Masterclass content;
- recording lesson progress;
- improving educational materials;
- personalising educational experiences where appropriate;
- evaluating educational effectiveness.
Educational content is intended solely for informational and educational purposes.
6.3 Conducting Investor Research
Grovcap conducts investor research to better understand investor behaviour, educational outcomes and market expectations.
Research information may be used to:
- analyse aggregated investor behaviour;
- improve educational content;
- produce Investor Pulse reports;
- develop statistical research;
- identify broad trends across groups of participants.
Research activities are designed to support statistical analysis at an aggregated level and are not intended to evaluate individual investors.
6.4 Communications
Personal information may be processed to:
- respond to enquiries;
- send newsletters where consent has been provided;
- communicate important service information;
- provide updates regarding changes to the Services;
- administer events or webinars.
Users may unsubscribe from marketing communications at any time. Service-related communications may continue where necessary for the operation of the Services.
6.5 Security and Fraud Prevention
Personal information may be processed to:
- maintain the security of the Services;
- detect, investigate and prevent fraud;
- identify malicious activity;
- investigate suspected misuse;
- protect the rights, property and safety of Grovcap, its users and third parties.
6.6 Legal and Regulatory Compliance
Personal information may be processed where reasonably necessary to:
- comply with applicable laws;
- satisfy regulatory requirements;
- respond to lawful requests from public authorities;
- establish, exercise or defend legal claims;
- enforce contractual rights;
- resolve disputes.
6.7 Business Operations
Personal information may also be processed where reasonably necessary for legitimate business purposes, including:
- internal administration;
- auditing;
- quality assurance;
- business continuity;
- risk management;
- strategic planning;
- corporate governance.
Such processing is undertaken only where appropriate safeguards are in place and where required by applicable law.
Where the General Data Protection Regulation ("GDPR") or other applicable data protection laws apply, Grovcap processes personal information only where a valid legal basis exists.
Depending on the nature of the processing activity, Grovcap may rely on one or more of the following legal bases.
7.1 Consent
Grovcap may process personal information where you have provided your consent.
Examples include:
- subscribing to newsletters;
- participating in Investor Pulse research where consent is required;
- participating in surveys or questionnaires;
- consenting to non-essential cookies where applicable;
- receiving marketing communications.
Where processing is based on consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.
7.2 Performance of a Contract
Grovcap may process personal information where processing is necessary to provide the Services requested by you or to perform obligations arising under an agreement with you.
Examples include:
- creating and administering user accounts;
- authenticating users;
- delivering educational content;
- maintaining account preferences;
- responding to customer support requests;
- providing requested Services.
7.3 Legitimate Interests
Grovcap may process personal information where such processing is necessary for its legitimate interests or those of a third party, provided that those interests are not overridden by your interests, fundamental rights or freedoms.
Examples include:
- improving the Services;
- maintaining platform security;
- detecting and preventing fraud;
- preventing misuse of the Services;
- maintaining system integrity;
- conducting internal analytics;
- measuring educational effectiveness;
- producing aggregated statistical research;
- developing new products and services;
- improving user experience;
- business planning;
- quality assurance;
- corporate governance.
Where processing relies upon legitimate interests, Grovcap considers the nature of the processing, the reasonable expectations of users and the impact on individual privacy before undertaking such processing.
7.4 Compliance with Legal Obligations
Grovcap may process personal information where necessary to comply with applicable laws, regulations, regulatory requirements, judicial proceedings or lawful requests from competent authorities.
Examples include:
- responding to court orders;
- responding to lawful regulatory requests;
- complying with tax, accounting or corporate obligations;
- maintaining legally required records;
- establishing, exercising or defending legal claims.
7.5 Protection of Vital Interests
In exceptional circumstances, Grovcap may process personal information where necessary to protect the vital interests of an individual or another natural person.
7.6 Processing for Statistical and Research Purposes
Where permitted by applicable law, Grovcap may process personal information for statistical, educational and research purposes using appropriate safeguards designed to protect the rights and freedoms of individuals.
Where reasonably practicable, research information is processed in pseudonymised, aggregated or otherwise privacy-enhancing forms.
Institutional reports generated by Grovcap are intended to describe aggregate patterns of investor behaviour and are not designed to identify or evaluate individual participants.
Processing Summary
| Processing Activity | Primary Legal Basis |
|---|---|
| Providing the Services | Performance of a Contract |
| Account Administration | Performance of a Contract |
| Customer Support | Performance of a Contract / Legitimate Interests |
| Investor Pulse Research | Consent and/or Legitimate Interests (where permitted by law) |
| Educational Analytics | Legitimate Interests |
| Statistical Research | Legitimate Interests and/or Scientific or Statistical Research Provisions under Applicable Law |
| Fraud Prevention | Legitimate Interests |
| Information Security | Legitimate Interests |
| Regulatory Compliance | Legal Obligation |
| Newsletter Communications | Consent |
| Cookie Preferences | Consent (where required) |
| Business Administration | Legitimate Interests |
| Legal Claims | Legal Obligation and Legitimate Interests |
No Incompatible Processing
Grovcap will not process personal information for purposes that are incompatible with the purposes for which it was originally collected unless:
- you provide additional consent;
- applicable law permits such processing; or
- another lawful basis applies.
