How we use waitlist information
CSPORTFOLIOMANAGER LTD is the controller of the personal data described in this notice. We are a private company registered in Scotland under company number SC897191. Contact us at support@csportfoliomanager.com.
Information we collect
- Required to join: your email address, permission to receive waitlist, private-beta and launch emails, and confirmation that you are at least 18.
- Optional beta profile: whether you want to be considered for the private beta and, if you do, one broad transaction-history size range and one broad inventory size range.
- Waitlist records: the wording you accepted, submission and confirmation dates, contact status, limited source or campaign labels, and records showing whether requested messages were accepted, delivered, rejected or unsubscribed.
- Beta selection: the outcome and date of our review if you volunteer for the private beta.
Joining the waitlist does not give us your sign-in credentials, trade link, transaction contents, item names, inventory contents, portfolio value or payment details. The waitlist pages do not use advertising pixels, and email open and click tracking is disabled.
Why we use it and our lawful bases
We use your email address and permission to confirm your request and send the waitlist, private-beta and launch messages you asked for. This processing relies on your consent. You can withdraw that consent at any time.
We use limited status, delivery, security and consent records for our legitimate interests in operating a reliable waitlist, preventing misuse, proving that permission was given and respecting opt-outs. We use information where necessary to meet legal obligations. Optional beta information is used only to review your request to take part; selection is reviewed by people and is not based solely on automated processing.
Recipients
Access is limited to authorised people who need it and to organisations that process information on our instructions for website operation, message delivery, security, support or legal compliance. We may also disclose information where the law requires it or to establish, exercise or defend legal claims. We do not sell personal data.
How long we keep it
- Confirmation links expire after 48 hours. Expired, used or replaced confirmation-token records are removed after 30 days.
- Message-delivery records and delivery events are removed after 90 days.
- If you are not selected for the beta, the two optional size ranges are cleared 90 days after that decision.
- Core waitlist and consent records are kept while the waitlist remains relevant and are scheduled for deletion no later than 12 months after general launch. You can ask us to erase your record sooner where the right applies.
- After an unsubscribe, complaint or permanent delivery failure, we may retain a minimal suppression record for as long as needed to prevent further messages to that address.
Your choices and rights
You can unsubscribe using the link in any waitlist email or by contacting us. UK data-protection law may give you rights to access, correct, erase or restrict your information, receive portable information, object to processing and withdraw consent. Withdrawing consent does not affect processing that was lawful before withdrawal. The right to object to direct marketing is absolute.
Contact us to exercise a right or raise a concern. You may also complain to the Information Commissioner’s Office.
International processing and security
Information may be processed outside the UK. Where a restricted transfer applies, we use an applicable adequacy regulation or recognised contractual safeguards and complete any required transfer assessment. Contact us if you would like more information about those safeguards.
We use data minimisation, access controls, encrypted transport, restricted secrets, hashed action links and rate limits. No online system can promise absolute security, so please contact us promptly if you suspect unauthorised access.
Changes to this notice
We review this notice when the waitlist or the law changes. We will show the current effective date here and communicate a material new use before it begins.