Privacy Policy

 

Last Updated: March 10, 2025

1. Introduction

FOAM (“we,” “our,” or “us”) is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (the “App”).

This policy has been developed in accordance with the UK Data Protection Act 2018, the UK General Data Protection Regulation (UK GDPR), and the EU General Data Protection Regulation (EU GDPR) where applicable.

Please read this Privacy Policy carefully. By downloading, registering with, or using the App, you agree to the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the App.

2. App Overview

The App enables you to consolidate all your assets in one place, facilitating efficient tracking and management of your asset portfolio. Based on this functionality, the service may provide you with information about products or additional services offered by third-party partners.

To be eligible to use the App, you must be at least 18 years old.

Users are not permitted to register multiple times on the Service App or register on behalf of another individual without their explicit consent.

We are committed to providing the service with a reasonable standard of expertise and care, in compliance with all applicable laws and regulations. These measures are implemented to ensure adherence to the relevant legal requirements.

3. Data Controller

For the purposes of applicable data protection laws, FOAM is the data controller responsible for your personal data.

Contact details:

– Email: [email protected]

– Postal address: Tavistock House South Entrance D, Tavistock Square, London, United Kingdom, WC1H 9LG

3. Personal Data We Collect

We may collect several types of personal data about users of our App, including:

3.1 Data You Provide to Us:

• Account information (name, email address, phone number)
• Profile information
• Communication data (when you contact us)
• Transaction data (if applicable)
• User content (any content you submit through the App)

3.2 Data We Collect Automatically:

• Usage data (how you interact with our App)
• Device information (device type, operating system)
• Location data (with your consent)
• Log data (IP address, browser type, pages visited)

5. Legal Basis for Processing

We process your personal data on the following legal bases:

• Consent: Where you have explicitly given us permission to process your data for specific purposes.
• Contract: Processing necessary for the performance of our contract with you.
• Legitimate Interests: Where processing is necessary for our legitimate interests, provided those interests do not override your fundamental rights and freedoms.
• Legal Obligation: Where processing is necessary to comply with our legal obligations.

6. How We Use Your Personal Data

We use your personal data for the following purposes:

• To provide and maintain our App
• To notify you about changes to our App
• To allow you to participate in interactive features of our App
• To provide customer support
• To gather analysis or valuable information so that we can improve our App
• To monitor the usage of our App
• To detect, prevent and address technical issues
• To fulfil any other purpose for which you provide it

7. Data Retention

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.

To determine the appropriate retention period for personal data, we consider:

• The amount, nature, and sensitivity of the personal data
• The potential risk of harm from unauthorized use or disclosure
• The purposes for which we process your personal data
• Whether we can achieve those purposes through other means
• The applicable legal requirements

8. Data Sharing and Disclosure

We will not sell, trade, or rent your personal data to third parties. We may share your personal data with:

• Service Providers: Third parties who provide services to us (hosting, maintenance, analysis, etc.)
• Business Partners: With your consent, we may share data with business partners to offer you certain products, services, or promotions
• Legal Requirements: When we believe disclosure is necessary to:
• Comply with a legal obligation
• Protect the rights, property, or safety of FOAM, our users, or others

All third parties with whom we share your data are required to protect your personal data in accordance with the law and we have appropriate contracts in place.

9. International Transfers

We primarily process and store your personal data within the UK and the European Economic Area (EEA). However, we may transfer your personal data to third parties outside the UK/EEA. When we do, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards, such as:

• Standard Contractual Clauses
• Ensuring countries have adequacy decisions
• Obtaining your explicit consent for specific transfers

9. Your Data Protection Rights

Under data protection laws, you have rights including:

• Right to Access: The right to request copies of your personal data.
• Right to Rectification: The right to request correction of inaccurate or incomplete information.
• Right to Erasure: The right to request deletion of your personal data in certain circumstances.
• Right to Restrict Processing: The right to request restriction of processing of your personal data.
• Right to Data Portability: The right to request transfer of your personal data to you or a third party.
• Right to Object: The right to object to processing of your personal data.
• Right to Withdraw Consent: The right to withdraw consent where we rely on consent to process your personal data.

