Privacy Policy

Table of Contents

  1. Introduction
  2. Who we are
  3. Audience
  4. Personal information
  5. Personal information of children
  6. WealthExplorer™ Users
  7. Acceptance
  8. Changes
  9. Collection
  10. Use
  11. Disclosure
  12. Security
  13. Accurate and up to date
  14. Retention
  15. Transfer to another country
  16. Your rights in respect of your data
  17. Right to complain
  18. Limitation
  19. Enquiries

Callouts like this are a summary of our privacy policy and contain the most important and relevant points for you. Please read the full privacy policy because it applies to you.

1 Introduction

Welcome to PortfolioMetrix’s privacy policy, which lays out our plan of action for protecting your privacy. We respect your privacy and take the protection of personal information very seriously. The purpose of this policy is to describe the way that we collect, store, use, and protect information that can be associated with you or another specific natural or juristic person and can be used to identify you or that person (personal information).

The purpose of this policy is to describe the way that we handle personal information.

2 Who we are

This privacy policy applies to PortfolioMetrix companies (referred to as PortfolioMetrix, we, us, our).

The following PortfolioMetrix companies process personal information according to this Privacy Policy: PortfolioMetrix Asset Management Ltd; PortfolioMetrix UK Ltd; PortfolioMetrix Holdings Ltd; PortfolioMetrix Ireland; PortfolioMetrix Asset Management SA (Pty) Ltd; PortfolioMetrix South Africa (Pty) Ltd; and PortfolioMetrix Operations (Pty) Ltd.

PortfolioMetrix Asset Management Ltd is 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 info@Portfoliometrix.com, 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 info@Portfoliometrix.com.

The purpose of this policy is to describe the way that we handle personal information.

3 Audience

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 advisor providing advice (whether or not that leads to you becoming a client of the advisor or PortfolioMetrix) and investing you in financial products and services;
  • optional information that you provide to us voluntarily (see below);

but excludes:

  • 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 advisor 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 of 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.

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;

4.2 Sensitive personal information

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 WealthExplorer™ Users

Our End-User Licence Agreement (EULA or the Agreement) sets forth the terms and conditions governing your access to and use of WealthExplorer™ (The Tool).

Your access to and use of the Tool will indicate that you have read and understood the EULA and that you accept those terms and conditions in conjunction with this Privacy Policy.

The underlying sections set out the privacy and data protection clauses, as well as the confidentiality stipulations that you agree to be bound by when you make use of the WealthExplorer™ Tool.

6.1 Privacy and Data Protection

In this clause, Data Protection Laws mean all applicable national, regional, sectoral and international laws, regulations and codes of conduct governing data protection, protection of Personal Information, Investor confidentiality, fair information practices and privacy, including the European General Data Protection Regulations of 2016 (GDPR), Treating Customers Fairly rules (TCF) issued by the UK Financial Conduct Authority and the Data Protection Act of 2018.

We take privacy and the protection of personal information very seriously. We take reasonable and appropriate information security measures to comply with all applicable Data Protection Laws that apply to us. As the data controller, you always remain responsible for the personal information you use in, upload into or access using the Tool and for complying with all relevant Data Protection Laws that apply to you.

Personal Information includes data, documents and information we, you, or any third party collects on our, your, or a client’s behalf:

(a) when submitted through the Tool,
(b) when imported into the Tool, and
(c) automatically when you access or use the Tool in any way.

We may monitor access to and use of the Tool and collect, store, use and share personal and technical information submitted through the Tool for the purposes of:

(a) security;
(b) ensuring proper operation and functioning of the Tool and related services;
(c) understanding usage and improving the Tool and related services;
(d) complying with applicable Data Protection Laws;
(e) collecting statistical information;
(f) assessing financial needs, and financial personality;
(g) supporting the provision of financial advice & our services; and
(h) any other lawful and reasonable purposes we communicate to you from time to time, subject to additional specific consent where necessary.

You acknowledge that to obtain the above information we will undertake monitoring and that your devices will send technical information to us for the purposes set out above.
Personal Information may be transmitted, transferred, processed or stored outside the European Economic Area (EEA). We will, however, ensure that any such transfer complies with Data Protection Laws and that the information is given the same levels of protection as required under these laws. You acknowledge that we may transfer Personal Information uploaded into the Tool outside the EEA in compliance with Data Protection Laws.

