Privacy Notice
1. Introduction
1.1 FunderPro Ltd. (hereinafter “the Company“, “We”, “Us“, or “Our“) is a limited liability company incorporated in the Republic of Malta with registration number C104558. The Company acknowledges the importance of protecting your privacy and safeguarding your Personal Data. This commitment arises from the European General Data Protection Regulation (EU 2016/679) (“GDPR“) and the Data Protection Act (Cap. 586 of the Laws of Malta), which implements the GDPR in Malta and is amended from time to time (hereinafter referred to as “the Law“). This Privacy Notice (hereinafter “the Notice“) sets out the purposes and methods for processing your Personal Data by the Company.
2. Scope
2.1 This Notice aims to give you information on how we collect and process your Personal Data through or in conjunction with your use of this website and our services. You are strongly advised to carefully read this Notice, as it is part of the Company’s Terms and Conditions, as applicable, and shows how the Company complies with the provisions of the GDPR and the Law.
2.2 This Notice details the conditions for collecting and processing your Personal Data and ensures compliance with the transparency principle under applicable data protection laws.
2.3 The Notice describes the methods we use to acquire and handle your Personal Data through digital interfaces and software associated with this Privacy Notice.
2.4 The Notice is directed to natural persons who are:
a) current, potential, or past clients of the Company;
b) beneficial owners or authorized representatives/agents of legal entities which are current, potential, or past clients of the Company;
c) authorized representatives/agents of natural persons who are current potential or past clients of the Company.
2.5 Our website, located at https://funderpro.com/ (the “Website“), and any other website owned by the Company, is not intended for children, and we do not knowingly collect data relating to children under the age of 18.
2.6 By accepting this Notice and using our Website, you consent to the data practices described in this Notice and all extensions and addendums to this Notice, such as the usage and management of personal information from its visitors and current, potential, or past clients who are accessing or using the Company’s Website(s) and/or mobile applications. The Notice applies to all Personal Data that the Company has relating to identifiable individuals. The Company is the data controlling entity for the purposes of this Notice, as it determines the purposes and means of the processing.
3. Personal Data
3.1 As per Article 4 of the GDPR, “Personal Data” refers to any information related to an identified or identifiable natural person (“Data Subject“). A “Data Subject” is someone who can be distinguished by reference to an identifier such as a name, an identification number, location data, an online identifier, or other factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of the individual.
3.2 The Company will collect and process various types of Personal Data. In line with Article 5 of the GDPR, Personal Data must be processed according to several principles:
3.2.1 processed fairly, lawfully and in a transparent manner;
3.2.2 collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
3.2.3 adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
3.2.4 accurate and, where necessary, kept up to date;
3.2.5 kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
3.2.6 processed in a manner that ensures appropriate securities of the personal, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage.
3.3 What are the purposes for which the Company is collecting, using, storing, and/or processing your Personal Data?
3.3.1 The Company collects, uses, stores, and transfers Personal Data to provide services to its clients and ensure compliance with legal obligations. If a client fails to provide the requested information, the Company may be unable to provide its services. It is the client’s responsibility to provide accurate and up-to-date information.
3.4 What Personal Data the Company collects and/or processes about you?
3.4.1 The Company may collect and process the following types of Personal Data:
3.4.1.1 Identity Data: Name, maiden name, surname, proof of identity, username, marital status, title, date and place of birth, gender, country of residence, and citizenship.
3.4.1.2 Tax and Financial Data: Country of tax residence, tax identification number, bank account details, payment card details, e-wallet information.
3.4.1.3 Transaction Data: Payment details, products and services purchased, and transaction purposes.
3.4.1.4 Technical Data: IP address, login data, browser type and version, time zone, operating system, device information, and other technical data related to your use of our Website.
3.4.1.5 Profile Data: Username and password, order history, preferences, feedback, marketing communication preferences, and survey responses
3.4.2 The Company may also process Personal Data obtained from publicly available sources such as the internet, media, the Department of Registrar of Companies, and the Land Registry. Additionally, the Company may process sensitive personal information for employment purposes as permitted by law.
4. Usage of Personal Data
4.1 The Company is committed to protecting and respecting your privacy. By accessing or using our platform, you consent to the data practices outlined herein.
