Last Updated: September 2022.
This privacy policy (the “Policy”) explains how Storelli & Pepe Stocks
Investments (hereinafter referred as S&PStocks, SPStocks, S&PS , SPS or,
simply “us”) collects, uses and discloses personal information through
its, mobile applications, websites and any other online products and/or
services that may link to this Policy, including any of the products and
services detailed in the following paragraph (collectively, the
“Services”) or when you otherwise interact with us.
The Services include providing: (i) the S&PStocks platform for Stocks
Analysis (ii) training investments (playing money trading platform)
(iii) stocks racing tools, including championships and prizes (iv)
access to indices created by S&PStocks for information purposes and
other Services available at S&PStocks Platform.
We encourage you to read the Policy carefully as it forms part of the
relevant S&PStocks Entity’s terms and conditions and each single legal
document officially issued by S&PStocks, as the case may be.
If you accept or agree to this Policy on behalf of a company or other
legal entity, you represent and warrant that you have the authority to
bind that company or other legal entity to the privacy Policy and, in
such event, “you” and “your” will refer and apply to that company or
other legal entity.
For the purposes of applicable state and/or international data protection laws, S&PStocks is the “controller” of personal information collected through www.spstocks.com (http://www.spstocks.com), other S&PStocks websites, widgets, mobile applications and other platforms (together the “Site”), and is the company to contact if you have questions about the use of your personal information (see the “Contact Us” section below). The Policy also applies to personal data about each authorized representative of a client and about other persons or entities where this personal data is collected in the course of providing the Services (such as directors of corporate clients).
Information You Provide to Us
We collect information you provide directly to us. For example, we
collect information when you create an S&PStocks Account, participate in
any interactive features of the Services, fill out a form, participate
in a contest or promotion, make a purchase, communicate with us via
third party social media sites, request customer support, or otherwise
communicate with us.
When You Sign Up or Register for an S&PStocks Account or Services.
If you sign up for an S&PStocks Account or other Services, we will
collect basic information about you including your name, email address
and telephone number. You may provide this information to us directly,
or by signing in to your account/service with a third party, including
without limitation, Facebook or Google (see “Information We Collect from
Other Sources” below). We will use the information that we collect about
you to:
● Create and maintain your S&PStocks Account;
● Allow you to log in to S&PStocks;
● Contact you about your S&PStocks Account and/or our Services (this may
include marketing
emails).
When You Provide Information to Build Your Profile
Once you have created an S&PStocks Account, we will ask you to provide
additional information to allow you to make use of certain functions.
We may ask you to provide a copy of an identification document, such
as a passport, residency permit, visa or national identity card, a
utility bill and such other documents as may be required by us in order
to comply with our regulatory obligations and to verify your identity.
Please note that if you choose to provide additional information about
yourself to complete your “Profile”, then the information we ask for may
include your gender, date of birth, place of birth, addresses, nationality,
national insurance number, social security number (or other government
issued identification number), citizenship and residency status, and other
details or questions as may be required in the Profile creation and the
process may be amended by us from time to time.
We will use the information you provide in your Profile to:
● verify your identity and carry out checks that we are required to conduct
by applicable laws and regulations.
● contact you on matters related to your S&PStocks Account, including to
request any additional information or documentation.
● provide you with notices related to your S&PStocks Account, general
updates, market updates
and other marketing materials, including about the Services offered by
members of S&PStocks.
● tailor the products and services offered through the Site to you,
including without limitation, to perform any suitability or appropriateness
assessments for using our services and/or products Features.
● maintain administrative records relating to our business.
● provide the Services.
You can update your Profile at any time by visiting the “Account” page in
the Settings menu when logged into your S&PStocks Account.
We recommend that you update your Profile regularly, to ensure that the
S&PStocks functions offered to you are appropriate for your current
circumstances. You further agree to update such information upon S&PStocks’
request, if S&PStocks considers the information provided as untrue, incorrect,
incomplete and/or inconsistent with other information provided by you at any
time. You acknowledge that we may rely upon such information and that you are
responsible for any damages or losses which may result from any inaccuracies,
including without limitation, the inappropriateness of our Services to your
Profile. You do not have to complete your Profile and therefore do not have to
provide the information; however, if you choose not to, we will be unable to
offer S&PStocks’ full functionality to you.
When You Contact Us
If you contact us by telephone, email, post or use another function offered by
S&PStocks, such as the chat feature, we will collect any information about the
communication and any additional information that you choose to give us. We
will use this information to review, investigate and respond to any comment
or question that you may raise. Please note that we record and retain all
telephone calls and other communication with us and may use it in our dealings
with you, including any dispute resolution or legal proceedings.
