Privacy Policy

1. Introduction

This is your guide to how personal data is managed by Join Shuttle Limited (“Shuttle”, “Firm”). Please read it carefully. Data privacy is taken very seriously at Shuttle. It is important that you know exactly what we do with the personal information you and others provide to us, why we gather it and what it means to you. This document outlines our approach to Data Privacy to fulfil our obligations under the General Data Protection Regulation (“GDPR”) and the Irish Data Protection Act 2018. The aim of this policy is to reassure you of the importance we place on keeping your personal data secure, and of the strict guidelines we apply to its use. We want you to be clear on:

Who we are;
The information we collect about you;
When and how we collect information about you;
How we use your information;
How we use automated processing or “analytics”;
Who we share your information with;
How long we hold your information;
Implications of not providing information;
The legal basis for using your information;
Processing your information securely;
Processing your information outside the EEA;
How to exercise your information rights (including the right to object);
How to contact us and/or our Data Protection Officer;
Changes to this Policy.

This Privacy Policy applies to our services that we provide to you and the use of our platform and website associated with the services. You have a number of rights in relation to your information, including the right to object to processing of your personal information for direct marketing or where the legal basis for our use of your data is not a legitimate business interest or the performance of a task is not in the public interest.

2. Who we are

Throughout this document, “we”, “us”, “our” and “ours” refers to Join Shuttle Limited. The website joinshuttle.com and the crowdfunding platform (“Website”, “Platform”) are owned and operated by Join Shuttle Limited.

Registered Office: 3rd floor, 61 Thomas Street, Dublin 8, Ireland. Company registration number 697037. Join Shuttle Limited is regulated by the Central Bank of Ireland. The Firm is authorised pursuant to Article 12 of Regulation (EU) 2020/1503 as a crowdfunding service provider.

3. The information we collect about you

There are a number of reasons for gathering information about you. For instance, we need to know how to get in touch with you, we need to be certain of your identity and we need to understand your financial circumstances combined with economic rationale for conducting transactions. We need this information so that we can offer you products and services and give you the best possible customer experience. The information we collect falls into various categories.

3.1 Identity & contact information

Name, date of birth, contact details, online user identities (such as your log on identity, internet protocol, addresses and cookie identifiers), security details to protect identity, nationality, home address, email address, work or personal phone numbers, information relating to power of attorney arrangements.

3.2 Financial details/circumstances

Financial details, application processing and administration records, suitability assessment records, investment details, transaction details, financial needs/attitudes.

3.3 Information you provide us about others or others provide us about you

If you give us information about someone else (for example, information about a spouse, family member or financial associate provided during the course of an application or to explain the economic rationale for a specific transaction with that person), or someone gives us information about you, we may add it to any personal information we already hold and we will use it in the ways described in this Privacy Policy. Before you disclose information to us about another person, you must be sure that you have their agreement to do so. You should also show them this Privacy Policy. You need to ensure they confirm that they know you are sharing their personal information with us for the purposes described in this Privacy Policy.

3.4 Sensitive categories of data

We may hold information about you which includes sensitive personal data, such as information about you being in vulnerable circumstances or criminal conviction information. We will only hold this data when we need to for the purposes of the product or services we provide to you or where we have a legal obligation to do so. Examples of when we use this type of data include:

If you have criminal convictions, we may process this information in the context of compliance with our anti-money laundering and counter terrorist financing obligations;
Information which you have consented to us using;
Your agreement to allow us to contact you through certain channels to offer you relevant products and services.

3.5 When and how we collect information about you

As you use our services, apply for products, make enquiries, execute transactions and engage with us, information is gathered about you. We may also collect information about you from other parties, for example, when you are named in an application, from identification verification companies, Companies Registration Office and from sources where you have chosen to make your information publicly available, such as social media sites.

When and how we collect information about you:

When you use our Website and online services provided by us;
When you or others give us information verbally or in writing. This information may be in online application forms, in records of your transactions with us or if you make a complaint;
When you use our products or services, including making transactions on our Platform;
We collect information about your online activity using technology known as cookies, which can often be controlled through internet browsers;
We collect information about your internet browser settings or otherwise Internet Protocol (“IP”) and other relevant information to help us identify your geographic location when providing you with our services;
We may collect information publicly available about you – for example in online forums, social media (Facebook, Twitter, YouTube or other);
Telephone and image recordings, video recordings (office CCTV);
Information in relation to data access, correction, restriction or deletion;
Sometimes we may collect and use your personal data even though you are not a customer of ours. For example, you may be a beneficial owner, authorised signatory or representative of one of our customers or project owners, or you may be in the process of making an application for a Shuttle product or service. If so, we will apply the principles outlined in this Privacy Policy when dealing with your information.
When you make information about yourself publicly available on your social media accounts or where you choose to make information available to us through your social media account, and where it is appropriate for us to use it, this information can help enable us to do things like:
Improve our service (for example, identifying common service issues);
Personalise your online experience with us;
Contact you through the social media services, and enable you to share your experience and content via social media services. For a description on how social media services and other third party platforms, plug-ins, integrations or applications use your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings.

