Privacy Policy

This Privacy Policy sets out how we, Witan Pacific Investment Trust plc and Witan Investment Services Limited (together "Witan Pacific", "we", "us" or "our"), collect, store and process information about you when you use or interact with our website, https://www.witanpacific.com/ (our website) and/or where we otherwise obtain or collect information about you. This Privacy Policy is effective from 25 May 2018.

Contents

  1. Summary
  2. Our details
  3. Information we collect when you visit our website
  4. Information we collect when you contact us or invest in our products
  5. Information we collect when you interact with our website
  6. Information collected or obtained from third parties
  7. Our use of profiling
  8. Disclosure and additional uses of your information
  9. How long we retain your information
  10. How we secure your information
  11. Transfers of your information outside the European Economic Area
  12. Your rights in relation to your information
  13. Your right to object to the processing of your information for certain purposes
  14. Sensitive Personal Information
  15. Changes to our Privacy Policy
  16. Children’s Privacy
  17. California Do Not Track Disclosures

1. Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

  • Data controller: Witan Pacific Investment Trust plc (and/or Witan Investment Services Limited where your interaction is with Witan Investment Services Limited e.g. when investing in savings schemes)
  • How we collect or obtain information about you: 
    • when you provide it to us (e.g. by investing in our savings schemes or contacting us, for example by signing up to receive our emails); 
    • from your use of our website, using cookies and similar technologies; and 
    • from third parties, such as RDIR who may provide us with your contact details.
  • Information we collect: name, contact details, details which you provide in communications or application forms; IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on), the geographical location from which you accessed our website (based on your IP address).
  • How we use your information: for administrative and business purposes (particularly to contact you, to improve our business and website), to fulfil our contractual obligations, to advertise ourselves, to analyse your use of our website and in connection with our legal rights and obligations.
  • Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you, where required by law or to enforce our legal rights.
  • Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No
  • How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes) and any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business).
  • How we secure your information: using appropriate technical and organisational measures such as granting access to your information where necessary.
  • Use of cookies and similar technologies: we use cookies and similar information-gathering technologies such as web beacons on our website including essential, functional and analytical cookies. For more information, please see our cookies policy on our website.
  • Transfers of your information outside the European Economic Area: in certain circumstances we, (or our service providers), may transfer your information outside of the European Economic Area. Where we do so, we will ensure (or, in the case of service providers, require that) appropriate safeguards are in place, e.g. the third parties we use who transfer your information outside the European Economic Area have self-certified themselves as compliant with the EU-U.S. Privacy Shield.
  • Use of profiling: we use profiling in relation to our website e.g. through the use of web analytics, cookies, web beacons or server logs analysis tools (profiling).
  • Your rights in relation to your information
    • to access your information and to receive information about its use
    • to have your information corrected and/or completed
    • to have your information deleted
    • to restrict the use of your information
    • to receive your information in a portable format
    • to object to the use of your information
    • to withdraw your consent to the use of your information
    • to complain to a supervisory authority
  • Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.

2. Our details

The data controller in respect of our website is Witan Pacific Investment Trust Plc (company registration number: 00091798). You can contact the data controller by writing to Beaufort House, 51 New North Road, Exeter, England, EX4 4EP or sending an email to [email protected].

Witan Investment Services Limited (company registration number: 05272533) assists in the operation of our website. You can contact Witan Investment Services Limited by writing to 14 Queen Anne's Gate, London, SW1H 9AA or sending an email to [email protected].

If you have any questions about this Privacy Policy, please contact the data controller.

3. Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

3.1. Web server log information

We use a third party to host our website, Moore-Wilson.  

Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), your HTTP status code, the number of bytes transferred, full user agent string, apache/programming language error messages and your browser version and operating system.

Our server is located in the EU.

Use of website server log information for IT security purposes.

Our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our and a third party’s legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: we and our third party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.

Use of website server log information to analyse website use and improve our website.

We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser used. 

We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).  

Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.

3.2. Cookies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular website.  Cookies allow web applications to respond to you as an individual.  The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use cookies on our website, including essential, functional and analytical cookies. For further information on how we use cookies, please see our cookies policy which is available on our website.

