Privacy policy

Dated: 20 October 2016

This policy (together with our End User Access Agreement and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand the types of information we collect from you, how we use that information and the circumstances under which we will share it with third parties. By visiting our website and the intelligent savings platform known as ‘ABAKA’ (together, the “Platform”) you are accepting and consenting to the practices described in this policy.

For the purpose of the Data Protection Act 1998 (Act), the data controller is Abaka Holdings Limited of 3rd Floor, 86-90 Paul Street, London EC2A 4NE, United Kingdom (“Abaka”, “we”, “our” or “us”). Our ICO Registration Number is: ZA197872.


We may collect and process the following data about you.

Information you give us

You may give us information about you by filling in forms on our Platform or by corresponding with us by phone, e-mail or otherwise. This includes (but is not limited to) information you provide when you register to use our Platform, communicate with other users of the Platform or report a problem with our Platform. The information you give us may include (but is not limited to) your name, address, e-mail address and phone number, financial and credit card information, NI number, personal description and photograph.

Information we collect about you

With regard to each of your visits to our Platform we may automatically collect the following information:

  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Platform (including date and time); what you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Information we receive from other sources

We are working closely with third parties (including, for example, business partners, social network, sub-contractors in technical, advertising networks, analytics provider) and may receive information about you from them.


Our Platform uses cookies and similar technologies to distinguish you from other users of our Platform. This helps us to provide you with a good experience when you browse our Platform and also allows us to improve our Platform. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer, mobile phone or other device - if you agree. There are other similar technologies such as pixel tags, web bugs and webs storage which are used in desktop software or mobile devices.

For more information about the use of cookies and how to block them, visit or

If you have any questions about our use of cookies, please contact us at

Information about our use of cookies

Our website and intelligent savings platform (“Platform”) uses cookies and similar technologies to distinguish you from other users of our Platform. This helps us to provide you with a good experience when you browse our Platform, and also allows us to improve our Platform. By continuing to use our Platform, you are agreeing to our use of cookies. We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our Platform. They include, for example, cookies that enable you to log into secure areas of our Platform or our services.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Platform when they are using it. This helps us to improve the way our Platform works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our Platform. This enables us to personalise our content for you and remember your preferences.

We also use the other technologies identified above for the purposes articulated in this Cookies Policy. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Managing cookies

You block cookies by activating the settings on your web browser that allows you to refuse the setting of all or some cookies. You may be able to manage other technologies in the same way. Please note that if you use your browser settings to block all cookies (including essential cookies) and other technologies you may not be able to access all or parts of our Platform.

Expiry of cookies and other technologies

Except for essential cookies and the equivalent other technologies, all cookies and other technologies will expire after 12 months.


We use information held about you in the following ways:

  • to carry out our obligations arising from any contracts entered into between you and us (including the End User Access Agreement) and to provide you with the information and services that you request from us, other users or our business partners (including financial investment solutions);
  • to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about;
  • to provide you with information about goods or services we feel may interest you. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, do not tick the relevant box situated on the form on which we collect your data;
  • to notify you about changes to our service;
  • to administer our Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our Platform to ensure that content is presented in the most effective manner for you and for your computer or mobile device;
  • as part of our efforts to keep our Platform safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • Internal record keeping.


We may share your information with the following selected third parties:

  • service providers, sub-contractors and business partners for the performance of any contract we enter into with them or you (including the provision of financial investment solutions to you);
  • analytics and search engine providers that assist us in the improvement and optimisation of our Platform.

We may also disclose your personal information to particular third parties in the following circumstances:

  • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • if we or substantially all of our assets are acquired by a third party, in which case personal data held by it about our customers will be one of the transferred assets; and
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the End User Access Agreement and any other documents referred to on it; or to protect the rights, property, or safety of Abaka, our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.


The data that we collect is stored by us on our secure servers located in the European Economic Area (“EEA”).

However, as part of our processing of your data, it may be transferred to a destination outside the EEA. It may also be processed by staff operating outside the EEA who work for us or for one of our service providers. By submitting your personal data, you agree to this transfer, storing and processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.


Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We restrict access of your personal information to those employees of ABAKA who have a business reason for knowing such information. We continuously educate and train our employees about the importance of confidentiality and privacy of customer information. We maintain physical, electronic and procedural safeguards that comply with the relevant laws and regulations to protect your personal information from any unauthorised access.

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place physical, electronic and managerial procedures to safeguard and secure the information we collect.

Sophisticated encryption: When you use ABAKA’s website or Platform, data is transferred from your device to us. We use advanced encryption technology to keep your data secure. Automated logout: You will automatically be logged out of ABAKA’s website or Platform if you are inactive for a prolonged period of time. Fraud: ABAKA has robust fraud screening processes to mitigate and detect fraud. Authentication: ABAKA’s platform is protected by a passcode.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Platform; any transmission is at your own risk. Once we have received your information, we use strict procedures and security features to try to prevent unauthorised access.


You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at


Our Platform may, from time to time, contain links to and from the websites of our business partners, advertisers and affiliates, or other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites


You have the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.


Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.


Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to