Privacy Policy

LAST UPDATED: 24 OCTOBER 2024

1. Overview

Haruko Limited and its affiliates (collectively, “Haruko”, “we”, “us” and “our”) provide digital asset technology services that include portfolio management and risk management tools.

We care about your personal privacy and take it seriously. This Privacy Policy describes how we collect, use and share the personal information we collect from you or about you when you use our website and other services (“Services”). It also sets out your privacy rights. We appreciate that information privacy is an ongoing responsibility and therefore we will occasionally update this Privacy Policy as we undertake new personal data practices and adopt new policies.

If your details are processed by us in the context of an agreement with you or the organisation with which you are employed or affiliated, then the relevant data controller is the Haruko entity identified in such agreement. If not, the data controller is Haruko Limited when you use our Services.

For more information on how to contact us, please see Section 10 below.

This Privacy Policy should be read alongside, and in addition to, our Terms and Conditions.

2. What information we collect about you

We collect and retain certain personal data of employment applicants, business contacts (including personnel of clients, prospects and partners) and other users accessing our Services as described below.

2.1 Information you provide to us directly

2.1.1 Clients

When your organisation becomes a Haruko client, we collect certain information such as (non-exhaustive): (i) your organisation’s name; (ii) your organisation’s address; (iii) potential users’ names and contact information; (iv) certain organisation-authorised representatives’ names and contact information; (v) billing information; and (v) other information that may be relevant to serving your needs as a client. By “contact information”, we mean your work email address, work address and a work phone number. Similarly, we may process emails you send us that contain such information in your signature. Your organisation and other users may occasionally provide us with additional information or update or remove the information that we have on file.

2.1.2 Other users of our Services

When you interact with our website or engage with us for reasons such as (non-exhaustive) prospective employment, communicating with us about our Services, receiving product and company news or partnering with us, we may collect certain information such as (non-exhaustive): (i) your name; (ii) your email address; (iii) phone number; (iv) mailing address. This may include both personal and work information, depending on how you choose to interact with us.

2.2 Information collected automatically

We may collect personal information automatically when you use our Services as outlined below.

When visiting our website or interacting with our communications, we may automatically collect certain information such as (non-exhaustive) (i) your Internet protocol (IP) address; (ii) cookie identifiers; (iii) website pages you visit; (iv) information about the links you click on; (v) the frequency and duration of your interaction with our website and/or communications; and (vi) other information about how you use our website.

We may also collect information about you that other people provide when they use our Services, such as when including you in email communication with us.

For more information about the cookies that we use, please read our Cookie Policy.

3. How we use the information we collect about you

We collect and process information about you only where such processing is lawful under the UK Data Protection Act 2018 (“UK GDPR”). This means that we collect and process your information only where:

• You give us consent to do so for a specific purpose.
• The processing satisfies a legitimate interest as defined in the UK GDPR to improve our Services, to market and promote our products and Services or to protect our legal rights and interests.
• We need to process your personal data to comply with a legal obligation.
• The processing of your data is necessary to enable us to take certain steps at your request prior to entering a contract or for the performance of a contract with you.

More specifically, we may use your personal data for the below purposes in line with the lawful bases identified above.

3.1 To provide our Services

We use your personal data to provide our Services to you, such as authenticating your login credentials and facilitating client support.

3.2 To improve our Services

We use your personal data to resolve issues you encounter, respond to requests for assistance, analyse log files to enhance your user experience and improve our Services.

3.3 To communicate with you about our Services

We use your personal data to send communications to you via email or your dedicated client support channel, including responding to comments and questions, sending you technical notes and updates. Should you object to us processing your data, we might not be able to fulfil your requests or inform you about changes to our Services.

3.4 To market, promote and drive engagement with the Services

We use your personal information to send communications to you that may be of interest as an employee of an organisation with whom we have or look to develop a business relationship, including by email.

These are aimed at driving engagement and maximising the value of our Services for our clients, prospective clients and business partners and include information about new product features, news and events we attend or sponsor which we think may be of interest.

3.5 To process job applications

We use your personal information and additional information you provide us for prospective employment processes. Should you object to us processing your data, we might not be able to process your application.

3.6 To protect our legitimate business interests and legal rights

Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory and audit functions.

4. How we share the information we collect about you

We are not in the business of selling information about you. We will not sell your information to advertisers or other third parties for commercial purposes.

We share information we collect about you with our staff and, in some cases, with certain subcontractors to the extent necessary to provide you with our Services.

When we send you emails, we may track whether you open them to understand and learn how to improve the user experience.

Where international transfers are required to provide you with our Services, we process your data in accordance with standard contractual clauses on data protection to safeguard the transfer.

5. How we secure the information we collect about you

We will use technical and organisational measures to safeguard your personal data, for example, in the case of us providing you with our Services:

• Access to your Haruko account is controlled by a password and a username that is unique to you.
• Your data is stored on single-tenant, secure servers in SOC 2-compliant data centres.

Technical and organisational measures include measures to deal with any suspected data breach.

If you suspect any misuse or loss or unauthorised access to your data, please let us know immediately by contacting us.

6. How long we keep the information we collect about you

Unless a longer retention period is required or permitted by law, we will only hold your personal data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the personal data be deleted.

Even if we delete your personal data, it may persist on a backup or archival media for legal, tax or regulatory purposes.

7. How you can access and control your information

You have the following rights in relation to your personal data:

• Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive”. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
• Right to correct – the right to have your personal data rectified if it is inaccurate or incomplete.
• Right to erase – the right to request that we delete or remove your personal data from our systems.
• Right to restrict our use of your personal data – the right to “block” us from using your personal data or limit the way in which we can use it.
• Right to data portability – the right to request that we move, copy or transfer your personal data.
• Right to object – the right to object to our use of your personal data, including where we use it for our legitimate interests.

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), please contact us.

If you are not satisfied with the way a complaint you make in relation to your personal data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal changes during the period for which we hold it.

8. Managing cookies

This website may place and access certain cookies on your computer. Haruko uses cookies to improve your experience of using the website and to improve our range of services. Haruko has carefully chosen these cookies and has taken steps to ensure that your privacy is protected and respected at all times.

All cookies used by this website are used in accordance with current UK and EU Cookie Law.

You can find more information about the cookies that we use in our Cookie Policy.

9. Changes to this Privacy Policy

We reserve the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the website and you are deemed to have accepted the terms of the privacy policy on your first use of the website following the alterations.

10. Contact details

The website is owned by Haruko Limited, incorporated in England and Wales with registered company number 13383328, whose registered office is at 20 Aldermanbury, London EC2V 7HY, United Kingdom.

If you have any questions about this policy or the personal information we collect about you, please email us at dpo “at” haruko “dot” io.