Table of Contents
- Who we are
- Personal information
- Personal information of children
- Accurate and up to date
- Transfer to another country
- Your rights in respect of your data
- Right to complain
The purpose of this policy is to describe the way that we handle personal information.
2 Who we are
PortfolioMetrix Asset Management Ltd is a registered as a Data Controller with the Information Commissioner’s Office with registration number Z345209X. PortfolioMetrix companies based in the United Kingdom can be contacted via email at firstname.lastname@example.org, via telephone on 020 7965 7533 and via post at 66 Buckingham Gate, Westminster, London SW1E 6AU.
Other PortfolioMetrix companies can be contacted via email at email@example.com.
The purpose of this policy is to describe the way that we handle personal information.
This policy applies to you if you are:
- a visitor to our website; or
- a client or adviser who has invested in the products or services that we provide.
By using our websites and services, you consent to the processing of data about you in the manner and for the purposes set out in this policy.
This policy applies to you under certain circumstances.
4 Personal information
Personal information includes:
- information that we collect automatically when you visit or use any of our websites or online services;
- information collected on registration (see below);
- information collected in the process of your financial adviser providing advice (whether or not that leads to you becoming a client of the adviser or PortfolioMetrix), producing advice and investing you in financial products and services;
- optional information that you provide to us voluntarily (see below);
- information that has been made anonymous so that it does not identify a specific person;
- permanently de-identified information that does not relate or cannot be traced back to you specifically;
- non-personal statistical information collected and compiled by us; and
- information that you have provided voluntarily in an open, public environment or forum including any blog, chat room, community, classifieds, or discussion board (because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal information subject to protection under this policy).
Personal information includes information we collect (i) automatically when you visit or use our website and online tools, (ii) on registration, (iii) collected by your financial adviser and (iv) from you voluntarily. It excludes (i) anonymous, (ii) de-identified, (iii) non-personal statistical, and (iv) public information.
4.1 Common examples
Common examples of the types personal information which we may collect and process include your:
- identifying information – such as your name, date of birth, or identification number of any kind;
- contact information – such as your phone number or email address;
- address information – such as your physical or postal address and your Internet Protocol Address (IP address); or
- demographic information – such as your gender or marital status.
4.2 Sensitive personal information
Depending on the products or services that you require, we may also collect sensitive personal information, including your:
- financial information – such as your bank account details, assets and liabilities, cash flow details;
But, we will not collect sensitive personal information in the form of your:
- sensitive demographic information – such as your race or ethnicity;
- medical information – such as information about your physical or mental health;
- sexual information – such as information about your sex life or sexual orientation;
- criminal information – such as information about your commission or alleged commission of any offence or about any related legal proceedings;
- employment information – including your membership of a trade union; and
- beliefs – including your political, philosophical or religious beliefs.
5 Personal information of children
PortfolioMetrix does not provide any services to a natural person younger than 18 years old, without prior authorisation from a person who is legally competent to consent to decisions taken in respect of the child. Upon written request to PortfolioMetrix, the legally competent person may review the child’s personal information as processed by PortfolioMetrix.
6.1 Acceptance required
You must accept all the terms of this policy when you choose to contract with PortfolioMetrix, register for, or use any of our services. If you do not agree with anything in this policy, then you must not contract with PortfolioMetrix, register for, or use any of our services.
You may not contract with PortfolioMetrix or register for, or use any of our services if you do not accept this policy.
6.2 Deemed acceptance
By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.
6.3 Your obligations
You may only send us your own personal information or the information of another data subject where you have their permission to do so. For example, if you are providing financial information relating to your spouse or a related legal entity such as a trust, you need their permissions to do so.
We may change the terms of this policy at any time by updating this web page. We will notify you of any material changes by placing a notice in a prominent place on the website or by sending you an email detailing the changes that we have made and indicating the date that they were last updated. If you do not agree with the changes, then you must stop using the website and our products or services. If you continue to use the website or our products or services following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted those updated terms.
8.1 On registration
Once you register on our website, you will no longer be anonymous to us. You will provide us with certain personal information when you register on our website or for one of our online tools.
We will use this personal information to provide services and information to you and your adviser as we reasonably think appropriate, and for any other purposes set out in this policy.
We collect certain information on registration, when you register on our website or for one of our online tools.
8.2 On order
When you use any products or services from us, you may be asked to provide us with additional information on a voluntary basis (products information or services information). You will only be asked to provide this information where it is required by us to provide the product or services to you.
8.3 From browser
We collect certain information from your web browser, including your Internet usage information when you visit this website.