You hereby acknowledge that the lawful basis for our processing of Personal Information that you submit or upload through the Tool shall be that of “contractual obligation” – this is where we process such Personal Information to enable us to comply with our contractual obligations; or, in certain limited circumstances, “legitimate interest” where such processing is not undertaken pursuant to our contractual obligation, but where we have a legitimate interest in the processing and, in undertaking the processing, the rights and freedoms of data subjects are not negatively impacted. You acknowledge that we may collect, access, host, store, process, transfer and use Personal Information you submit and upload through the Tool, and any related technical data, for purposes that include access to and functioning of the Tool, service improvement and security. You in turn undertake to make appropriate disclosures to and obtain all necessary authorisations and consents from, affected data subjects, where appropriate, to collect, store, process and transfer their personal information (outside the EEA) to us.

You agree that you shall not upload any Personal Information into the Tool without first having obtained the required consents and having informed the data subjects of all relevant information that you are obliged to provide them under the Data Protection Laws. Furthermore, you agree that you will not upload any ‘Special Category’ Personal Information (as defined in the Data Protection Laws) into the Tool unless:

(a) such Special Category Personal Information is absolutely necessary for you to be able to provide the services you are providing to the data subject; and
(b) you only obtain the bare minimum of such Special Category Personal Information required to perform such services.

We take all reasonable and appropriate security measures to prevent unauthorised access, corruption and loss of Personal Information according to generally accepted standards and any relevant Data Protection Laws. However, you upload any Personal Information into, submit through or store it in the Tool at your own risk, and we and third parties on our behalf are not responsible for the privacy and security of that Personal Information, to the extent allowed by applicable law.

We will comply with any reasonable written request from you to give you access to any information we have about Personal Information you have submitted and uploaded into the Tool and its processing, subject to confidentiality or other obligations or restrictions under any applicable law.

We and any relevant third-party service provider will only retain all Personal Information for as long as is necessary or as required by any applicable law. You may choose to update or remove the Personal Information you have uploaded into the Tool by deleting it or asking us to delete it on your behalf.

You indemnify, defend, and hold PortfolioMetrix (and any of its group companies) from and against any claim, demand, loss, damage, cost, or liability (including legal costs) arising out of or relating to your failure to comply with your obligations under this clause. If permissible under applicable law, legal costs will be based on all legal and related fees actually incurred.

6.2 Confidentiality

Confidential Information means all information belonging to or about a party, its related entities, associates, officers, Investors, partners, successors in title and assigns, which is not ordinarily available to external parties and includes, but is not limited to:

(a) the fact of our agreement and the terms of this Agreement, information any party wishes or is obliged to keep confidential, and/ or which is identified as or by its nature is confidential or proprietary to any party;
(b) knowledge of and/or details about trade secrets, know-how, expertise, designs, inventions, processes, procedures and practices used in business, operations or regarding products or services;
(c) business processes and internal management, administrative and control systems;
(d) knowledge of or influence over customers, business associates, suppliers, licensors, licensees, principals, agents, distributors, advisers, consultants or either party, or information about any financial, contractual, credit, discount and other arrangements with any of them;
(e) purchasing, sales, advertising, marketing, public relations and staff policies and strategies;
(f) details of investment and business decisions, financial statements or management accounts or financial structure, business affairs and operating results;
(g) details of the remuneration paid to employees and their duties;
(h) statistics and market research relating to customers, activity levels, market share and market size of a business

Each party acknowledges the other party’s right to protect Confidential Information.

All right, title and interest in and to Confidential Information (including all Intellectual Property rights therein) remain that of the disclosing party or its Group Entities, as may be applicable.

Each party acknowledges that by reason of its dealings with the other party or its use of the Tools, it may have access to, or be acquainted with the Confidential Information.
Each party undertakes in favour of the other:

(a) to use such information solely for the purpose for which they received it;
(b) to protect the Confidential Information, in order to prevent the unauthorised disclosure thereof, to return or destroy upon the written request to do so, all Confidential Information received on any media or which the party reduced to any media.
(c) Nothing in this Terms of Business means that either party grants or confers upon the other party any lien over, licence to, or other rights in, such Confidential Information.

