InvestEngine Customer Survey Privacy Notice
Effective Date: 26/01/2025
Controller: InvestEngine (registered with the ICO and authorised and regulated by the Financial Conduct Authority)
1. Purpose and Scope of this Notice
This notice specifically covers the collection and processing of personal data provided through the "Customer Profile Survey" (the "Survey"). This Survey is designed to validate and refine our target customer profile to ensure our product development, marketing, and communications are relevant.
This notice supplements our main Privacy Policy and applies specifically to data collected via the Survey.
2. Data We Collect and Use (The "Survey Data")
We collect the following data points, which will be treated as personal data when linked to your customer ID:
- Financial & Demographic Data: Age, Annual Salary (banding), Household Annual Income (banding), Investment Value (banding).
- Financial Context: Mortgage status, Mortgage/Income ratio, Investment experience, Platforms used.
- Lifestyle & Opinion: Children status, Financial well-being description.
3. Lawful Basis for Processing
We process your Survey Data based on the following lawful bases:
| Processing Activity | Lawful Basis | Justification |
|---|---|---|
| Anonymous Aggregated Research | Legitimate Interest | Improving our services, content strategy, and target market understanding. This is a reasonable expectation for a customer of a financial services firm. |
| Profiling & Targeted Cross-Selling | Consent | Due to the sensitive nature of the financial data and the high-risk activity of linking it to your ID for personalized commercial offers, we require your explicit, separate consent to proceed. |
4. Consequences of Profiling (How we use the data)
If you grant consent, your Survey Data will be linked to your existing customer account to form a Customer Profile. This profile will be used solely to:
- Customise Communications: Send you targeted content, newsletters, and educational resources we believe are most relevant to your stated financial goals.
- Targeted Cross-Selling: Select and present relevant InvestEngine products or services (e.g., ISA, SIPP, General Investment Account) that align with your confirmed financial capacity and experience level.
5. Data Subject Rights
You have the right to withdraw your consent for Activity 2 (Profiling and Targeted Cross-Selling) at any time. This can be done by unsubscribing from targeted emails or by emailing our Support Team at support@investengine.com. Withdrawing consent does not affect the lawfulness of processing before the withdrawal.