4.2 Purposes of Personal Data Usage
We may collect and use Personal Data for the following purposes:
4.2.1 Account Management: To open and maintain your account on our platform.
4.2.2 Service Improvement: To enhance services and optimize website functionality.
4.2.3 Communications: To send newsletters, alerts, and updates with your consent.
4.2.4 Performance Analytics: To monitor and analyze website interactions for improvement.
4.2.5 Legal Compliance: To fulfill legal obligations and requirements.
4.2.6 Contractual Fulfillment: To execute agreements with users or partners.
4.3 Necessity of Personal Data
The collection and processing of Personal Data are justified by the following reasons:
4.3.1 Website Operation: To provide access to our platform and ensure smooth operations.
4.3.2 Market Data Products: To provide market data services or similar products.
4.3.3 Personalized Services: To tailor content and services to individual preferences.
4.3.4 Communication Retention: To retain your data for communication purposes regarding your account and updates.
4.4 Use of Cookies and Tracking Technologies
We utilize cookies and tracking technologies for the following purposes:
4.4.1 Website management and analytics: Cookies help us manage website operations and analyze user behavior to improve our services.
4.4.2 Monitoring user interactions: We may use cookies to monitor how users interact with our website and services to enhance user experience.
4.4.3 Tracking links opened or interacted with in communications: Cookies may be used to track links opened or interacted with in communications sent to you.
5. Legal Basis for Processing Personal Data
5.1 The legal grounds for processing Personal Data by the Company are as follows:
5.1.1 Legitimate Interest: Processing based on the legitimate interest of the Company in safeguarding and promoting its business.
5.1.2 Consent: Where we have your explicit consent for processing, such as for newsletters or other marketing purposes.
5.1.3 Performance of a Contract: To fulfill contractual obligations between you and the Company.
5.1.4 Legal Compliance: To comply with applicable legal requirements.
5.2 Multiple Legal Bases for Processing
5.2.1 We may process Personal Data under more than one legal basis, depending on the specific purpose for which the data is being used. Below is a detailed table showing the purposes, data categories, and the corresponding legal bases for processing:
Purpose | Data Category | Legal Basis |
To register you as a new user, issue login credentials, verify validity, and allow access to services as per T&Cs. | Registration Data, Contact Data, Log-in Data | Performance of the contract |
To allow access to services. | Usage data | Performance of the contract |
To manage the relationship with you, provide access to services, and ancillary products. | Registration Data, Contact Data, Profile Data, Other Communication Data, Usage Data | Performance of the contract, Compliance with legal obligations |
Direct marketing of third-party services (e.g., bonuses, offers). | Marketing Communication Data | Legitimate interest (to promote our services, develop our business, enhance relationships), Consent |
Social Media Marketing | Contact Data | Legitimate interest (to promote our services, develop our business, enhance relationships), Consent |
Commercial business analysis (creating reports). | Usage Data, Analytics Data | Legitimate interest (to develop our products/services and grow our business) |
Web Analytics | Usage Data, Analytics Data | Legitimate interest (to develop our products/services and grow our business) |
5.3 Direct Marketing
In compliance with relevant laws and regulations, and based on legitimate interest or consent, the Company may periodically notify you about similar products or services. This includes but is not limited to new services, promotions, bonuses, and offers. Such notifications may be sent through:
5.3.1 Electronic email (or SMS),
5.3.2 Social media,, or (iii) Live phone calls,
5.3.3 Push notifications (desktop and/or app).
5.4 When relying on legitimate interest, the Company will provide you with the option to oppose such direct marketing when registering on our Website.
5.5 When relying on consent, the consent may be granted by you during the registration process on our Website.
6. Disclosure of Personal Data
6.1 Data Protection and Confidentiality: The Company is committed to ensuring the protection and confidentiality of your Personal Data. Below, we outline our protocols for disclosing and transferring your data, including international transfers:
6.1.1 Recipient Identification: Personal Data may be transferred globally to the Company’s subsidiaries, affiliates, and third-party service providers. These transfers are conducted in strict adherence to data protection standards to ensure confidentiality and security.
