Updated May 2018

Your privacy is very important to us. Moxi Wealth (“we” or “us” or “our site”) is committed to protecting and respecting your privacy. This policy explains the types of personal information we may collect about you when you interact with us. It also explains how we handle this information. Please read to understand our practices and how they affect you as you use our features and services.

If you have any questions or concerns regarding this policy, you should email hello@moxiwealth.com.

1. What personal information do we collect about you?

Moxi Wealth collects information about our users so that we can provide a more interesting and useful experience. We ask for your name and email address if you sign-up for personalised services; including the Money Tips email, the My Money tool results and the Ask MOXI notification email. 

We sometimes conduct surveys, although you do not have to respond to them.

We collect IP addresses to understand how people use our site so that we can improve our site’s user experience.

2. How do we use your personal information?

Here we explain how we collect and use your personal information.

2.1 Money Tips email

We collect your name and email address when you sign-up to receive MOXI’s Money Tips email. This is usually sent twice a month and on occasions we may send a special edition if we have something important to share with you. 

2.2 My Money tool 

We collect your name and email address when you request to have your results emailed to you. We use this to send your results by email. 

2.3 Ask MOXI email 

We collect your name and email address when you ask a question using the Ask MOXI form. We use this to send you a notification by email that your question has been answered and include a link to the answer’s webpage. 

2.4 Internal reporting, insight and analysis

We may also use the personal information referred to in this Section 1 to generate anonymised data on an aggregated basis for the purpose of internal reporting, insight and analysis to help us improve the service we provide. Where necessary this exercise may be carried out by a third party. 

2.5 Contacting you

We collect and may use your personal information to: 

2.5.1 Contact you in response to communications you have directed at us. 

2.5.2 Invite you to take part in surveys carried out by us or other organisations on our behalf. Collected surveys will only be used to improve our site. You do not have to take part in the survey. 

If you're providing us with another person's personal information you should first ask them to read this Privacy Policy and our Terms and Conditions. By giving us personal information about another person you are confirming that they have given you consent to provide the personal information to us and that they understand how their details will be used.

We will periodically review your personal information to ensure that we do not keep it for longer than is permitted by law (see section 9 below).

3. Why do we process your personal information 

We will only collect and use your personal information (as described in Sections 1 and 2) in accordance with data protection laws. Our grounds for processing your personal information are as follows:

Consent – Where necessary we will only collect and process your personal information if you have consented for us to do so. For example, when you sign-up to the Money Tips email, we will use your personal information to provide the services detailed at section 2.1.

Legitimate Interests – We may use and process some of your personal information where we have sensible and legitimate business grounds for doing so. Under European privacy laws there is a concept of "legitimate interests" as a justification for processing your personal information. Our legitimate interests for processing your personal information are:

o to enable you to access and use our site;

o to improve our site. We may use your personal information to undertake demographic segmentation and generate profiling information to help us understand what you might be interested in and for market research. We are always working to make a better Site for you and using your personal information in this way helps us to do this.

You have a right to object to our use of your personal information for these legitimate interests, including a right to object to profiling by us (see section 4 below).

4. Your information rights and responsibilities

4.1.  Right to request a copy of the personal information we hold on you, if you request it in writing. 

4.2. Right to correct: the right to have your personal information rectified if it is inaccurate or incomplete;

4.3. Right to erase: the right to request that we delete or remove your personal information from our systems;

4.4. Right to restrict our use of your information: the right to 'block' us from using your personal information or limit the way in which we can use it;

4.5. Right to data portability: the right to request that we move, copy or transfer your personal information;

4.6. Right to object: the right to object to our use of your personal information including where we use it for our legitimate interests, or where we use your personal information to carry out profiling to inform our market research and user demographics. If you raise an objection we will stop processing your personal information unless very exceptional circumstances apply, in which case we will let you know why we're continuing to process your personal information.

We will use reasonable efforts consistent with our legal duty to provide you with your rights in accordance with data protection legislation.

To make enquiries, exercise any of your rights set out in this Privacy Policy and/or make a complaint please email hello@moxiwealth.com. 

If you're not satisfied with the way any complaint you make in relation to your personal information is handled by us then you may be able to refer your complaint to the relevant data protection regulator. In the UK, this is the Information Commissioner's Office.

5. How can you change your permissions?

Your privacy is of huge importance to us. All emails or other forms of communication directly from us to you will include clear instructions on how to unsubscribe. Plus, if you don't want to be contacted by us anymore you can email hello@moxiwealth.com 

6. How do we use “IP addresses”, “cookies”, “web beacons” and “other technologies”?

6.1. IP Addresses

Your Web browser or email application automatically provides your Internet Protocol address (“IP address”) to other computers with which you communicate over the internet, so that they know where to send you information.

We receive an IP address each time you view one of our Web pages, because the browser automatically reports it to us. We also may store the IP address when you register with Moxi Wealth.

We may use IP addresses for various purposes, including:

·       Diagnosing service or technology problems.

