Dated 13/08/2020. Updated: 10/02/2021
We take your privacy very seriously. Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the Data Protection Act 2018 and the General Data Protection Regulation and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
It would be helpful to start by explaining some key terms used in this policy:
|We, us, our||means INVESTOR INFORMATION LIMITED registered in England and Wales under company number 13169410 registered office 25 Hatton Garden, Lde Suite, London, England, EC1N 8BQ.|
|Affiliate and Affiliate Group||‘Affiliate’ means any entity that directly or indirectly Controls us or is Controlled by us or is under common Control with another entity; ‘Control’ means the beneficial ownership of more than 50% of the issued share capital of a company or the legal power to direct or cause the direction of the management of the company] and the expression change of control shall be construed accordingly; ‘Affiliate Group’ means the group comprising us and all Affiliates|
|Personal information||Any information relating to an identified or identifiable individual|
Personal information we collect about you
We may collect and use the following personal information about you:
- your name and contact information, including email address and telephone number and company details
- Information to enable us to check and verify your identity, eg your date of birth
- your gender information, if you choose to give this to us
- location data, if you choose to give this to us
- your billing information, transaction and payment card information
- your personal or professional interests
- your professional online presence, eg LinkedIn profile
- your contact history, purchase history and saved items
- information from accounts you link to us, eg Facebook
- information to enable us to undertake credit or other financial checks on you
- Information about how you use our website, IT, communication and other systems
- your responses to surveys, competitions and promotions
How your personal information is collected
We collect most of this personal information directly from you, primarily via our website but may also do so by in person, by telephone, text or email. However, we may also collect information:
- from publicly accessible sources, eg Companies House or HM Land Registry;
- directly from a third party, eg:
- sanctions screening providers;
- credit reference agencies;
- customer due diligence providers;
- from a third party with your consent, eg your bank or building society;
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:
- to comply with our legal and regulatory obligations;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide information to you||For the performance of our contract with you or to take steps at your request before entering into a contract|
|To prevent and detect fraud against you or us||For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for us and for you|
|Conducting checks to identify our users and customers and verify their identity|
Screening for financial and other sanctions or embargoes
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety regulation or rules issued by our professional regulator
|To comply with our legal and regulatory obligations|
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, eg policies covering security and internet use||For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information|
To comply with our legal and regulatory obligations
|Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures||For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price|
|Preventing unauthorised access and modifications to systems||For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you|
To comply with our legal and regulatory obligations
|Updating and enhancing customer records||For the performance of our contract with you or to take steps at your request before entering into a contract|
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products
|Seeking investors in our business and that of an Affiliate||To develop our business and that of an Affiliate|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations|
For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
|Marketing our services and those of selected third parties to:|
—existing and former customers;
—third parties who have previously expressed an interest in our services;
—third parties with whom we have had no previous dealings.
|For our legitimate interests or those of a third party, ie to promote our business to existing and former customers|
|Credit reference checks via external credit reference agencies||For our legitimate interests or those of a third party, ie to ensure our customers are likely to be able to pay for our products and services|
|External audits and quality checks, eg for ISO or Investors in People accreditation and the audit of our accounts||For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards|
To comply with our legal and regulatory obligations
The above table does not apply to special category personal information, which we will only process with your explicit consent.
We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell OR share it with other organisations outside our Affiliate Group for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
- contacting us at [email protected]
- using the ‘unsubscribe’ link in emails
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal information with
We routinely share personal information with:
- companies within our Affiliate Group
- third parties we use to help deliver our services to you, eg investment providers, warehouses and delivery companies;
- other third parties we use to help us run our business, eg marketing agencies or website hosts;
- third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
- credit reference agencies;
- our insurers and brokers;
- our banks
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, eg in relation to ISO or Investors in People accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal information with any other third party.
Where your personal information is held
Information may be held at our offices and those of our Affiliate Group, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the UK and EEA’.
How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. Further details on this are available on request.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Transferring your personal information out of the UK and EEA
To provide information to you, it is sometimes necessary for us to share your personal information outside the UK and/or European Economic Area (EEA), eg:
- with our offices or other companies within our group located outside the UK/EEA;
- with your and our service providers located outside the UK/EEA;
- if you are based outside the UK/EEA;
- where there is an international dimension to the information we are providing to you.
These transfers are subject to special rules under UK data protection law. This means we can only transfer your personal information to a country or international organisation outside the UK/EEA where:
- the Information Commissioner (ICO) has issued an ‘adequacy decision’ in relation to that country or international organisation; or
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
- a specific exception applies under data protection law
These are explained below.
ICO adequacy decision
The ICO has the power to determine whether a country or international organisation provides an adequate level of protection for personal information and, if it does, to issue an ‘adequacy decision’. The effect of such a decision is that personal information can flow from the UK/EEA to that country without any further safeguards being necessary.
It may take several years to issue an adequacy decision and only a small number of countries currently benefit from one.
We may transfer personal information to the following countries that have the benefit of an adequacy decision.
Transfers with appropriate safeguards
We may transfer your data to a third country or international organisation on this ground where we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.
The safeguards will usually include using standard data protection contract clauses approved by the OIC. In relation to transfers to our overseas offices or other companies within our group, the safeguards may instead include legally binding rules and policies that apply to our Affiliate Group (known as binding corporate rules), which have been approved by the UK data protection regulator.
To obtain a copy of the standard data protection clauses and further information about relevant safeguards, including our binding corporate rules, please contact us.
Transfers under an exception
In the absence of an adequacy decision or appropriate safeguards, we may transfer personal information to a third country or international organisation where an exception applies under relevant data protection law, eg:
- you have explicitly consented to the proposed transfer after having been informed of the possible risks;
- the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
- the transfer is necessary for a contract in your interests, between us and another person; or
- the transfer is necessary to establish, exercise or defend legal claims
We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal information on this ground.
If you would like further information about data transferred outside the UK or EEA, please contact (see ‘How to contact us’ below).
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal information (the right of access)|
|Rectification||The right to require us to correct any mistakes in your personal information|
|To be forgotten||The right to require us to delete your personal information—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data|
|Data portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|To object||The right to object:|
—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
|Not to be subject to automated individual decision making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- complete a data subject request form; or
- email, call or write to us —see below: ‘How to contact us’; and
- let us have enough information to identify you (eg your full name, address and customer or matter reference number);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
Changes to this privacy notice
This privacy notice was published and last updated on the dates set out at the top.
We may change this privacy notice from time to time—when we do we will inform you via [insert mechanism for informing the data subject of changes to the notice, eg our website or other means of contact such as email].
How to contact us
Our contact details are shown below:
|INVESTOR INFORMATION LIMITED|
25 Hatton Garden, LDE Suite, London ECN 8BQ
Do you need extra help?
If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).