3.6 Cookies

“Cookies” are small pieces of information that are stored by your browser on your device. Like most Websites or Apps, we use cookies to keep track of your activity and enhance your experience. We also use cookies to assist us in the fight against fraud or malice. If you wish to disable these cookies, the “help” section of the toolbar on most browsers will tell you how. However, if you set your browser to disable cookies, you may not be able to access certain areas or features of our Website.

4. How we use your information

Whether we’re using it to confirm your identity, to help in the processing of an application for a product or service or to improve your experiences with us, your information is always handled with care and the principles outlined in this Privacy Policy are always applied. We use your information to:

Provide our products and services to you, and to fulfil our contract with you;
Process your applications for products and/or services;
Establish your eligibility and suitability for our products and services;
Establish your identity;
Manage and administer your accounts, transactions, benefits or other products and services that we or our partners may provide you with;
Conduct our regulatory requirement of ongoing due diligence and suitability assessment;
Carry out account reviews;
Run loyalty, refer a friend and other such reward programmes you have signed up to;
Contact you by phone, text message, Whatsapp, email, social media, using our online Website or other means, but not in a way contrary to your instructions to us or contrary to law;
Manage and respond to a complaint;
Compile and process your information for audit, statistical or research purposes (including, in some instances, making your data anonymous);
Protect our business, reputation, resources and equipment, manage network and information security, deal with accidental events or unlawful or malicious actions that compromise the availability, authenticity, integrity and confidentiality of stored or transmitted personal data and the security of the related services;
Prevent and detect fraud, dishonesty and other crimes (for example, to prevent someone trying to steal your identity);
Manage our legitimate interests;
Comply with our legal and regulatory obligations, including:
Complying with your information rights;
Providing you with statutory and regulatory information and statements;
Establishing your identity in order to comply with law and regulation concerning the prevention of money laundering, fraud and terrorist financing;
Complying with binding requests from the regulatory bodies, including the Central Bank of Ireland, Data Protection Commission or other authorities;
Complying with court orders arising in civil or criminal proceedings;
Performing a task carried out in the public interest.
Using your information for marketing purposes, where you have given us permission (which you can withdraw at any time):
Send electronic messages to you about product and service offers;
When we ask for your consent, we will provide you with more information on how we will use your data in reliance on that consent, including in relation to third parties we would like your consent to share your data with. For example, running promotions and direct marketing (provided that you have not objected to us using your details in this way), and research, including customer surveys, analytics and related activities.

5. How we use automated processing or analytics and our legal basis

We may use automated statistical analysis of the information we collect about you as part of our business. Analysis of your information helps us to make automated decisions. Automated analysis of our customer information (including your information) as a whole helps us to manage our business for our legitimate interests. It enables us to:

Make more informed business decisions, including improving the quality of products and services we can offer (including for the purposes of direct marketing, unless you have objected to us using your details in this way);
Test and maintain the stability and performance of our systems;
Carry out long-term statistical modelling, provided that such modelling does not affect any decision we make about you;
Automated analysis of your information also enables us for service, administrative purposes and helps us to form a single view of your relationship with Shuttle. This is intended to help us to manage and build our relationship with you and is an important part of managing our business in our legitimate interests. For example, it enables us to develop personalized information for you in real-time based on your financial and personal circumstances (for example, providing you with information when you log into your account warning you that your account is running low so you can put it in funds in order to meet a future need).

6. Who we share your information with

We only share your information with a select number of individuals and companies, and only as necessary. Sharing can occur in the following circumstances and/or with the following persons:

Your authorised representative, accountant and/or the financial institution you keep your payment account with for the purpose of the use of Shuttle service;
Your attorney (under a Power of Attorney) and any other party authorised by you to receive your personal data;
Third parties we need to share your information with in order to facilitate the services we provide to you (for example, other banks or payment institutions) and those you ask us to share your information with.
When you open a Shuttle account as a business and use our services, this may mean that your personal data will be shared with the other applicants related to the business account. For example, transactions made by you will be seen by others so authorised to view the business account transactions;
Companies that provide support services for the purposes of protecting our legitimate interests;
Your personal information remains protected when our service providers use it. We only permit service providers to use your information in accordance with our instructions, and we ensure that they have appropriate measures in place to protect your information;
Our service providers may include marketing and market research companies, analytics companies, banking partners, investment companies, IT and telecommunication service providers, software development contractors, data processors, computer maintenance contractors, printing companies, document storage and destruction companies, trust or company service providers and providers of administration services, archiving services suppliers, budgeting agencies, liquidators, examiners, auditors and consultants including legal advisors;
Statutory and regulatory bodies and law enforcement authorities. These include the courts and those appointed by the courts, government departments, statutory and regulatory bodies in all jurisdictions where Shuttle operates including An Garda Síochána (Police);
Third parties in connection with a sale or purchase of assets by Shuttle;
Those who are interested in connection with a funding arrangement for the Firm.

