Privacy policy & GDPR Notice.

Halvestor Limited – Privacy Policy

Effective date: 27 April 2025
Last updated: 27 April 2025

1. Introduction

Halvestor Limited (“Halvestor”, “we”, “our”, “us”) operates the Halvestor paper-trading mobile application and the website www.halvestor.com (together, “the Service”).
This Privacy Policy explains:

  • what personal data we collect,

  • how we collect and use it,

  • the legal bases we rely on,

  • how we store and protect it, and

  • the data-protection rights you have as a user.

2. Organisation details

Item

Detail

Controller

Halvestor Limited (Company No. 15381418)

Registered address

Flat 36, Clay Alto, Exhibition Way, Wembley, London HA9 0GS

Contact e-mail

prosper@halvestor.com


3. What data do we collect?

Data category

Specific data

When collected

Account data

Name, e-mail address, encrypted password

When you create an account or join our wait-list

Technical / usage data

IP address, device model & OS, in-app actions, crash logs

Automatically through the app

Marketing preference

Opt-in/opt-out status

When you toggle marketing consent

We do not collect payment data, phone numbers, identity documents, or real-time geolocation in the MVP.

4. How do we collect your data?

  1. Directly from you – when you fill in the sign-up form or e-mail us.

  2. Automatically – via the app’s analytic events (standard device & usage logs).

  3. Cookies and similar technologies – cookies on our public website (see Section 9).

5. How will we use your data?

Purpose

Details

Legal basis (UK GDPR)

Provide and secure the Service

Account creation, login, password management, detect misuse

Contract / Consent Art 6 (1)(a)(b)

Improve and debug

Monitor performance, analyse aggregated usage patterns

Legitimate interest Art 6 (1)(f)

Wait-list & product updates

Send feature announcements, early-access offers (only if you opted in)

Consent Art 6 (1)(a)

Investor traction statistics

Report anonymised totals (e.g. number of sign-ups)

Legitimate interest Art 6 (1)(f)

We never sell personal data to third parties.

6. How do we store your data?

  • Data is held on secure cloud servers located in the UK or EEA.

  • Transmission is protected with TLS 1.2+ encryption; passwords are hashed with bcrypt.

  • Access is role-based and logged.

Retention: We keep personal data while your account is active and for 24 months after your last sign-in, unless you request deletion sooner or the law requires longer retention.

7. Marketing

If you agree to receive marketing, Halvestor may e-mail you product news or promotions. You can unsubscribe at any time by:

  1. Clicking “unsubscribe” in any marketing e-mail, or

  2. Changing the marketing toggle in the app settings, or

  3. E-mailing prosper@halvestor.com.

Marketing consent is optional and not a condition of using the Service.

8. Your data-protection rights

Under UK GDPR you have:

  1. Right of access – obtain a copy of your personal data.

  2. Right to rectification – request correction of inaccurate data.

  3. Right to erasure – “right to be forgotten.”

  4. Right to restrict processing – request we limit use of your data.

  5. Right to object – object to processing based on legitimate interest.

  6. Right to data portability – receive your data in a structured format.

  7. Right to withdraw consent – at any time, for processing based on consent.

To exercise any right, e-mail prosper@halvestor.com. We respond within 30 days.

9. Cookies

Our public website uses:

Cookie type

Purpose

Essential

Site security and basic functions

Analytics (basic)

Count visits and page views (aggregate)

When you first visit, you can accept or reject non-essential cookies via the banner. In-app, we use minimal analytics SDKs; no advertising identifiers are collected in the MVP.

10. Privacy policies of other websites

The Service may contain links to third-party sites (e.g., news sources, charities). Our Privacy Policy applies only to Halvestor. If you click a link to another site, read their privacy policy.

11. Changes to our Privacy Policy

We review this policy periodically and post updates on this page. For material changes, we will notify you by e-mail or prominent in-app notice at least 7 days before the new version takes effect.

12. How to contact us

Questions, requests, or complaints: prosper@halvestor.com
Postal: Halvestor Limited, Flat 36, Clay Alto, Exhibition Way, Wembley, London HA9 0GS.

13. How to complain

You may complain to the supervisory authority:

Information Commissioner’s Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
www.ico.org.uk / 0303 123 1113

(End of Privacy Policy – version 1.0)









GDPR FAIR-PROCESSING NOTICE (Short Form)

Controller: Halvestor Limited, Flat 36, Clay Alto, Exhibition Way, Wembley, London HA9 0GS
Purpose: Operate a free stock-market simulation app; send optional product news.
Data: Name, e-mail, password hash, IP/device logs.
Lawful Bases: Consent & legitimate interest.
Recipients: Cloud-hosting and analytics providers under contract.
Transfers: Data may be processed outside the UK under adequacy regulations or standard contractual clauses.
Retention: 24 months after last activity or upon deletion request.
Rights: Access, rectification, erasure, restriction, objection, portability, withdraw consent.
Contact: privacy@halvestor.com.
Supervisory Authority: ICO (ico.org.uk).