Privacy Policy

1. Introduction

Newcomm Invest ("we", "us", or "our") provides an AI-driven investment analysis platform designed for passive, UK-based investors. We are committed to protecting the privacy and security of the personal information you share with us. This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed.

By using our website or services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this policy, please discontinue use of our website and services.

2. Information We Collect

We may collect and process the following categories of information:

• Identity and contact data: name, email address, phone number, and postal address, typically provided when you submit an enquiry or start an analysis request.
• Account and usage data: information related to your interactions with our platform, including preferences, session activity, and analysis inputs you provide.
• Technical data: IP address, browser type and version, device information, time zone setting, and operating system, collected automatically as you navigate our site.
• Financial context data: general, non-sensitive financial preferences or parameters you choose to submit for the purpose of receiving analysis outputs. We do not require and discourage submission of full account credentials or highly sensitive financial identifiers.
• Communications you send to us, such as correspondence via our contact channels.

3. How We Use Your Information

We use the information we collect for the following purposes:

• To provide, operate, and maintain our analysis platform and related services.
• To respond to enquiries, provide customer support, and communicate updates relevant to your use of our services.
• To improve, personalise, and develop our website, models, and service offerings.
• To detect, investigate, and prevent fraudulent, unauthorised, or unlawful activity.
• To comply with applicable legal, regulatory, and contractual obligations.

4. Legal Basis for Processing

Where applicable data protection law requires a legal basis for processing personal data, we rely on one or more of the following: your consent, the necessity of processing to perform a contract with you, our legitimate interests in operating and improving our services (balanced against your rights), and compliance with a legal obligation to which we are subject.

5. Cookies and Tracking Technologies

Our website may use cookies and similar tracking technologies to enhance your browsing experience, understand usage patterns, and support core site functionality. You can control or disable cookies through your browser settings; however, doing so may affect certain features of our website.

6. Sharing and Disclosure of Information

We do not sell your personal information. We may share information with:

• Service providers and technology partners who assist us in operating our platform, subject to appropriate confidentiality and data protection obligations.
• Professional advisers, including legal and financial consultants, where necessary for our legitimate business purposes.
• Regulatory or governmental authorities, where required to comply with a legal obligation or valid request.
• Any successor entity in the event of a merger, acquisition, or sale of assets, subject to equivalent privacy protections.

7. Data Retention

We retain personal information only for as long as necessary to fulfil the purposes outlined in this policy, including any legal, accounting, or reporting requirements. When retention is no longer necessary, we take reasonable steps to securely delete or anonymise the relevant data.

8. Data Security

We implement appropriate technical and organisational measures designed to protect personal information against unauthorised access, alteration, disclosure, or destruction. However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

9. International Data Transfers

Where personal information is transferred outside of the United Kingdom or the European Economic Area, we take steps to ensure that appropriate safeguards are in place in accordance with applicable data protection legislation.

10. Your Rights

Subject to applicable law, you may have rights to: access the personal information we hold about you; request correction of inaccurate data; request deletion of your data; object to or restrict certain processing activities; request data portability; and withdraw consent where processing is based on consent. To exercise any of these rights, please contact us using the details provided on our Contact page.

11. Third-Party Links

Our website may contain links to third-party websites or services. We are not responsible for the privacy practices or content of such third parties. We encourage you to review the privacy policies of any external sites you visit.

12. Children's Privacy

Our website and services are intended for use by adults and are not directed to individuals under the age of 18. We do not knowingly collect personal information from children.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Any updates will be posted on this page with a revised "Last updated" date. We encourage you to review this policy periodically.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please reach out via the details provided on our Contact page.