6.1.2 International Data Transfer Protocols: We implement measures such as encryption, pseudonymization, and contractual agreements to safeguard the integrity and security of your data during international transfers.
6.1.3 Confidentiality and Legal Obligations: Personal Data is treated as confidential and may be shared within the Company and with partners to fulfill contractual and legal obligations. Partners are bound by confidentiality agreements, limiting their use of your data strictly to the purposes defined by the Company and in compliance with applicable regulations.
6.1.4 Authorized Recipients of Personal Data: The Company may disclose Personal Data to the following recipients:
6.1.4.1 Technological experts appointed to maintain system operations
6.1.4.2 Platform providers supporting service delivery
6.1.4.3 Payment service providers/credit institutions to facilitate client transactions
6.1.4.4 Governmental authorities and regulatory bodies as required by law
6.1.4.5 Fraud prevention agencies, authentication, verification, and screening service providers
6.1.4.6 Data reporting service providers to meet regulatory obligations
6.1.4.7 External consultants, including internal and external auditors
6.1.4.8 The Company’s Data Protection Officer, who may be an outsourced entity
6.1.5 Legal Compliance: The Company may disclose Personal Data if required by law, law enforcement agencies, or government officials. Data may also be shared to prevent harm, combat illegal activities, enforce Terms and Conditions, or support corporate functions, all in compliance with applicable laws and regulations.
6.1.6 Recipient Notification: In cases where an individual requests rectification, deletion, or limitation of the processing of their Personal Data, the Company will notify relevant third-party recipients to ensure compliance with such requests.
6.1.7 Business Transition: In the event of a corporate reorganization, merger, or sale, Personal Data may be disclosed or transferred as part of the business transition process. The Company will implement protective measures to maintain the confidentiality and integrity of your information.
6.1.8 Third-Party Compliance: The Company does not permit third-party service providers to use your Personal Data for their own purposes. These parties are only authorized to process your Personal Data for specified purposes, following the Company’s instructions and in compliance with applicable laws. Any third-party recipient must comply with the GDPR or equivalent legislation in their jurisdiction, ensuring the same level of data protection as upheld by the Company. By using our services or accessing our platform, you acknowledge and consent to the disclosure and transfer of your Personal Data as outlined in this clause.
7. Third-Party Sites
7.1 The Company provides links to external websites or information as a service. Clicking these links redirects users away from the Company’s site.
7.2 It is important to note that the Company neither endorses nor sponsors these third parties or their sites.
7.3 Users are solely responsible for their use of these external links, which is subject to the terms and privacy notices of the respective third-party websites.
8. User Forums
8.1 Participation in user forums on this Site or through links redirecting to third-party platforms like Discord or Telegram implies acknowledgment that shared information may be accessible and utilized by other individuals.
8.2 The Company disclaims responsibility for the practices or actions of third parties who gather and employ data publicly disclosed by users on the website forums.
8.3 Users are advised to exercise prudence and discretion when divulging personal or sensitive information in such forums.
9. Mobile Device Information
9.1 The Company relies on trusted third-party service providers for in-depth analysis of mobile applications. This analysis aims to optimize performance, track usage patterns, and promptly rectify any errors detected within mobile applications.
9.2 Reports generated encompass aggregate usage data, browsing patterns, device information and details on application errors.
10. Data Retention
10.1 We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
10.2 The criteria we use to determine what is ‘necessary’ depends on the nature of the particular Personal Data in question. Our usual practice is to determine whether there are any laws (e.g., license requirements, tax, or corporate laws) permitting or obliging us to keep certain Personal Data for a period of time. In such cases, we will retain the Personal Data for the maximum period allowed by the applicable law. If there are no such laws, we will keep the data for the duration necessary to defend ourselves against any claims or legal actions.
10.3 Where your Personal Data is no longer required, we will either securely delete or anonymize it.
11. Usage of Automated Chatbots
11.1 The Company may utilize chatbots as an initial point of contact between the Company and its users to facilitate customer service interactions.
11.2 The Company exclusively utilizes chatbots as the primary contact point for triaging inquiries from users. Inquiries falling beyond predetermined parameters, such as those not addressed in the FAQ section or similar resources, are directed to human agents for further assistance. The use of chatbots is supervised by human agents.