Where required by applicable law, Grovcap will provide additional notice before undertaking materially different processing activities.
Data Minimisation
Grovcap seeks to process only the personal information that is reasonably necessary for the purposes described in this Privacy Policy.
Where reasonably practicable, information used for statistical reporting, educational analysis or institutional research is processed in a form that reduces the ability to identify individual participants.
Grovcap may disclose personal information only where permitted or required by applicable law and only to the extent reasonably necessary for the purposes described in this Privacy Policy.
Grovcap does not sell personal information to third parties.
Nothing in this Privacy Policy restricts Grovcap from using or disclosing information that has been aggregated or anonymised in accordance with applicable law.
8.1 Service Providers
Grovcap may disclose personal information to carefully selected third-party service providers that perform services on Grovcap's behalf.
Such services may include:
- cloud hosting;
- infrastructure services;
- authentication;
- database management;
- website hosting;
- analytics;
- customer support;
- email delivery;
- communications;
- monitoring;
- cybersecurity;
- backup and disaster recovery;
- fraud detection;
- software development;
- operational support.
Service providers process personal information only:
- under contractual obligations;
- for the purposes instructed by Grovcap;
- subject to appropriate confidentiality obligations;
- subject to appropriate technical and organisational safeguards.
8.2 Professional Advisers
Grovcap may disclose personal information where reasonably necessary to:
- legal advisers;
- auditors;
- accountants;
- insurers;
- compliance advisers;
- consultants.
Such disclosures are limited to information reasonably necessary for the relevant professional engagement.
8.3 Regulatory Authorities and Law Enforcement
Grovcap may disclose personal information where required or permitted by applicable law, including where reasonably necessary to:
- comply with legal obligations;
- respond to lawful requests;
- cooperate with regulators;
- comply with judicial proceedings;
- comply with court orders;
- respond to law enforcement authorities;
- protect the rights, property or safety of Grovcap, users or others;
- investigate fraud or unlawful activity.
Nothing in this Privacy Policy requires Grovcap to notify users where applicable law prohibits such notification.
8.4 Corporate Transactions
Personal information may be disclosed in connection with:
- mergers;
- acquisitions;
- investments;
- financing transactions;
- restructurings;
- reorganisations;
- asset sales;
- transfers of business operations;
- insolvency proceedings.
Where appropriate, such disclosures will remain subject to confidentiality obligations and applicable legal requirements.
8.5 Research and Statistical Reporting
Grovcap conducts educational and behavioural research.
Institutional reports generated from Investor Pulse or other research initiatives contain aggregated statistical information only.
Grovcap does not disclose personally identifiable research responses to institutional subscribers.
Aggregated statistical reports may include, for example:
- investor preferences;
- investment intentions;
- ETF interests;
- educational outcomes;
- market expectations;
- behavioural trends.
Such reports are intended to describe groups of participants and should not be interpreted as identifying individual participants.
8.6 With Your Consent
Grovcap may disclose personal information where you have expressly authorised or requested such disclosure.
8.7 Business Protection
Grovcap may disclose personal information where reasonably necessary to:
- establish, exercise or defend legal claims;
- protect Grovcap's legal rights;
- enforce agreements;
- investigate suspected misconduct;
- prevent fraud;
- maintain the security and integrity of the Services.
The Services may be operated using infrastructure located in multiple jurisdictions.
Accordingly, personal information may be transferred to, stored in or otherwise processed in countries outside your country of residence, including countries that may not provide the same level of data protection as your home jurisdiction.
Where personal information is transferred outside the European Economic Area ("EEA"), the United Kingdom or other jurisdictions requiring appropriate safeguards, Grovcap will implement one or more lawful transfer mechanisms where required by applicable law.
These safeguards may include:
- adequacy decisions adopted by the European Commission;
- the European Commission's Standard Contractual Clauses ("SCCs");
- approved certification mechanisms;
- other safeguards recognised under applicable law.
Where required by law, individuals may request additional information regarding the applicable transfer safeguards by contacting:
office@grovcap.com
Grovcap retains personal information only for as long as reasonably necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.
Retention periods are determined by considering factors including:
- the nature of the information;
- the purposes for which it is processed;
- applicable legal obligations;
- contractual obligations;
- regulatory requirements;
- limitation periods;
- operational requirements;
- security considerations.