7. How long we hold your information

The length of time we hold your data depends on a number of factors, such as regulatory rules and the type of financial product we have provided to you. Those factors include:

The regulatory rules contained in laws and regulations or set by the Central Bank of Ireland and other authorities;
Whether you and us are in a legal or some other type of dispute with another person or each other;
The type of data we hold about you;
Whether you or a regulatory authority asks us to keep it for a valid reason;
Whether we use your data for long-term statistical modelling, provided that such modelling does not affect any decision we make about you;
As a general rule, we keep your information for a specified period after the date on which a transaction has completed or you cease to be a customer. In most cases this period is six (6) years, but may be longer where we had a deed in place.

8. Implications of not providing information

Sharing information with us is in both your interest and ours. We need your information in order to:

Provide our products and services to you and fulfil our contract with you;
Manage our business for our legitimate interests;
Comply with our legal obligations.
You can choose not to share information, but doing so may limit the services we are able to provide to you.
We may not be able to provide you with certain products and services that you request. We may not be able to continue to provide you with or renew existing products and services;
We may not be able to assess your suitability for a product or service;
When we request information, we will tell you if providing it is a contractual requirement or not, and whether or not we need it to comply with our legal obligations.

9. The legal basis for using your information

We will use your data and share that data where:

Its use is necessary in relation to a service or a contract that you have entered into or because you have asked for something to be done so you can enter into a contract with us.
Its use is in accordance with our legitimate interests outlined in this Policy.
Its use is necessary because of a legal obligation that applies to us (except an obligation imposed by a contract). An example of this would be us sharing your information with the regulatory authorities;
You have consented or explicitly consented to the using of your data in a specific way;
Its use is necessary to protect your “vital interests” pursuant to Article 6(1)(d) of the GDPR;
In exceptional circumstances we may use and/or disclose information (including special categories of data) we hold about you to identify, locate or protect you, for example, if it comes to our attention that you are in imminent physical danger and this information is requested by An Garda Síochána (Police);
Where you have made clearly sensitive categories of data about yourself public;
Where the processing of special categories of data is necessary for the establishment, exercise or defence of legal claims;
Where authorised by law or regulation, we may undertake processing of special categories of data for a substantial public interest;
Where the processing of criminal conviction data is authorised by Irish or other local law.

10. Processing your information outside EEA

Your information is stored on secure systems within Shuttle premises and with providers of secure information storage.

We may transfer or allow the transfer of information about you and your products and services with us to our service providers and other organisations outside of the European Economic Area (“EEA”) but only to countries that have been deemed by the EEA to have equivalent data protection rules and regulations to the GDPR.

11. How to exercise your information rights (including the right to object)

Providing and holding personal information comes with significant rights on your part and significant obligations on ours. You have several rights in relation to how we use your information. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you ask us otherwise. You have the right to:

Find out if we use your information, to access your information and to receive copies of the information we have about you;
Request that inaccurate information is corrected and incomplete information updated;
Object to particular uses of your personal data where the legal basis for our use of your data is our legitimate business interests (for example, profiling we carry out for our legitimate business interests) or the performance of a task in the public interest. However, doing so may have an impact on the services and products we can / are willing to provide;
Object to use of your personal data for direct marketing purposes. If you object to this use, we will stop using your data for direct marketing purposes;
Have your data deleted or its use restricted – you have a right to this under certain circumstances. For example, where you withdraw consent you gave us previously and there is no other legal basis for us to retain it, or where you object to our use of your personal information for particular legitimate business interests;
Obtain a transferable copy of certain data to which can be transferred to another provider, known as “the right to data portability”. This right applies where personal information is being processed based on consent or for performance of a contract and the processing is carried out by automated means. You are not able to obtain through the data portability right all of the personal information that you can obtain through the right of access. The right also permits the transfer of data directly to another provider where technically feasible. Therefore, depending on the technology involved, we may not be able to receive personal data transferred to us and we will not be responsible for the accuracy of the same;
Withdraw consent at any time, where any processing is based on consent. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.

We are obliged to respond without undue delay. In most instances, we will respond within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months. Should this be necessary, we will explain the reasons why.

You have the right to complain to the Data Protection Commission on the website https://forms.dataprotection.ie/contact or by post at: Data Protection Commission, Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland.

12. How to contact us and/or our Data Protection Officer

If you have any questions about how your personal data is gathered, stored, shared or used, or if you wish to exercise any of your data rights, please contact our Data Protection Officer at: support@joinshuttle.com

13. Changes to this Policy

Any updates to this Privacy Policy will be made available to you at any time via Shuttle Website and/or copies can be requested by email.

This Policy was last updated on 02/01/2026

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