12. Data Security
12.1 We have implemented security measures to safeguard your Personal Data from accidental loss, unauthorized access, alteration or disclosure. To comply with the law, we employ industry-standard encryption techniques to encrypt data during transit and at rest, ensuring confidentiality and integrity at all times.
12.2 We limit access to your Personal Data to those employees, agents, contractors, and third parties who have a legitimate need to know for business purposes. They will only process your Personal Data on our instructions or based on a lawful ground, as well as their duty of confidentiality.
12.3 While we take all reasonable precautions, the Company cannot guarantee absolute protection against unauthorized access or breaches. In the event of a data breach, the Company will conduct a thorough risk assessment and notify impacted individuals in accordance with applicable local laws.
13. Your Rights under the GDPR
13.1 In accordance with the EU and UK GDPR, you have the right to request confirmation from us regarding the processing of your Personal Data and we will provide you with access to the following information with reasonable intervals:
13.1.1 What Personal Data we have about you;
13.1.2 The reasons why we are processing your data;
13.1.3 The recipients to whom your data may have been disclosed;
13.1.4 The duration for which we intend to keep your data (if possible);
13.1.5 Whether we transfer your data and the safeguards we have to protect your data;
13.1.6 Your rights with respect to your Personal Data;
13.1.7 The process for making a complaint;
13.1.8 The source of your Personal Data;
13.1.9 Whether we have used any automated decision-making or profiling and any related information.
13.2 Right to Rectification – You have the right to request the rectification of any inaccurate Personal Data or to complete incomplete Personal Data concerning you. Please notify us of any changes, and we will take reasonable steps to update the data. If the change pertains to data that cannot be amended via your profile, please contact us directly.
13.3 Right to Erasure – You have the right to request the deletion of your Personal Data under the following circumstances:
13.3.1 The Personal Data are no longer necessary for the purposes for:
13.3.1.1 The Personal Data are no longer necessary for the purposes for which they were collected;
13.3.1.2 You have withdrawn your consent (if we rely on consent) and we have no other legal ground to process your data;
13.3.1.3 You have successfully exercised your right to object (explained below);
13.3.1.4 Your Personal Data have been processed unlawfully;
13.3.1.5 There exists a legal obligation to erase the data to which we are subject.
13.4 Right to Data Restriction – You have the right to request the restriction (i.e., storing but not processing) of your Personal Data in the following cases:
13.4.1 The accuracy of your data is contested (as per the right to rectification), for a period enabling us to verify the accuracy of the data;
13.4.2 The processing is unlawful and you oppose the erasure of your Personal Data;
13.4.3 We no longer need the data for the purposes for which it was collected, but you need it for the establishment, exercise, or defence of legal claims; or
13.4.4 You have exercised your right to object, and verification of our legitimate grounds to override your objection is pending.
Following a request for restriction, except for storing your Personal Data, we may only process it:
13.4.5 With your consent;
13.4.6 For the establishment, exercise, or defense of legal claims;
13.4.7 For the protection of the rights of another individual or legal entity; or
13.4.8 For reasons of important public interest.
13.5 Right to Data Portability – You have the right to request your Personal Data in a format that is easy to read by machines or to directly transfer it to another data controller, if technically feasible and without harming the rights of others. This right applies only if:
13.5.1 The processing is based on your consent or on the performance of a contract with you;
13.5.2 The processing is carried out by automated means.
13.6 Right to Object to Certain Processing – You can object to the processing of your Personal Data if it is carried out for public interest tasks or for our legitimate interests (as outlined in section 5.2). If we process your data for direct marketing purposes, you can object at any time, including profiling related to such marketing.
13.7 Right to Withdraw Consent – If we process your Personal Data based on your consent, you have the right to withdraw it at any time. You may unsubscribe from emails or update your preferences on your profile page. Withdrawing consent does not affect the lawfulness of any processing done prior to the withdrawal. If necessary, we will assess if there is an alternative legal basis for processing your data.
13.8 Right to lodge a Complaint – You can file a complaint with the relevant Data Protection Supervisory Authority, such as the Information and Data Protection Commissioner. If you reside in an EU member state, you can file a complaint with the relevant Data Protection Authority. However, we encourage you to first attempt to resolve any issues with us before contacting the authority.
