Version: 1.1
Last Updated: 04/08/2026
1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
1.4 In this policy, "we", "us" and "our" refer to Pavtek Ltd. For more information about us, see Section 15.
1.5 We provide our services through two applications, and your data is handled very differently in each of them:
(a) the ShareCalc app (the "app"), our current application, which runs entirely within your own web browser. Your financial records are stored on your own device, and are neither transmitted to nor stored on our servers; and
(b) the legacy application (the "legacy application"), our earlier server-based application, which we are in the process of retiring, and in which your financial records are stored on our servers.
1.6 Where a provision of this policy applies to only one of those applications, we say so. Where a provision does not distinguish between them, it applies to both.
2.1 In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
2.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you.
2.3 We may process your website user account data ("account data"). The account data may include your account identifier, name, email address, business name, account creation and modification dates, usage history, website settings, and marketing preferences. The primary source of the account data is you, although some elements of the account data may be generated by our website. Account data does not include your financial records held in the app; see Sections 2.8 and 2.9.
2.4 We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
2.5 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication.
2.6 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, the pages, files and other resources you request, and the response our servers return, as well as information about the timing, frequency and pattern of your service use. The usage data comes from three sources: the logs that our web servers and application generate automatically whenever your browser requests anything from us, our analytics tracking system (provided by Simple Analytics), and our error monitoring system (provided by Sentry). Server logs are generated whether or not you have an account and whether or not you are signed in.
2.7 In the legacy application only, we may process the financial records that you upload to or enter into that application ("financial data"). The financial data may include share transactions, corporate actions, dividends, interest, financial institution account ids, withdrawals, deposits, tax liabilities, profits, losses, and account balances. The source of the financial data is you, although some elements of it may be generated by the legacy application. This Section 2.7 does not apply to the app; see Section 2.8.
2.8 In the app, we do not receive, process or store your financial records at all. The app runs inside your web browser and performs all calculations there. Your data is stored either in a file on your own device that you choose and control, or in storage provided by your web browser on your own device. It is not transmitted to us. In consequence:
(a) we cannot access, read, disclose or produce a copy of that data;
(b) we cannot recover that data for you if you lose it, and we hold no backup of it; and
(c) deleting your account with us does not delete that data, because it is not ours to delete. Deleting it is a matter for you, on your own device.
2.9 We may process any material that you choose to send to us, for example when you contact us for support or report a problem ("material you send us"). This may include ShareCalc data files, broker statements, screenshots and error reports. We only receive such material if you actively send it to us; the app never sends it on your behalf. We process it for the purposes of providing support and improving our services, and our rights in relation to it are set out in our terms and conditions. The legal basis for this processing is our legitimate interests, namely providing support to our users and improving our services.
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Operations - We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
3.3 Relationships and communications - We may process contact data, account data, customer relationship data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
3.4 Direct marketing - We may process contact data, account data, profile data, customer relationship data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email for marketing-related purposes. The legal basis for this processing is consent.
3.5 Research and analysis - We may process usage data, service data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
3.6 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.7 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.8 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.9 Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.10 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
4.2 Your personal data held in our website database will be stored on the servers of our hosting services providers https://cloud.google.com/ and https://aws.amazon.com/. Data held on your own device by the app is not stored in our website database and is not held on those servers; see Section 2.8.
4.3 Disclosure of personal data to third parties
(a) We may disclose your email and name to https://www.mailgun.com insofar as reasonably necessary for sending you email.
(b) We may disclose your usage data, transaction data, and account data to https://www.sentry.com insofar as reasonably necessary for tracking any service errors and monitoring service use.
(c) We may disclose your usage data to https://www.simpleanalytics.com insofar as reasonably necessary for analysing the use and performance of our website.
4.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.5 When you use the app, your web browser requests foreign exchange rate data directly from the public data service operated by the European Central Bank at https://data-api.ecb.europa.eu. That request is made by your browser rather than by us, and the European Central Bank will receive your IP address and the technical details of the request. No account data, no financial data, and no information about your holdings or your identity is included in those requests.
5.1 This Section 5 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) contact data will be retained for a minimum period of 1 month and maximum period of 3 months following the date of unsubscribing from our email communications where we have contact data separate from account data. Contact data held as part of account data will be deleted at the same time as the account data;
(b) account data, and financial data held in the legacy application, will be retained for a minimum period of 1 month following the date of closure of the relevant account, and for a maximum period of 3 months following that date;
(c) transaction data will be retained for a minimum period of 7 years following the date of the transaction, and for a maximum period of 9 years following that date;
(d) communication data will be retained for a minimum period of 1 month following the date of the communication in question, and for a maximum period of 9 years following that date;
(e) usage data will be retained for up to 12 months following the date of collection; and
(f) material you send us for the purposes of improving our services will be retained for as long as it remains relevant to that purpose.
5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on our legal obligations.
5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5.6 This Section 5 does not apply to data held on your own device by the app, because we do not hold that data. Its retention and deletion are entirely under your control. See Section 2.8.
6.1 In this Section 6, we have listed the rights that you have under data protection law.
6.2 Your principal rights under data protection law are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
6.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
6.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
6.5 The rights set out in this Section 6 apply to personal data that we process. They do not apply to data held on your own device by the app, because we do not process that data and have no access to it. You exercise the equivalent control over that data directly, on your own device: you can read, export, correct and delete it yourself at any time, without needing to ask us. See Section 2.8.
7.1 Our website includes hyperlinks to, and details of, third party websites.
7.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
8.1 Our website and services are targeted at persons over the age of 18.
8.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
9.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
10.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
10.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
10.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
11.1 We use cookies for the following purposes:
(a) authentication and status - we use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website;
(b) security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
(c) analysis - we use cookies to help us to analyse the use and performance of our website and service; and
(d) cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.
12.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
12.2 We currently do not use any service providers that set cookies.
13.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser and from version to version.
13.2 Blocking all cookies will have a negative impact upon the usability of many websites.
13.3 If you block cookies, you may not be able to use all the features on our website.
14.1 We may update this policy from time to time by publishing a new version on our website.
14.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
15.1 This website is owned and operated by Pavtek Ltd.
15.2 We are registered in England and Wales under registration number 16016675, and our registered office is at 71-75 Shelton Street London, WC2H 9JQ.
15.3 You can contact us by email, using info@sharecalc.co.uk
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