When an S&PStocks User Invites You to Use S&PStocks
Users of S&PStocks can invite their contacts to sign up for an account with us.
We only collect the email addresses of individuals that users choose to invite
to join S&PStocks and S&PStocks only uses the email addresses for sending an
invitation to the individual at the request of the existing S&PStocks user.
Usage and Automatically Collected Information
When you access or use our Services, we automatically collect information about
you (the type of information depends on the Site you are using), including:
● Log Information: We collect log information about your use of the Services,
including the type of browser you use, app version, access times, pages viewed,
your IP address, any other network identifiers, and the page you visited before
navigating to our Services.
● Device Information: We collect information about the computer or mobile device
you use to access our Services, including the hardware model, operating system and
version, unique device identifiers, and mobile network information.
● Activities on the Site: We collect records of activities on the Site, including,
your S&PStocks Account details, the time and amount of any play money training
platform transaction, time, and kind of race you chose to create or participate,
even it is further deleted.
● Location Information: In accordance with your device permissions, we may collect
information about the geo-location of your device.
● Information Collected by Cookies and Other Tracking Technologies: We use different
technologies to collect information, including cookies and web beacons. You can find
out more about S&PStocks’ use of cookies and similar technologies in our Cookie Policy.
Information We Collect from Other Sources
We may collect personal information about you from third party entities when you use
or connect to S&PStocks by or through a third party platform, such as Facebook or a
nother site, you allow us to access and/or collect certain information from your
third party platform profile/account as permitted by the terms of the agreement
and your privacy settings with the third party platform. We will share such
information with the third party platform for their use.
Some of the information we collect from you on installation of the mobile app will
be shared by us with vendors and other service providers who are engaged by, or
working with, us in connection with operating and analyzing the Services we provide to you.
Unsolicited Information
If you provide us with personal information that we have not requested then we will
endeavor to only retain the information that we are entitled or required to hold
because of the products and services we provide. However, if this additional information
is surplus to our requirements but is provided to us in a manner where it is combined
with information that we are either required or entitled to retain then you acknowledge
that this unsolicited information may be held by us in the same manner as the balance of
your personal information.
We use the information we collect to provide, maintain, and improve the Services, such
as to administer, verify and maintain your account, to provide the Services you request
and customize your experience with us. We also use the information we collect to:
● carry out our obligations owed to you;
● comply with our legal obligations;
● monitor/access any content you may post in any platform related to SPStocks, including,
but not limited to, social medias using our name or social medias managed by us;
● administer transactions (payments for our services);
● determine whether a payment method is being abused;
● compile statistical analysis of the pages of our platform and websites;
● monitor and analyze our business;
● investigate and to manage enquiries, disputes and legal proceedings and to comply with
court orders, mandatory dispute resolution determinations and mandatory government
authority or law enforcement orders or directions;
● participate in crime prevention, legal and regulatory compliance and to assist
regulatory, cybercrime, data and information protection agencies and police with
their enquiries and enforcement, even if not compelled to do so;
● develop and to market other products and services; and
● novate, transfer or assign any of the rights or liabilities of the S&PStocks Entity.
We will not share the personal information we hold about you except in the following circumstances:
● between and among the S&PStocks current and future parents, affiliates,
subsidiaries, and other companies under common control and ownership; and
● with professional advisors, vendors, consultants, and other service providers, such as
payment service providers, IT hosting companies or any other strictly necessary to have
access to such information to carry out work on our behalf;
● in connection with, or during negotiations of, any merger, sale of company assets,
financing or acquisition of all or a portion of S&PStocks by another company;
● disclosure in accordance with, or required by, any applicable law or legal process,
including lawful requests by public authorities to meet national security or law
enforcement requirements;
● if we believe your actions are inconsistent with our user agreements or policies, or to
protect the rights, property, and safety of S&PStocks or others; or.
● where we have your consent. For example, if you opt to share, in your account, your
personal information, we will be authorized to share it with a third party for any promotional services.
We may allow others to provide analytics services and serve advertisements about our products
and services on our behalf across the web and in mobile applications. This may involve cookies
and other technologies to collect information about your use of the Services. This information
may be used by S&PStocks to, among other things, analyze and track data, determine the popularity
of certain content, deliver advertising and content targeted to your interests on our Services,
and better understand your online activity in connection with the Services. Please refer to our C
ookie Policy for more information about the cookies involved and the process of consenting or
refusing cookies.
For more information about interest-based ads generally, please visit www.aboutads.info/choices
if you are in the United States and if you are in the EU or the UK, please visit www.youronlinechoices.eu/
You may have certain rights and protections under the law regarding the processing of your personal
data. For example, you may also have the right to object to, or request that we restrict, certain
processing and in some circumstances to obtain a copy of the personal information in machine readable
format. There are limits to such rights where they apply and in certain circumstances we may not be
required or able to meet your request, or we may only meet your request in part.