We may place small text files called ‘cookies’ on your device when you visit our websites. These files do not contain personal information, but they do contain a personal identifier allowing us to associate your personal information with a certain device. These files serve a number of useful purposes for you, including:
- granting you access to age restricted content;
- tailoring our website’s functionality to you personally by letting us remember your preferences;
- improving how our website performs;
- allowing third parties to provide services to our website; and
- helping us deliver targeted advertising where appropriate in compliance with applicable laws.
We collect certain information from cookies that we may send to your computer to try and give you a personalised experience.
8.5 Third party cookies
8.6 Web beacons
Our websites may contain electronic image requests (called a single-pixel gif or web beacon request) that allow us to count page views and to access cookies. Any electronic image viewed as part of a web page (including an ad banner) can act as a web beacon. Our web beacons do not collect, gather, monitor or share any of your personal information. We merely use them to compile anonymous information about our website.
We collect certain information from web beacons on our website to compile anonymous information about our website.
8.7 Optional details
You may also provide additional information to us on a voluntary basis (optional information). This includes content or products that you decide to upload or download from our website or when you enter competitions, take advantage of promotions, respond to surveys, order certain additional products or services, or otherwise use the optional features and functionality of the website.
8.8 Recording calls
We may monitor and record any telephone calls that you make to us, unless you specifically request us not to. You have the right to request recordings of any recorded calls in which you participate. Contact firstname.lastname@example.org to request a relevant recording in writing. We endeavour to provide the recording within a reasonable time frame. Please note that in order to better protect you and safeguard your personal information, we take steps to verify your identity before granting you access to your telephone recordings.
We may record telephone calls that you make to us. You have the right to request recordings of any recorded calls in which you are a participant.
8.9 Purpose for collection
We may use any products information, services information, or optional information that you provide to us for the purposes that you indicated when you agreed to provide it to us.
We generally collect and process your personal information for various purposes, including:
- services purposes – such as providing advice, administration, and management services related to investment products, financial advice, or other services;
- marketing purposes – such as pursuing lawful related marketing activities;
- business purposes – such as internal audit, accounting, business planning, and joint ventures, disposals of business, or other proposed and actual transactions; and
- legal purposes – such as handling claims, complying with regulations, or pursuing good governance.
Processing includes gathering your personal information, storing it, transmitting it, disclosing it, analysing it, disposing of it, and combining it with other personal information.
We may use your usage information for the purposes described above and to:
- remember your information so that you will not have to re-enter it during your visit or the next time you access our websites or online tools;
- monitor website usage metrics such as total number of visitors and pages accessed; and
- track your entries, submissions, and status in any promotions or other activities in connection with your usage of the website.
We may use any of your personal information that you provide to us for the purposes that you indicated when you agreed to provide it to us.
8.10 Lawful basis for processing
We will process your personal information using the following lawful basis:
- Consent – we will seek your consent to processing where it is appropriate for us to do so;
- Contractual Obligation – we will process your personal information to enable us to comply with our contractual obligations to you;
- Legal Obligations – we will process your personal information to ensure compliance with any legal obligation we may have; and
- Legitimate Interest – on occasions we will process your data where we have a legitimate interest in doing so and such processing will not unduly negatively affect your rights.
The lawful basis we use for processing your personal information are Consent, Contractual Obligation, Legal Obligation and Legitimate Interest.
9.1 Our obligations
We may use your personal information to fulfil our obligations to you.
9.2 Messages and updates
PortfolioMetrix would like to keep in touch with you about our products and services that may interest you. Where you are not an existing client, you can sign up to receive such updates by email or other electronic means by clicking here. You can then opt-out of receiving such updates at any time by visiting our email preference centre by clicking here.
We may, on occasion, need to send you important service notifications where lawful.
9.3 Targeted content
While you are logged into the website, we may display targeted adverts and other relevant information based on your personal information. In a completely automated process, computers process the personal information and match it to adverts or related information. Decisions regarding targeted content directed towards you (e.g. profiling) may be made on an algorithmic basis using your personal information where there are legitimate business grounds to do so. If you require such decisions to be explained to you, contact our Data Protection Officer at email@example.com.
We never share personal information with any advertiser, unless you specifically and unambiguously provide us with your consent to do so. Advertisers receive a record of the total number of impressions and clicks for each advert. They do not receive any personal information. If you click on an advert, we may send a referring URL to the advertiser’s website identifying that a client is visiting from the website. We do not send personal information to advertisers with the referring URL. Once you are on the advertiser’s website however, the advertiser is able to collect your personal information.
