Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Who are we?
Investment Owl, Miss J Fitzgerald is the data controller. This means she decides how your personal data is processed and for what purposes. Her contact details are: firstname.lastname@example.org For all data matters contact Miss J Fitzgerald on email@example.com
The purpose(s) of processing your personal data
We use your personal data for the following purposes: For promoting ad sales of our investment products.
The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data: Personal data Name, Telephone Number, Email address, in the event of a sale we process your passport copy and proof of address.
We have obtained your personal data from Online Marketing and advertising and Not from publicly accessible
What is our legal basis for processing your personal data?
Our lawful basis for processing your general personal data: Consent of the data subject.
Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with the developers of the investment products you are investing in.
How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary for a period of 5 years however if you have invested we retain your personal data indefinitely in order to maintain contact in case of changes to your investment and we are requested to make contact by the developer, and in case of any legal claims/complaints; for safeguarding purposes etc.
Providing us with your personal data
You are under an obligation to provide your personal data to us unless you are investing in an investment product in which case proof of identity and proof of address will be required to carry out anti money laundering checks before transacting.
If you fail to adhere the consequences will be failure of anti-money laundering checks.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
Transfer of Data Abroad
We do not transfer your data abroad unless you have purchased an overseas investment or where the developer of the investment you have entered into is based overseas.
In the event that your data is shared with an overseas developer we have ensured they will not share your data and it will be treated as strictly confidential and used only for the purpose of contacting you to promote further investment in the aforementioned developer’s portfolio or to contact you in case of any legal claims/complaints; for safeguarding purposes etc.
Automated Decision Making
We do not use any form of automated decision making in our business.
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact Mr Jon Pedley on firstname.lastname@example.org
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
Please note – LHS Solicitors owns the copyright in this document. You must not use this document in any way that infringes the intellectual property rights in it. You may download and print this document which you may then use, copy or reproduce for your own internal non-profit making purposes. However, under no circumstances are you permitted to use, copy or reproduce this document with a view to profit or gain. In addition, you must not sell or distribute this document to third parties who are not members of your organisation, whether for monetary payment or otherwise.
The content of this document has been written with best practices in mind, however this is not a substitute for taking legal advice on your circumstances. If you do require specific advice, get in touch with us and we’ll be happy to assist you.