Version 1.0, as at March 2019
Personal data is any information that directly or indirectly identifies you which includes, without limitation, your personal details, transactions and use of our products and services as part of your relationship with us.
Tangible Investment Management Limited (TIML, we or us) are committed to protecting the privacy and security of your personal data. For the purposes of the General Data Protection Regulation and its local implementing laws and regulations (Data Protection Laws), we are a data controller. This means that we are primarily responsible for making determinations about how and why we process your personal data.
These Data Protection Laws apply to European Economic Area (EEA) residents. If you are not a resident in the EEA, then we still may process your personal data as set out in this Privacy Notice although we are not obliged to, unless we are required by other relevant laws and regulations.
Collecting your personal data
We collect personal data about you from different places including:
- directly from you;
- from someone acting on your behalf;
- from publicly available sources or third parties; or
- where we generate such information ourselves.
We may collect, use and share certain categories of your personal data which include, without limitation, your:
- name, date of birth, address and contact details;
- nationality and national identity number(s);
- identification documentation;
- tax status and tax identification number;
- employment details, income and personal wealth; and
- bank account details and/or account balance information.
Using your personal data
We will only use your personal data when we are allowed to under the Data Protection Laws in order to fulfil our legal or regulatory obligations, provide our contractual services to you or because we have a legitimate business interest. This includes:
- detecting and preventing fraud, money laundering and/or other types of financial crime;
- providing products and/or services requested by you;
- managing your TIML accounts and dealing with any of your transactions;
- enforcing or defending our rights;
- monitoring and recording calls; and
- managing our relationship, including electronic communications, with you.
Sharing of your personal data
When we use your personal data for the purposes set out above, we may only share it with:
- custodians, clearing houses or other third parties contracted with us (and that agree to be bound by appropriate confidentiality restrictions) in order to carry out these contractual services for you or for your benefit;
- any law enforcement, regulatory, tax and other governmental authorities where we are required to do so by law or regulation;
- any introducing broker or financial intermediary from whom we receive your personal data; or
- persons ostensibly authorised to act on your behalf, including your financial advisers, appointed persons or your bank.
Transfer of your personal data to third parties and outside the EEA
We or the above recipients may transfer your personal data to third parties, both inside and outside of the EEA (such as South Africa, where data privacy laws are not equivalent to those in the EEA). In those instances, we will take the necessary steps to ensure that your personal data is protected in accordance with the Data Protection Laws.
You have a right to:
- receive certain information about our processing activities;
- request access to the personal data we hold about you;
- request the rectification, erasure or withdrawal of your personal data;
- restrict or object to the processing of your personal data;
- prevent our use of your personal data for direct marketing purposes; and
- in certain circumstances, request to transfer your personal data from us to another data controller.
In instances where we have either received consent from you or we have assessed that there is a legitimate interest for us to send you marketing communications, you may opt out of receiving this information when we collect details or at any time by contacting us at email@example.com.
When assessing legitimate interest, we will balance our interests with your rights and only send communications where you would reasonable expect to hear from us.
If you wish to exercise any of these rights you should contact our Data Protection Officer using the details provided under the Contact tab. However, please note that in some circumstances we might not be able to comply fully with your request if it conflicts with the Data Protection Laws or other laws and regulatory obligations to which we are bound.
You also have the right to lodge a complaint with the Information Commissioner’s Office if you consider that our processing of your personal data infringes the applicable Data Protection Laws. Please see: https://ico.org.uk/ for more information on how to lodge a complaint.
Security of your personal data
We have taken and will continue to take the necessary steps to protect your personal data against loss or theft, as well as from unauthorised access, disclosure, copying, use or modification, regardless of the format in which it is held. Our current policy is that we will retain your personal data for a period of five years from the end of our relationship with you.
Cookies – Information we may store on your computer
This website uses information trackers, web beacons and similar technologies (called "Cookies") to track information provided to us by your browser or software application when you use this website. Cookies are small pieces of information that a website stores on your web browser or software application which can later be used to retrieve user information. Cookies, for instance, enable a website to recognise you on your return, remember your preferences, provide tailored services or distinguish you from other users. This helps improve your experience when you browse this website and it improves the functionality, security and performance of these websites.
Most browsers are initially set to accept Cookies. In the event that you want to disable Cookies, you are responsible for deleting them from your browser or software application. If you want to know how to disable Cookies, please refer to the help menu on your web browser. For more information about Cookies, how they work, why they are so useful and how to disable them, you can visit www.allaboutcookies.org.
Please note that if Cookies are disabled, it may lead to a reduced functionality of this website (and we are not responsible for any reduced functionality).
Changes to this Privacy Notice
We may revise or supplement this Privacy Notice at any time to reflect, for example, any changes in relevant laws and regulations or as a result of a significant change to our business practices or to the technology we use. Please ensure that you check our website from time to time for such modifications.
All enquires, requests or comments regarding this Privacy Notice or relating to the processing of your personal data are welcomed and should be sent to the Data Protection Officer at Tangible Investment Management Limited, York Gate, 100 Marylebone Road, NW1 5DX, London, United Kingdom or by email to firstname.lastname@example.org.