The provisions of this clause do not prevent each party from disclosing Confidential Information if it can prove that in respect of that specific disclosure:

(a) the proprietor of such Confidential Information consented to such disclosure in writing; or
(b) such Confidential Information is or has become lawfully available to it without any obligation to keep it confidential; or
(c) such Confidential Information is or has become part of the public domain other than through a breach of this Terms of Business; or
(d) the provision of any law (including a court order) requires such disclosure.

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.

7 Acceptance

7.1 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.

7.2 Deemed Acceptance

By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.

7.3 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.

8 Changes

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.

9 Collection

9.1 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 advisor 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.

9.2 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, as per Section 6.

We collect certain information in line with our contractual obligations when we provide services

9.3 From browser

We automatically receive and record internet usage information on our server logs from your browser, such as your IP address, browsing habits, click patterns, version of software installed, system type, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences, search engine keywords, JavaScript enablement, the content and pages that you access on the website, and the dates and times that you visit the website, paths taken, and time spent on sites and pages within the website (usage information). Please note that other websites visited before entering our websites might place personal information within your URL during a visit to it, and we have no control over such websites. Accordingly, a subsequent website that collects URL information may log some personal information.

We collect certain information from your web browser, including your Internet usage information when you visit this website.

9.4 Cookies

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.

Your internet browser generally accepts cookies automatically, but you can often change this setting to stop accepting them. You can also delete cookies manually. However, no longer accepting cookies or deleting them will prevent you from accessing certain aspects of our websites or tools where cookies are necessary. Many websites use cookies and you can find out more about them at www.allaboutcookies.org.

We collect certain information from cookies that we may send to your computer and try and give you a personalised experience.

9.5 Third-party cookies

Some of our business partners use their own cookies or widgets on our website. We have no access to or control over them. Information collected by any of those cookies or widgets is governed by the privacy policy of the company that created it, and not by us.

9.6 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

9.7 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.

9.8 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 info@Portfoliometrix.com 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

9.9 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

9.10 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
  • 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

10 Use

10.1 Our obligations

We may use your personal information to fulfil our obligations to you.

10.2 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 post, telephone, email, text message or other electronic means by clicking here. You can then opt-out of receiving such updates at any time by visiting our mail preference centre by clicking here.

We may, on occasion, need to send you important service notifications where lawful.

10.3 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 info@Portfoliometrix.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

11 Disclosure

11.1 Sharing

We may share your personal information with:

  • other companies within the PortfolioMetrix group of companies to which we belong and who comply with this privacy policy so as to provide joint content and services like registration, for transactions and client support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services, and communications;
  • 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.

11.2 Regulators

We may disclose your personal information as required by law or governmental audit.

11.3 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 purposes.

11.4 No selling

We will not sell personal information. No personal information will be disclosed to anyone except as provided in this privacy policy.

11.5 Marketing Purposes

We may disclose aggregate statistics (information about the client population in general terms) about the personal information to advertisers or business partners.

11.6 Employees

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.

11.7 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.

12 Security

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 authorize access to personal information only for those employees who require it to fulfil their job responsibilities. We implement disaster recovery procedures where appropriate.

Our website is hosted on a secure server and uses security measures to prevent interference by intruders

13 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 advisor. If you would like to update your personal information processed by us, please contact our Data Protection Officer at info@Portfoliometrix.com to access or update this information. On your written request, we will provide you with 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 advisor. 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 the time.

14 Retention

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 info@Portfoliometrix.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.

15 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 is given the same levels of protection as required under these laws.

We may transfer your personal information outside the country in which it was collected.

16 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 the 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?
Consent Yes Yes No*
Contractual Obligations Yes Yes No
Legal Obligations No No No
Legitimate Interests Yes No Yes

* 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 info@Portfoliometrix.com.

17 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.

18 Limitation

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.

19 Enquiries

If you have any questions or concerns arising from this privacy policy or the way in which we handle personal information, please contact us. See details on https://www.portfoliometrix.com/contact