Legal Basis for Processing: For transparency purposes (where relevant under data protection legislation
applicable to our processing of your personal information) we process your personal data on the following
legal grounds:
▪ Entering into and Performing the Contract with You: If you have an S&PStocks Account or have registered
on the Site or for the Services, our legal basis for processing your personal information is that it is
necessary for the performance of the S&PStocks terms and conditions, terms of business and/or terms of
use, and to provide the requested service to you. With respect to an S&PStocks Account, this includes
facilitating access to our platform, processing payments and executing play-money trades.
▪ For other Justifiable Grounds, including Legal Obligation and Legitimate Interests: We process your
personal information where necessary for S&PStocks to comply with legal and regulatory obligations we
are under, and also where it is necessary for legitimate interests we have in conducting our business
(or the legitimate interests of our partners in complying with their legal obligations), balanced
against the rights of our customers, like you. These include without limitation:
o Learning about your interests and preferences to contact you with information that is relevant to
you and helping us target marketing communications and advertisements for our products and services
so that they are more relevant to you.
o Using your pseudonymized details to show you advertising for our products and services on social
media platforms, such as Facebook or via other third-party advertising that may appear on other
websites you use. The information shared with these platforms is pseudonymized to protect your personal data.
o Analyzing and continually improving the Site and the Services and helping us pilot test versions of
the Site internally to develop new features and ensure the efficient running of S&PStocks’ services.
o Detecting and reducing frauds of any kind;
Data Subject Requests: You may have the right to access personal data we hold about you and to ask
that your personal data be updated, corrected, erased, or transferred. You may also have the right
to object to, or request that we restrict, certain processing. If you would like to exercise any of
these rights, you can log into your account or contact us via this Link. Alternatively, you may also
reach us by email at support@spstocks.com. If you wish to delete or deactivate your account, please
note that we may retain certain information as required by law or for legitimate business purposes.
We may also retain cached or archived copies of information about you for a certain period of time.
Questions or Complaints: If you are interested in exercising any of these rights (or confirming if
they apply to our processing of your personal data), you can contact us at support@spstocks.com.
If you have a concern about our processing of personal data that we are not able to resolve, you
may have the right to lodge a complaint with the relevant data protection supervisory authority
where you reside. As noted above, even where such rights apply, they are subject to limits. This
means that, in certain circumstances, we may not be required or able to meet your request, or we
may only meet your request in part.
You may opt out of receiving promotional emails or text messages from S&PStocks by following the
instructions in those emails or text messages and you may opt-out anytime you want, by notifying
us at support@spstocks.com or simply replying any email or
message with the title (if email) or
body text (if a message) UNSUBSCRIBE.
If you opt out, we may still send you non-promotional emails, such as service messages about
your S&PStocks Account or our ongoing business relationship.
With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
We store the information we collect on you for as long as is necessary for the purpose(s) for which we
originally collected it, or for other legitimate business purposes, including to meet our legal,
regulatory, or other compliance obligations. The period for which we will retain personal information
will vary depending on the purposes that it was collected for, as well as the requirements of any
applicable law or regulation. For example, if you are invited to use S&PStocks by another user, we
will store the personal information about you provided by such other user for a period of six months
in order to send an invitation to you by email.
If you have an S&PStocks Account, we will store your personal information for as long as you maintain
that account, and after you cease holding an account, for as long as we are required to by laws and
regulations that are applicable to us, if any.
We protect your personal information by using data security technology and using tools such as firewalls
and data encryption. We also require that you use a personal username and password every time you access
your account online. As set out in the S&PStocks terms and conditions, you must not share your password
with anyone else. We recommend that you do not re-use a password previously used by you for other
platforms/services.
We restrict access to personal information at our offices so that only officers and/or employees with
a legitimate business purpose can access it.
The Policy will be reviewed and updated from time to time to take account of changes to our operations or practices and, further, to make sure it remains appropriate in light of any changes in law, technology and the business environment. Any personal information held will be governed by our most current Policy. Please refer back to the Policy on a regular basis.
The Site may include links to other websites on the internet. We are not responsible for the content of these
sites or for any other privacy practices on these internet sites. You should read the terms of use and the
privacy statements of any such websites. Our terms of use and our Privacy Policy apply only to information
collected by us in accordance with this Policy.
Contact Us
Should you have any questions regarding the Policy, please contact our customer support at:
support@spstocks.com so we are able to handle your query properly. We may require that you provide
additional information to verify your identity before allowing you to exercise certain rights outlined above