This privacy policy describes how Middleton Private Capital protects and makes use of the personal information you as a client give the company when you choose to invest with us. If you are asked to provide personal information, it will only be used in the ways described in this privacy policy. This policy is updated from time to time. This document is the latest version and was updated on 1st June 2018, in line with data protection law that changed on 25th May 2018 and updated the Data Protection Act 1998 to the General Data Protection Guidelines 2018. You are asked to read this policy alongside our Fair Processing Notice.
If you have questions about this policy, please phone us on 01909 261071 or alternatively you can email holly.jones@middletonprivatecapital.co.uk or write to:
Middleton Private Capital: Cavendish House, Welbeck, Worksop, Nottinghamshire, S80 3LL
Introduction
We gather and use certain information about individuals in order to provide products and services that we have stated we will fulfil. Your privacy is protected by law and Data Protection Law states we are permitted to use your personal information only if we have a proper reason for doing so. This includes sharing it outside Middleton Private Capital.
In order to be able to use your personal data, the law states we much have one or more of the following reasons:
1. To fulfil a contract we have with you;
2. When it is our legal duty;
3. When it is in our legitimate interest; or
4. When you consent to it.
A legitimate interest is when we have a business or commercial reason to use your information as long as that legitimate interest does not unfairly go against what is both right and best for you.
What data we gather
To enable us to carry out the service you have chosen us to provide, we will collect the following information:
- Name and job title;
- Contact information including email address;
- Demographic information such as address and postcode; and
- Other information relevant to processing business
- Your date of birth
- Your National Insurance Number (NIN)
This data is required under the terms of contract we have with the client and us required to process your business. If you choose not to give us this personal information, it may prevent or delay us from meeting our obligations to you as a client or may prevent you becoming a client altogether. It may also mean that we cannot perform the services needed. Any data collection that is optional will be made clear at the point of collection.
How we use this data, our reasons and legitimate interests
Collecting this data helps us understand what you are looking for from the company, enabling us to deliver improved services and products that will suit you and your requirements. Below is a list of the ways we may use your personal information, and which reasons we rely on to do so. This will also tell you what our legitimate interests are.
What we use your personal information for
- To provide you with advice or guidance about the services we provide;
- To deliver client portfolio information on a twice-yearly basis;
- For our own internal records;
- To improve the products and services available to you and that we provide;
- To contact you in response to a specific enquiry;
- To customise your service experience;
- To develop and carry out marketing activities that will enhance the business;
- To send you emails or call you about the products and services we offer and the products and services you have already requested from us;
- To contact you via email, telephone or mail for research purposes;
- To manage risk for us and our customers;
- To respond to complaints and to seek to resolve them; and
- To exercise our rights set out in agreements or contracts.
Our Reasons
- Your consent.
- Our professional service agreement.
- Fulfilling contracts.
- Our legal duty.
- We want to keep our products and services up to date and the most competitive and value for money available in our sector.
- To make sure we can get in touch with you as quickly and efficiently as possible.
- We want your experience with us to be first class, efficient and to your satisfaction.
- To ensure our company continues to develop and grow in the future.
- Inform you about new developments of both new / existing products & services.
- To develop and improve our products and services.
- To make sure we control the risk we take in our investment decisions continue to match our strategy and investment mandate.
- To make sure we have all the information we need to assess and resolve any complaints.
- To make sure we are able to provide our services in a manner that is fair to both of us.
Our legitimate interests
- To ensure we provide the correct and most suitable services to you to meet your objectives.
- To make sure our information is accurate and up to date and provides you with all the information you need to assess our performance and the value for money of our services.
- To ensure that we always have the correct and full information
necessary to allow us to provide the service we offer on a full and satisfactory basis. - We want to provide a first-class service to you that is always competitive, value for money and suitable for your needs.
- To make sure we can respond to any specific enquiry in a timely and satisfactory manner.
- To fulfil our promise to deliver first-class business in a first-class way.
- To make sure you get the service you are looking and for the cost of using our service.
- If we can develop and prosper we will be able to invest more in our company to make our services even better for you.
- To make sure you have the most up to date information about the products and services you are using and those others that are available that might interest you.
- To give you all the information you need to make sure the services you are using are right for you or what new services may also be right for you.
- We want to make sure that we continue to deliver both products and a service that meet and exceed your needs and expectations.
- Our two strategies have risk management at their core and are essential to delivering the services and target returns of each strategy. We also need to understand your own tolerance to taking a risk with your money to make sure our services are suitable and appropriate for you.