You can reject some or all of the cookies we use on or via our website by changing your browser settings, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

Where the website provides links to other websites, we are not responsible for the data protection/privacy/cookie usage policies of such other websites, and you should check these policies on such other websites if you have any concerns about them.  If you use one of these links to leave our website, you should note that we do not have any control over that other website.  Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting a linked website and such websites are not governed by this policy. You should always exercise caution and review the privacy policy applicable to the website in question.

4. Information we collect when you contact us or invest in our products

We collect and use information from individuals who contact us or invest in our products in accordance with this section and the section entitled Disclosure and additional uses of your information.

4.1. Email

When you send an email to the Witan Pacific email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email or in any attachments, such as in a CV). Emails to other persons will be dealt with in accordance with their privacy policies.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). 

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to goods or services provided to us (or being provided by us) we will process your information in order to do so.

Transfer and storage of your information

The information may be passed to other service providers as appropriate (e.g. to our company secretary or other service providers).  Details of our service providers and their privacy policies are set out below.

4.2. Contact form

When you contact us using our contact form, we collect your name, email address, address and phone number. We also collect any other information you provide to us when you complete the contact form, including any optional information, such as: where did you hear about us. 

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

If you do not supply the optional information required by our contact form, we will not know how you found out about us. 

Please note that details provided via the contact form will be received by certain of our service providers including DST and Direct Response. Links to their respective privacy policies are set out below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to the provision of goods or services we will process your information in order to do so.

Transfer and storage of your information

Messages you send us via our contact form will be stored on our third party hosting provider’s servers in the EU. Our third party hosting provider is Moore-Wilson.  

4.3. Phone

When you contact us by phone, we (or our relevant service providers) collect your phone number and any information provide to us during your conversation with us.

Please note that some telephone calls may be recorded.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
 
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to the provision of goods or services we will process your information in order to do so.

Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is processed by Witan Investment Services Limited's third party telephone service providers, Elite Telecom and NSN. Links to Elite Telecom’s and NSN's privacy policies are set out below.

The information may also be passed to other service providers as appropriate (e.g. to our company secretary or other service providers).  Details of service providers and their privacy policies are set out below. 

Information about your phone call will be stored by our third party telephone service providers within the European Economic Area. 

4.4. Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation) 

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to the provision of goods or services (for example, providing information about such goods and services), we will process your information in order to do so.

5. Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

When you sign up for our e-newsletter to stay up to date on Witan Pacific's performance and the views of our Managers on our website, we collect your email address.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation). 

Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

Transfer and storage of your information

We use a third party service to send out our e-newsletter and administer our mailing list, Suite 26 Their privacy policy is available here: https://www.iomart.com/privacy-policy/.

Information you submit to subscribe for our e-newsletter will be stored inside the European Economic Area on our third party mailing list provider’s servers.

Use of web beacons in emails

We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates and which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.

For more information on how we use web beacons in our e-newsletter emails, see our cookies policy which is available on our website.

For more information about our third party mailing list provider and their use of web beacons, please see their privacy policy which is available here: https://www.iomart.com/privacy-policy/

6. Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

6.1. Information received from third parties

As well as receiving information from you directly, we may receive information about you from third parties. The third parties from which we may receive information about you include RDIR, Direct Response and  Edison.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain about you directly (other than as noted above) or from third parties will generally be your name and contact details, but will include any additional information about you provide to us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services/contact you, we will process your information in order to take steps at your request to contact you/enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.

For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

6.2. Information obtained by us from third parties

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as the electoral register, Companies House, online customer databases, business directories, media publications, social media, and websites (including your own website if you have one).

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business. 

For example, we may obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.

7. Our use of profiling 

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation,  personal preferences, interests, reliability, behaviour, location or movements.

We use profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.

You have the right to object to our use of profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.

You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available on our website.

Use of profiling for web analytics

Our web analytics service, Google Analytics uses collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on). We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy. Information collected about you, once collected is anonymised and stored on an aggregate basis.

Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market ourselves to them.

Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website and your location will be analysed based on your IP address. We may target advertisements based on the level of interest we receive from certain visitors and their behaviour on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: allowing us to improve our website and how to advertise and market ourselves based on how users interact with our content.

Use of profiling in marketing emails

We use web beacons in our marketing emails to analyse who opens our emails and what actions they take (for example, what they click on). We will only process information from web beacons if you have consented to their use in accordance with our cookies policy which is available on our website.

