We are the controller of the personal data provided to us for the purposes of applicable data protection legislation.
By personal data we mean identifiable information about you. Generally, this is likely to include information such as your name, email address, correspondence address and your IP address if you access our website.
We may collect, use, store and transfer different kinds of personal data about you:
We do not knowingly collect personal data of children. Please do not provide personal data to us unless you are at least 18 years old.
From time to time you may provide to us personal data. This may be because:
All personal data that you provide to us must be true, complete and accurate. 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 to the appropriate authorities.
Please note that we shall share your Contact Data and Identity Data with our Know Your Customer service provider, Northrow, to confirm 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 may automatically collect and store information about your Technical Data and Usage Data for the purposes of research and analysis.
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 to us is inaccurate, we may receive further personal data from third parties, such as credit reference agencies and the electoral register, to try to confirm your identity.
We may also receive personal data about you from our third party service providers, including our payment service providers, and our analytic service providers.
Our website is for individuals who are Eligible Counter parties, Professional Clients or who otherwise fall into one of the categories of person listed in Chapter 4.12 of theFinancial Conduct Authority Conduct of Business Rules, including High Net Worth Investors and Sophisticated Investors.
You should not access this website in any jurisdiction where the content of our website is not permitted. You therefore warrant that you are lawfully entitled to access the content of our website without breaching or causing us to breach any applicable regulation.
You may use our website for your personal, non-commercial use only.
You must not to (a) try to gain unauthorised access to our website or any networks, servers or computer systems connected to our website; (b) use our website in any manner that could damage, disable, overburden or impair our servers or networks or interfere with any other user’s use and enjoyment of our website; (c) use the website to provide services to third parties or to extract or scrape data; (d) use our website to develop a competitive website; and/or(e) except to the extent expressly permitted by law and not capable of exclusion by law, copy, reproduce, redistribute, sell, create derivative works from, decompile, reverse engineer, or disassemble all or part of our website.
We reserve the right to investigate and/or terminate your account if we reasonably believe that you have misused our website or behaved in a way that is inappropriate or unlawful.
If you upload any content to our website, you agree that your content will not (a) breach the provisions of any law, statute or regulation including any data protection laws and any financial services laws; (b) infringe the rights including copyrights, or other legal rights of any person; (c) be made in breach of any legal duty owed to a third party, such as a contractual duty or a duty of confidence; contain any data that identifies any living individual unless you have the right to allow us to use data on our website;(e)contain any information that would affect the trading of a security and that has not already been made publicly available; (f) be deliberately or knowingly false, inaccurate or misleading; and/or(g)otherwise give rise to any cause of action against us.
You grant to us the non-exclusive right and licence to use, edit, publish and distribute your content on our website and to allow third parties to access your content when you post in a public part of the website.
You shall indemnify and keep indemnified us, our directors and employees from and against all costs, claims, losses, expenses, fines and damages that we may suffer or incur as a result of the use of your content in accordance with these Terms or Use, including any third party claim for infringement of rights.
We accept no obligation to store your content accordingly, you shall separately maintain up-to-date copies of your content if you need to retain a copy.
Some or all of your personal data may be stored or transferred outside of the United Kingdom and/or European Economic Area (the EEA) for any reason, including for example, if our email server is located in a country outside the United Kingdom or the EEA or if any of our service providers are based outside of the United Kingdom or the EEA.
Where your personal data is transferred outside the United Kingdom and/or the EEA, it will only be transferred to countries that have been identified as providing adequate protection for personal data or to a third party where we have approved transfer mechanisms in place to protect your personal data.
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, unfortunately, because of the nature of electronic storage, we cannot promise that your personal data or any other data you provide to us will always remain secure. If there is a security breach, we will do all that we can as soon as we can to stop the breach and minimise the loss of any data.
You may consent to receive marketing email messages from us about our website and our services and business generally. 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. If you still have an account with us, we shall continue to email you in relation to your account only.
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
We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive, and we may ask for identification from you before we can fully respond to your request.
This means that we shall retain your personal data for as long as you have an account with us or otherwise access or use our website. 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 and in order to deal with any dispute you might raise.
Where we have no legal basis for continuing to process your personal data, we shall either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.