- It is important to us that we quickly resolve any complaints or anything that you are unhappy about. We can do this efficiently and effectively by making sure we have all the facts available about every part of your professional relationship with us.
- Our priority is to provide an exceptional service to you in every way. We can only do this by also making sure our company is not disadvantaged in a way that may affect our ability to provide this exceptional service to you.
Where we may collect this information
Most of your personal information will be collected from the application form you complete and provide to us when electing to become a client of Middleton Private Capital. However, you may need to update your personal information which you may do via:
- Telephone conversation
- Letter
Security
We will always hold your information securely. To prevent unauthorised disclosure or access to your information we have implemented strong physical and electronic security safeguards.
We also follow stringent procedures to ensure we work with all personal data in line with the General Data Protection Regulations 2018.
If Middleton Private Capital is ever sold in future, the new owners would be legally bound by the purchasing contract, to only use your personal data for the purposes laid out in this policy and our Fair Processing Notice, for which you, as a client, will have given authority to do so. Any changes to the way your personal data would be used must be communicated with you and an option given for you to permit or refuse such changes.
Marketing
When subscribing to our Internet Products or elsewhere on our Website you have the option to consent to receiving newsletters and other information on our products and services. If you “opt-in” we will send you promotional newsletters and inform you about offers, events and surveys via e-mail and through social media platforms.
The legal basis for such processing of your data is your consent (Art. 6(1)(a) GDPR) or – if you are an existing customer or subscriber – our legitimate interest (Art. 6(1)(f) GDPR) in providing you with relevant marketing information.
Please note that you are not legally required to provide us with your Personal Data. However, without your Personal Data we will not be able to send you our newsletters and other information as described above. You have the option to opt-out of these types of communication at any time by following the respective instructions in such communication.
Controlling your personal data
You can access your personal information that we hold at any time by writing to us at our address or by emailing Holly Jones at holly.jones@middletonprivatecapital.co.uk. If the information about you is incorrect or incomplete, then you have a right to question us and can do this over the phone, via email or by writing to us at our address. If you do, we will take reasonable steps to check accuracy and correct it.
You also have the right to object to our use of your personal information, or ask us to delete, remove or stop using it. This is known as ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’. However, if you request this then you must no longer be a client or have any investments with us – as without your personal data, we cannot provide the service you have requested from us.
We therefore will keep your personal data on file for as long as you are a client with us.
After you cease to be a client, we will keep your personal data for six years for one of the following reasons:
- To respond to any questions or complaints;
- To show that we treated you fairly; and
- To maintain records according to rules that apply to us.
We may keep your data for longer than 8 years if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.
How to complain
Please let us know if you are unhappy with how we have used your personal information. You also have the right to complain to the Information Commissioner’s Office. Our registration number is ZB202688.
Formats for sharing data
The Data Privacy laws changed on 25th May 2018. You now have the right to get your personal information from us in a format that can be easily re-used.
You can also ask us to pass on your personal information in this format to other organisations.
If we Send you Service Updates
We use your Personal Data to send you important service announcements and up-dates regarding our Website or Internet Products or, if you are a subscriber, about your billing account status. When you become a community user or when you subscribe to our Internet Products, we will send you a welcome email to provide transactional information about your subscription or to verify your username and password. Such service announcements and updates contain important information relevant to your use of our Website and/or our Internet Products.
The processing of your Personal Data for such purposes is necessary for the performance of our services. The legal basis for such processing of your Personal Data is therefore Art. 6(1)(b) GDPR. Please note that you are contractually required to provide us with such Personal Data and that without such Personal Data we will not be able to send you service-related communication.
If you Contact our Customer Service
If you contact our customer service, we will communicate with you in response to your inquiries, to provide the services you request, and to manage your subscription. We will communicate with you by email or telephone, in accordance with your preferences.
Such processing of your Personal Data is necessary for the performance of our ser-vices; the legal basis for such processing of your Personal Data is therefore Art. 6(1)(b) GDPR. Please note that you are contractually required to provide us with such Personal Data and that without such Personal Data we will not be able to send you customer service related communications.
Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. View Cookie Policy
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them below:
To enable us to monitor the usage of our website and the success of our marketing, we use Google Analytics, which uses a variety of cookies. These are used to track visitors and collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
If you would like to see a full up-to-date list of all cookies used by our website, you can use the following cookie-checking website http://sitebeam.net/cookielaw/test-your-compliance/ (other cookie-checking websites are available).
Please Note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
For more information regarding any of the information listed in our privacy policy, please Contact Middleton Private Capital