1 Lancaster Place
London, WC2E 7ED
Referred to as the “Company” or “we” or “our”
2. GENERAL DATA PROTECTION REGULATION (“GDPR”) IN THE UNITED KINGDOM
2.1. In complying with GDPR, we will ensure you have the following rights for individuals:
2.1.1. The right to be informed
2.1.2. The right of access
2.1.3. The right to rectification
2.1.4. The right to erasure
2.1.5. The right to restrict processing
2.1.6. The right to data portability
2.1.7. The right to object
2.1.8. Rights in relation to automated decision making and profiling.
3. INFORMATION WE MAY COLLECT FROM YOU
3.1. We may collect and process the following data about you provided at the time of requesting goods, services or information from us:
3.1.1. Information that you provide to us when you write to us (including by email)
3.1.2. Information that you provide to us when we speak to you by telephone. We may make and keep a record of the information you share with us.
3.1.3. Information that you provide to us by completing any surveys.
3.1.4. Information that you provide to us by filling in forms on our Platforms. This includes Contact Information such as name, email address, mailing address, phone number, Financial Information such as bank or brokerage account numbers, Unique Identifiers such as user name, account number, password and Preferences Information such as favourites lists, transaction history, marketing preferences. If you chose to list your company with us, we may ask for Information about your business such as company name, company size, business type and personal information such as a professional profile.
3.1.5. Details of transactions you carry out through Our Site and of the fulfilment of your orders.
3.2. As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyse trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information.
4. USES MADE OF THE INFORMATION
4.1. We use information held about you in the following ways:
4.2. To ensure that content from our Platforms is presented in the most effective manner for you and for your computer.
4.3. To provide you with information, products or services that you request from us, where you have consented to be contacted for such purposes.
4.4. To carry out our obligations arising from any contracts entered into between you and us.
4.5. To notify you about changes to our goods and services.
4.6. We may also use your data, and/or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we and/or they may contact you about these. If you are an existing customer/member, we will only contact you by electronic means (fax, email or SMS) with information about goods and services similar to those which were the subject of a previous sale to you.
4.7. We and/or any third party that we permit to use your data will not otherwise contact you by electronic means to provide you with information about goods and services which may be of interest to you, unless you have consented to this.
4.8. If you are a new customer/member, we and/or any third party that we permit to use your data will only contact you by electronic means to provide you with information about goods and services which may be of interest to you if you have consented to this. If you do not want us to use your data in one or more of the ways mentioned above, or to pass your details on to third parties for marketing purposes, please let us know by contacting us.
5. DISCLOSURE OF YOUR INFORMATION
5.2. We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
5.3. In addition to the above, we may disclose your personal information to third parties:
5.3.1. 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.
5.3.2. If all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
5.3.3. 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 our Terms and Conditions of Platform Use and other agreements; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
5.4. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users on a no-names basis. We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisements to that target audience.
6. ACCESS TO INFORMATION
6.1. If your personally information changes, or if you no longer desire our service, you may correct, update, amend, delete/remove or request it be deleted by making the changes in your member account settings page or by contacting us by telephone, email or postal mail at the contact information listed below. We will respond to your request to access within 30 days. Any access request may be subject to a fee of £50 to meet our costs in providing you with details of the information we hold about you.
6.2. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, which in some cases involving the collection and processing of financial data may require a retention period of 7 years.
6.3. If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page.
6.4. Similarly, 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 contacting us at any time.
7. COOKIES AND TRACKING TECHNOLOGIES
7.1. We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our user's browsing actions and patterns, and does not identify any individual.
7.2. For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our Platforms and to deliver a better and more personalized service. They enable us:
7.2.1. To estimate our audience size and usage pattern.
7.2.2. To store information about your preferences, and so allow us to customize our Platforms according to your individual interests.
7.2.3. To speed up your searches.
7.2.4. To recognize you when you return to our Platforms.
8. HOW WE STORE, PROCESS AND SECURE YOUR PERSONAL DATA
8.2. All information you provide to us via email or our Platforms is stored on our secure servers.
8.3. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platforms, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
8.4. The security of your personal information is important to us. When you enter sensitive information (such as bank account information) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL).
8.5. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us.
9.1. Our Platforms site offers a publicly accessible blog and a community forum. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them.
9.2. To request removal of your personal information from our blog or community forum, please contact us and we will endeavor to have it removed. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
10. LINKS TO 3RD PARTY SITES
10.1. Our Platforms may, from time to time, contain links to and from the websites of our suppliers, partner networks, advertisers, affiliates and other third parties.
10.2. If you follow a link to any of these websites, please note that these websites should have their own privacy policies and we do not accept any responsibility or liability for these policies or the content or operation of these websites. Please check these policies and the terms of the websites before you submit any personal data to these websites.
11. SOCIAL MEDIA WIDGETS
11.1. The Platform includes Social Media Features, such as the Facebook Like button. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly.
12.1. You can log in to our site using the sign-in service Facebook Connect. This service will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form.
12.2. Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your network.
14. PLATFORM PROVIDER
14.1. This Platform is provided under license to Envestors by Envestry, which is owned by Envestors Limited. The management of data on this platform is the ultimate responsibility of Envestors.
The Data Protection Officer
1 Lancaster Place
London, WC2E 7ED