1.4 We are the controller of the personal data provided to us for the purposes of applicable data protection legislation.
- Whose personal data do we collect?
2.1 By personal data we mean identifiable information about you, such as your name, email address, gender, age, mobile and home telephone number and your IP address.
From time to time you may provide to us personal data. This may be because you wish to:
- use our website;
- apply for a subscription to our online paid-for content;
- apply for a job with us;
- provide services to us; or
- otherwise contact us including with queries, comments or complaints.
You may provide personal data to us directly, or through our social media platforms.
If you provide us with any personal data for any other individual, you must have their consent to do so.
All personal data that you provide to us must be true, complete and accurate. Amongst other things, we shall use all personal data to verify your identity and FCA status. If you provide us with inaccurate or false data and we suspect or identify fraud, we will record this and we may also report this.
At our request, you shall promptly provide evidence of your identity.
When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you.
When you use our website, we automatically collect and store information about your device and your activities. This information could include :
- technical information about your device such as type of device, web browser or operating system;
- your preferences and settings such as time zone and language; and
- how long you used the website and which services and features you used.
Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, please see our Cookies Policy.
If we reasonably believe that any of the personal data you have provided is inaccurate, we may receive further personal data from third parties, including the FCA, confirming or otherwise, your identity.
We may also receive personal data about you from our payment providers, Know Your Client solution providers and our website security service partners.
- Lawful use of your personal data
- consent (where you choose to provide it);
- performance of our contract with you;
- compliance with legal requirements; and
- legitimate interests. When we refer to legitimate interests we mean our legitimate business interests in the normal running of our business which do not materially impact your rights, freedom or interests.
If you apply for a subscription to our online services, we shall use your personal data first to confirm your identity and that the information provided to us is accurate. Then, if we agree to allow you to access our online services, we shall use your personal data to allow you to access our online services in accordance with our Subscription Terms.
We may from time to time need to use your personal data to comply with any legal obligations, demands or requirements, for example, as part of anti-money laundering processes or to protect a third party’s rights, property, or safety.
- Who do we share your data with?
For our legitimate interests, we may share your personal data with our service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including Know Your Client solution providers payment providers, IT service providers, accountants, auditors and lawyers.
We shall provide our service providers, sub-contractors and agents only the personal data they need to provide the service for us and if we stop using their services, we shall request that they delete your personal data or make it anonymous within their systems.
We may also share personal data you provide to us with your employer.
- Where we hold and process your personal data
Some or all of your personal data may be stored or transferred outside of the European Economic Area (the EEA) for any reason, including for example, if our email server is located in a country outside the EEA or if any of our service providers are based outside of the EEA
Where your personal data is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data or to a third party where we have approved transfer mechanisms in place to protect your personal data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties).
We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. In particular, access is restricted to employees who need to know your personal data and we use appropriate password protection and appropriate strong encryption electronic measures within our electronic data management systems.
However, because of the nature of electronic storage we cannot promise that your personal data will always remain secure. If there is a security breach, we will take all reasonable steps to stop the breach as quickly as we are able and minimise the loss of any data.
You may consent to receive marketing email messages from us. You can choose to no longer receive marketing emails from us by contacting us or clicking unsubscribe from a marketing email. Please note that it may take us a few days to update our records to reflect your request.
If you ask us to remove you from our marketing list, we shall keep a record of your name and email address to ensure that we do not send to you marketing information.
- Your rights
You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below. Further information can be found here
- Right of access: You have the right to obtain from us a copy of the personal data that we hold for you.
- Right to rectification: You can require us to correct errors in the personal data that we process for you if it is inaccurate, incomplete or out of date.
- Right to portability: You can request that we transfer your personal data to another service provider.
- Right to restriction of processing: In certain circumstances, you have the right to require that we restrict the processing of your personal information.
- Right to be forgotten: You also have the right at any time to require that we delete the personal data that we hold for you, where it is no longer necessary for us to hold it. However, whilst we respect your right to be forgotten, we may still retain your personal data in accordance with applicable laws.
- Right to stop receiving marketing information: You can ask us to stop sending you information about our services, but please note we shall continue to contact you in relation to any matters relating to your subscription
We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive.
- Retention of personal data
In particular, we shall retain your personal data for as long as you access or use our online services. However, we may also be required to retain personal data for a particular period of time to comply with legal, auditory or statutory requirements, including requirements of HMRC in respect of financial documents.
Last updated: October 2018