·       Assessing and maintaining system security.

·       Displaying the most appropriate advertising or content.

·       Studying how people use our site and how we can improve it.

·       Reporting to advertisers about aggregate, but not individual, information derived from IP addresses.

6.2. Cookies

Data collection devices, such as “cookies,” are used to store, and sometimes track, information about you. These cookies help provide personalised services and promote trust and safety. We also may use cookies to measure your visiting patterns in aggregate. We use this research to understand how our users’ habits are similar or different from one another so that we can make each new experience on Moxi Wealth a better one. We may also use this information to better personalise the content, banners, and promotions that you and other Users will see on our Site. You are always free to decline our cookies if you wish and if your browser permits, however please know that doing so may interfere with the proper functioning of certain parts of our Site.

6.3. Web Beacons

We may use web beacons (invisible images often referred to as pixel tags or clear GIFs) on our site in order to recognise users, assess traffic patterns, identify preferred content and measure site engagement. We also include web beacons in our email messages in order to count how many email messages have been opened.

We use reputable third parties to collect information, through the use of web beacons, browser cookies and other tracking technologies. We may collect various data provided by your browser while you are on our site via web beacons. This data is collected in the aggregate, but may include or be associated with other non-personal information or personal information that users have voluntarily submitted.

6.4. Other Technologies

Other Technologies are technologies that store information in your browser or device utilising local shared objects or local storage, such as flash cookies, HTML cookies, and other web application software methods. These technologies can operate across all of your browsers, and in some instances may not be fully managed by your browser and may require management directly through your installed applications or device.

6.5. Our use of cookies, web beacons, and similar technologies

We offer certain site features, services, applications, and tools that are available only through the use of these technologies. You are always free to block, delete, or disable these technologies if your browser, installed application, or device so permits. However, if you decline cookies or other similar technologies, you may not be able to take advantage of certain site features, services, applications, or tools. For more information on how you can block, delete, or disable these technologies, please review your browser or device settings.

Any personal information that we collect and store through use of these technologies is first obtained through notice and consent. We obtain your consent by providing you with transparent notice of use of the technologies and providing you with the opportunity to make a choice to disable these technologies as set forth above.

If you would like to opt-out of all other types of technologies we employ on our site, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

6.6. Authorised third-party service providers

We use the third-party emailing platform MailChimp to send emails; if you have signed-up to one of our email services, your name and email address may be stored there. We may also in the future work with third-party companies such as marketing platforms to place third-party cookies, web beacons, or similar technologies for storing information on our site or in our services, applications, and tools with our permission. These service providers help us to provide you with a better, faster, and safer experience.

We carefully select providers who have a secure platform and follow EU data protection laws. 

7. Disclosure of your personal information to third parties

Moxi Wealth will not disclose any personally identifiable information about individual users, except as described in this Privacy Policy. We do not give, lend, or sell individual information to our advertisers, although we do provide aggregate information. For example, we might tell an advertiser that there are 20,000 registered email subscribers in London, but we will not tell them that you are one of them, nor will we give them your email address.

In the event of a sale or other transfer of assets or of any portion of our business, we reserve the right to transfer any and all information that we collect from visitors, or that we otherwise collect concerning or in connection with the Site, to a third party. In the event Moxi Wealth enters a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your personally identifiable information may be among the assets transferred.

We may disclose account information where we have reason to believe that disclosing the information is necessary to identify, contact, or bring legal action against someone who may be violating the law or may be causing injury to or interference with (either intentionally or unintentionally) Moxi Wealth’s rights or property, other Site users, or anyone else that could be harmed by such activities. Moxi Wealth may disclose or access account information when we believe in good faith that the law requires it and for administrative and other purposes that we deem necessary to maintain, service, and improve our services.

8. Keeping your personal information secure

8.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

8.2 We will store all the personal information you provide in our password-protected database. Our servers are protected by a firewall. In addition, all pages on the website relating to your personal information will be protected using SSL technology, and account details (including passwords) will be stored in our database in an encrypted form.

8.3 Of course, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

8.4 You are responsible for keeping your password and user details confidential. We will not ask you for your password (save when you log on to the website).

8.5 Some user content will be published on the website such as testimonials.

8.6 Should you wish to keep your identity anonymous when you post on the website, this will be your sole responsibility.

9. How long do we keep your personal information?

Unless a longer retention period is required or permitted by law, we will only hold your personal information on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request it is deleted. If, having registered for any of our services, you do not use them for a reasonable time (which may vary depending on the service(s) you've registered for) we may contact you to ensure you're still happy to receive communications from us. Even if we delete your personal information it may persist on back-up or archival media for legal or regulatory purposes.

10. Do we respect children’s privacy?

Our site is not directed at users under the age of 18. We will not knowingly collect or use personal information from anyone under 18.

Changes to the Privacy Policy

We may change this Privacy Policy at any time, but we will give notice of any material changes (or any notices that we are required to give you) on our website and/or in email messages.

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