13.9 You may exercise any of the above rights by sending an email to support@funderpro.com.
14. Your Rights under the California Consumer Privacy Act (“CCPA”)
14.1 For California residents under 18 years old who are registered users of any Sites featuring this Privacy Notice, California Business and Professions Code Section 22581 allows the request and removal of publicly posted content or information.
14.2 In compliance with the CCPA, this Privacy Notice outlines the Personal Data categories collected, processed and disclosed by the Company, along with the data sources and business purposes for such actions.
14.3 Under California law, you may also request, up to twice within a 12-month period, information regarding the Company’s collection, usage and disclosure of your Personal Data. This includes:
14.3.1 Categories of Personal Data collected and their sources in the preceding 12 months.
14.3.2 Commercial or business reasons for collecting, using, or disclosing that data.
14.3.3 Categories of third parties to whom the data was disclosed in the preceding 12 months.
14.4 Furthermore, upon receiving a verifiable request confirming your identity, you may inquire about the specific pieces of Personal Data collected about you and/or shared with third parties in the previous 12 months
14.5 You also retain the right to request deletion of Personal Data collected or maintained by us, subject to certain limitations specified in California law
14.6 To process your request, you must provide specific Personal Data to verify your identity as required by the CCPA. This may include your full name, email address, physical address, telephone number and details about your relationship with us
14.7 The Company does not engage in discriminatory practices based on the exercise of these rights.
15. Cookies
15.1 The Company’s Website uses cookies. For further information on what cookies are, which cookies we use, how and why we use cookies and how you can control which cookies are dropped, please read our Cookies Notice.
16. Record keeping: recording of telephone conversations and electronic communication
16.1 The Company records, monitors and processed any telephone conversations and/or electronic communications between the Company and you such as through phone, fax, email, social media, electronic messages, either initiated from the Company’s side or your side. All such communications are recorded and/or monitored and/or processed by the Company including any telephone conversations and/or electronic communications that result or may result in transactions or your order services even if those conversations or communications do not result in the conclusion of such transactions. The content of relevant in person conversations and/or communications with you may be recorded by minutes or notes.
17. Security
17.1 The privacy and confidentiality of your personal information is of fundamental importance to us. The Company takes all appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data and personal information.
17.2 The Company restricts access to personal information to employees who need to know the specific information in order to operate, develop, or improve our services. These individuals are bound by confidentiality agreements and will be subject to penalties if they fail to meet these obligations. Furthermore, Personal Data can be shared only with the parties set out in the aforementioned Disclosure of Personal Data section.
17.3 The Personal Data you provide in connection with purchasing a challenge or participating in the FunderPro Funded Phase is protected. This information can be accessed by the Client using a selected password, which must be kept secure and not shared with third parties. Additionally, this information is safely stored on the Company’s servers, with access restricted to authorized personnel only through appropriate access rights. The Company employs encryption techniques to protect this data and prevent unauthorized access.
18. Changes to the Company’s Privacy Notice
18.1 The Company reserves the right to change this Notice without further notice to you, provided that the changes do not significantly reduce your rights under this Notice. If the Company makes material changes to this Notice, the Company will notify you by email or by means of a notice on the Company’s home page or by changing the version of the document including the date of the update which will be visible to the first page of this document. The latest and prevailing version of this Notice will at all times be available at https://funderpro.com/privacy-notice/. Any revised Notice will be effective immediately upon posting on the Company’s Website.
19. Legal Disclaimer
19.1. The Company reserves the right to disclose your personally identifiable information as required by rules and regulations and when the Company believes that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order, or legal process served.
19.2. The Company will not be liable for misuse or loss of personal information resulting from cookies on the Company’s site(s) that the Company does not have access to or control over.
19.3. The Company will not be liable for unlawful or unauthorized use of your personal information, passwords, usernames, or login details due to misuse, misplacement of passwords, negligent or malicious intervention, or any other reason.
20. Contact Us
20.1 For inquiries regarding the retention period of the data you provide to us or for any other questions related to data privacy, please contact our customer support team at support@funderpro.com.