Depending on the category of information, personal information may be retained:
- for the duration of the relevant relationship;
- until an account is closed;
- until consent is withdrawn, where processing is based on consent;
- for the period necessary to comply with legal obligations;
- for the establishment, exercise or defence of legal claims.
Aggregated statistical information that no longer identifies individuals may be retained for research, historical, educational and analytical purposes for longer periods, where permitted by applicable law.
Where personal information is no longer required, Grovcap will take reasonable steps to securely delete, anonymise or otherwise dispose of such information in accordance with applicable law and internal retention practices.
Grovcap maintains administrative, technical and organizational measures designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access.
Such measures are designed having regard to the nature, scope, context and purposes of processing, the risks presented by the processing, and applicable legal requirements.
Security measures may include, where appropriate:
- access controls;
- authentication mechanisms;
- encryption of data in transit;
- network security controls;
- system monitoring;
- logging and audit mechanisms;
- secure software development practices;
- vulnerability management;
- backup and recovery procedures;
- incident response processes.
Despite these measures, no method of transmitting information over the Internet or storing electronic information can be guaranteed to be completely secure.
Accordingly, Grovcap cannot guarantee the absolute security of personal information and disclaims liability to the fullest extent permitted by applicable law for unauthorised access or disclosure resulting from circumstances beyond its reasonable control.
Users are responsible for maintaining the confidentiality of their authentication credentials and for notifying Grovcap promptly if they believe their account has been compromised.
Subject to applicable law, you may have one or more of the following rights regarding your personal information.
These rights may include:
- the right to request access to personal information;
- the right to request correction of inaccurate or incomplete information;
- the right to request deletion of personal information;
- the right to request restriction of processing;
- the right to object to certain processing activities;
- the right to withdraw consent where processing is based on consent;
- the right to request portability of certain personal information;
- the right not to be subject to decisions based solely on automated processing where such decisions produce legal or similarly significant effects.
The availability of these rights depends upon the applicable jurisdiction and the specific circumstances of the processing.
Grovcap may request information necessary to verify the identity of individuals exercising their rights before responding to such requests.
Where permitted by applicable law, Grovcap may decline requests that are manifestly unfounded, excessive, repetitive or otherwise not required to be fulfilled under applicable law.
Individuals also have the right to lodge a complaint with the competent supervisory authority responsible for data protection in their jurisdiction.
Grovcap does not make decisions based solely on automated processing that produce legal effects or similarly significant effects concerning individuals.
Information collected through the Services may be used to generate aggregated statistical analyses, educational insights and research outputs. Such processing is not intended to evaluate individual users or produce individual investment recommendations.
The Services are intended for adults interested in investing and financial education.
Grovcap does not knowingly collect personal information from children where prohibited by applicable law.
If Grovcap becomes aware that personal information has been collected from a child in circumstances where such collection is not permitted, Grovcap will take reasonable steps to delete such information as required by applicable law.
Parents or legal guardians who believe that a child has provided personal information to Grovcap may contact:
office@grovcap.com
Grovcap may amend or update this Privacy Policy from time to time.
Changes may be made to reflect:
- changes to applicable laws;
- regulatory guidance;
- technological developments;
- changes to the Services;
- changes to Grovcap's business operations;
- security improvements;
- operational requirements.
The "Last Updated" date appearing at the beginning of this Privacy Policy indicates when the most recent changes became effective.
Where required by applicable law, Grovcap will provide additional notice or obtain consent before material changes become effective.
Continued use of the Services following the effective date of an updated Privacy Policy constitutes acknowledgement of the revised Privacy Policy to the extent permitted by applicable law.
Questions regarding this Privacy Policy or Grovcap's privacy practices may be directed to:
Grovcap will use reasonable efforts to respond to privacy-related enquiries within the timeframes required by applicable law.
The Services are provided for educational, informational and research purposes only.
Nothing contained within the Services, including but not limited to:
- the ETF Masterclass;
- Investor Pulse;
- Market Signals;
- Grovcap Insights;
- research reports;
- educational materials;
- statistical analyses;
- newsletters; or
- other content,
constitutes investment advice, financial advice, legal advice, tax advice, accounting advice or any recommendation to purchase, sell or hold any security, financial instrument or investment product.
Research reports and aggregated statistical information reflect observations regarding groups of participants and should not be interpreted as forecasts, guarantees of future performance or recommendations for any investment decision.
Users remain solely responsible for evaluating the suitability of any investment, obtaining independent professional advice where appropriate, and making their own investment decisions.
To the maximum extent permitted by applicable law, Grovcap disclaims responsibility for investment decisions made in reliance upon the Services.
In operating the Services, Grovcap seeks to apply the following principles:
- lawfulness;
- fairness and transparency;
- purpose limitation;
- data minimisation;
- accuracy;
- storage limitation;
- integrity and confidentiality;
- accountability.
Nothing in this section creates contractual rights beyond those provided under applicable law.