Logic involved: by analysing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.

Significance and envisaged consequences: your behaviour when you open our emails will be tracked using small gif files (web beacons), including open rates and click through rates.

How to object: you can contact us.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: analysing the level of engagement and effectiveness of our marketing emails and content.

8. Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

8.1. Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). 

Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation). 

Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or (where applicable) to take the steps you have requested before we enter into a contract with you.

8.2. Disclosure of your information to other third parties

We may also disclose your information to other third parties in specific circumstances including, as set out below.

8.2.1. Providing information to third parties such as Google Inc. 

Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America. 

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

8.2.2. Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, affiliates, business partners, independent contractors.

Further information on each of these third parties is set out below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). 

Legitimate interest: running and managing our business efficiently.

Accountants and auditors

We share information with our accountants and auditors for tax and audit  purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.

Advisors

Occasionally, we obtain advice from advisors, such as regulatory and compliance practitioners,  financial advisors and corporate and executive coaching consultants. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.

8.2.3. Sharing your information within our business’ group of companies, including Witan Investment Services Limited for internal administrative purposes, including client, customer and employee information.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). 

Legitimate interest: running and managing our business effectively.

AND

Legal basis for processing: necessary to perform a contract or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation). 

Reason why necessary to perform a contract: we need to share your information with other companies in order to be able to meet our contractual obligations to you or to take steps at your request prior to entering a contract, for example because of the services or information you have requested.

8.2.4. Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). 

Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place

8.3. Disclosure and use of your information for legal reasons

8.3.1. Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that a fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

8.3.2. In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

8.3.3. In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process. 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): resolving disputes and potential disputes.

8.3.4. For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one or to the National Crime Agency in connection with suspected or potential money laundering matters. 

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation). 

Legal obligation(s): legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.

9. How long we retain your information

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for and in accordance with applicable law. Details of retention periods for different aspects of your personal data are available on request. Criteria which are to be considered in determining the retention periods include the following:

  • the purpose(s) and use of your information by us both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
  • whether we have any legal obligation to continue to process your information (such as any accounting, record-keeping or reporting obligations imposed by relevant law or regulation); 
  • whether we have any legal basis to continue to process your information (such as your consent);
  • any relevant agreed industry practices on how long information should be retained;
  • the levels of risk, cost and liability involved with us continuing to hold the information; 
  • how hard it is to ensure that the information can be kept up to date and accurate; and
  • any relevant surrounding circumstances (such as the nature and status of our relationship with you).

10. How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible. We limit access to your personal data to those agents, contractors and other third parties who have a business need to know.  They will only process your personal data on our instructions and they are subject to a duty of confidentiality;
  • using secure servers to store your information;
  • verifying the identity of any individual who requests access to information prior to granting them access to information;
  • putting in place procedures to deal with any suspected personal data breach.  We will notify you and any applicable regulator of a breach where we are legally required to do so.

Please note that transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

11. Transfers of your information outside the European Economic Area

Your information may be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

Some of the external service providers used by us may be based outside the European Economic Area (EEA) and/or may transfer data outside the EU so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever your personal data is transferred out of the EEA by us, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used when transferring your personal data out of the EEA.

12. Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to or sending an email to [email protected]:

  • to request access to your personal information and information related to our use and processing of your information (commonly known as a "data subject access request").  This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
  • to request the correction of information that we hold about you.  This enables you to have any incomplete or inaccurate information we hold about you corrected;
  • to request the erasure of your personal information.  This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.  You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.
  • to request that we restrict our processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
  • to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller); 
  • to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); 
  • to request the transfer of your personal information to another party; and
  • to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation. 

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website: 

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so. 

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information. 

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information. 

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

13. Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by sending an email to [email protected]:

  • to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
  • to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

  • clicking the unsubscribe link contained in any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link; 
  • sending an email to [email protected], asking that we stop sending you marketing communications or by including the words “OPT OUT”.

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available on our website.

14. Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation. 

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

15. Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email or by posting a notice on our website. 

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

16. Children’s Privacy

The only data we would hold in respect of persons under the age of 18 is that which is provided, with parental consent, in relation to investment in our Savings Schemes designed for children. We do not otherwise knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18. 

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to [email protected]

17. California Do Not Track Disclosures

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org

At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal. For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available on our website.