You will not have to pay a fee to access your personal data or exercise any of your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

To exercise any of these rights, please contact us at [email protected].

11. Data Security

We have implemented appropriate technical and organizational measures to secure your personal data from accidental loss, unauthorized access, use, alteration, and disclosure. All personal data you provide to us is stored on secure servers behind firewalls.

While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. You are responsible for maintaining the confidentiality of any login credentials.

11.1 Advanced Data Protection

• End-to-End Encryption – Your data is encrypted both in transit and at rest, ensuring that it remains private and secure.
• Secure Authentication – We use industry-standard authentication methods, such as multi-factor authentication (MFA) and tokenized access, to prevent unauthorized access.
• Strict Privacy Controls
• Limited Data Access – Only authorized systems and personnel can access your data, strictly on a need-to-know basis.
• No Unauthorized Sharing – We never sell or share your personal data with third parties without your explicit consent.

11.2 Continuous Security Monitoring

• Real-time threat detection: At FOAM, we have ongoing, automated surveillance of our systems, networks, and applications to identify security incidents as they occur rather than after the fact.
• Comprehensive visibility: Our solutions monitor all our resources, including endpoints, servers, networks, and cloud environments to provide a complete view of the application security landscape.
• Proactive approach: Our approach to incident response is proactive threat hunting and vulnerability identification, as opposed to being reactive waiting for incidents to take place.
• Automated analysis: We leverage advanced analytics, machine learning, and behaviour analysis to detect anomalies and potential threats that might evade traditional security measures.
• Compliance assurance: Our security systems maintain continuous compliance with regulatory requirements by providing ongoing evidence of security controls and immediate alerts for compliance violations.
• Reduced dwell time: Our monitoring solutions minimise the time between breach occurrence and detection, significantly reducing potential damage to our app and as a result negative impact on our customers.
• Contextual intelligence: We correlate events across different security tools to provide meaningful insights and reduce false positives.
• Dynamic adaptation: FOAM’s protection strategies continuously evolve based on emerging threats and your changing environment.

12. Children’s Privacy

Our App is not intended for children under the age of 18, and we do not knowingly collect personal data from children under 18 years of age. If we learn we have collected or received personal data from a child under 18 without verification of parental consent, we will delete that information promptly.

13. Cookies and Similar Technologies

We may use cookies, pixel tags, web beacons, and other tracking technologies to collect information about your interactions with our App. This information may include the type of device, browser information, IP address, and other usage information.

You can instruct your device to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our App.

14. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last Updated” date.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

15. Data Protection Officer

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our DPO at [email protected].

16. Complaints

If you have a complaint regarding any service provided by FOAM, please contact us via email at [email protected], through the in-app chat, or by writing directly to the Chief Executive Officer, FOAM Ventures Limited, 71-75 Shelton Street, London, England, WC2H 9JQ. In your complaint, please outline the issue and the resolution you seek. 

We are committed to addressing all concerns and will make every effort to respond within a reasonable timeframe. Our aim is to provide a reply within 15 Business Days from the date we receive your complaint, using a durable format that allows you to store the response for future reference. In exceptional cases beyond our control, if we are unable to meet this deadline, we will send a holding reply explaining the reason for the delay and specifying a new timeline for resolution. Under no circumstances will the process exceed 35 Business Days in total. 

If your complaint relates to how we store or process your personal information, you also have the option to contact the Information Commissioner’s Office. However, we would appreciate the opportunity to address your concerns first. 

For complaints regarding financial service products (such as banking, insurance, mortgages, pensions, savings and investments, credit cards, store cards, loans, hire purchase, or financial advice) where FOAM was involved in either selling or introducing you to the product, and neither we nor any associated third party (e.g., product provider or intermediary) can resolve your complaint within 8 weeks, you may escalate your complaint to the Financial Ombudsman Service at: 

The Financial Ombudsman Service 

Exchange Tower, Harbour Exchange Square 

London, E14 9SR, United Kingdom 

17. Contact Us

If you have any questions about this Privacy Policy, please contact us:

• By email: [email protected]
• By visiting this page on our website: https://foam-ventures.com
• By mail: Chief Executive Officer, FOAM Ventures Limited, 71-75 Shelton Street, London, England, WC2H 9JQ