We may use your information for targeted content in certain, specified instances.
We may share your personal information with:
- our product suppliers or service providers under contract who help supply certain products or help with parts of our business operations, including monitoring and management of your account, fraud prevention, bill collection, marketing, technology services (our contracts dictate that these product suppliers or service providers only use your information in connection with the products they supply or services they perform for us and not for their own benefit);
We may share your personal information with third parties for the purposes of fulfilling our obligations to you among other purposes.
We may disclose your personal information as required by law or governmental audit.
10.3 Law enforcement
We may disclose personal information if required:
- by a subpoena or court order;
- to comply with any law;
- to protect the safety of any individual or the general public; and
- to prevent violation of our client relationship terms.
We may disclose personal information to third parties if required for legal reasons.
10.4 No selling
10.5 Marketing purposes
We may disclose aggregate statistics (information about the client population in general terms) about the personal information to advertisers or business partners.
We may need to disclose personal information to our employees that require the personal information to do their jobs. This means we may disclose it to our management, operations, human resources, accounting, audit, compliance, information technology, or other personnel.
10.7 Change of ownership
If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may assign our rights to the personal information we process to a successor, purchaser, or separate entity. We will disclose the transfer on the website. If you are concerned about your personal information migrating to a new owner, you may request us to delete your personal information.
We take the security of personal information very seriously and always do our best to comply with applicable data protection laws. Our hosting company will host our website in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. Personal information is stored in encrypted form and we make use of industry standard security scanning services to ensure appropriate levels of security are maintained. We authorise access to personal information only for those employees who require it to fulfil their job responsibilities. We implement disaster recover procedures where appropriate.
Our website is hosted on a secure server and uses security measures to prevent interference by intruders.
12 Accurate and up to date
We will try to keep the personal information we collect as accurate, complete and up to date as is necessary for the purposes defined in this policy. From time to time we may request you to update your personal information. You are able to access, review or update any personal information that we hold on you at any time by accessing your account online, emailing or phoning your financial adviser. If you would like to update your personal information processed by us, please contact our Data Protection Officer at firstname.lastname@example.org to access or update this information. On your written request, we will provide you a copy of your personal information which we process within one month, for no cost. Please note that in order to better protect you and safeguard your personal information, we take steps to verify your identity before granting you access to your account or making any corrections to your personal information.
Please keep your personal information accurate and up to date by accessing your account online, emailing or phoning your financial adviser. Advisers who wish to access their personal information should contact our Data Protection Officer. You may request access to the data we hold on you at any time.
We may retain your personal information in physical or electronic records at our discretion. We will only retain your personal information for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless:
- retention of the record is required or authorised by law; or
- you have consented to the retention of the record.
During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal information. Should you wish to have your personal information erased by PortfolioMetrix, please contact email@example.com. In the absence of any legal requirement for PortfolioMetrix to retain your personal information, we will erase your information without unreasonable delay.
We will only retain your personal information for as long as is necessary.
14 Transfer to another country
We may transmit or transfer and process personal information outside of the country in which we are providing the product or service.
Personal information may be processed or stored on servers located outside the country in which we are providing the product or service, and whose laws protecting personal information may not be as stringent as the laws in the country in which we are providing the product or service. PortfolioMetrix will however ensure that any such transfer complies with the Data Protection Laws of the country in which we are providing the product or service and that the data it is given the same levels of protection as required under these laws. You consent to us processing your personal information in a foreign country in compliance with the Data Protection Laws of the country in which we are providing our services.
15 Your rights in respect of your data
You have a number of rights in respect of the personal information we hold about you, these are:
- The right to access your personal information
- The right to require us to correct any personal information we hold about you
- The right to request that we erase personal information we hold about you
- The right to object to any processing we are undertaking
- The right to require us to restrict the nature of the processing we are undertaking; and
- The right to require us to transfer the personal information we hold about you to another party.
The rights you can exercise depend on the lawful basis we are relying on for the processing we are undertaking. The table below outlines when you can exercise the above rights.
|Lawful Basis for Processing||Right to Erasure?||Right to Portability?||Right to Object?|
* This does not change your right to withdraw consent to us processing your personal data where we are relying upon consent as the lawful basis.
If you wish to exercise any of the above rights, or have any queries about how we hold and process your data, please contact firstname.lastname@example.org.
16 Right to complain
In addition to the above rights, you may submit a complaint to the relevant regulatory authority if you feel that data protection legislation applicable to you has been contravened.
We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third party websites or online tools.