Privacy and Cookie Policy - Tatton Investment Management

About this privacy policy

This Data Privacy Policy applies when you visit our websites tattonportal-prod.co.uk, tattoninvestments.com, tattonfunds.com, and tattonportal.co.uk. It also applies where we are in contact with you in other ways whether in your capacity as an individual or as a shareholder, or other representative of a company or other organisation.

Who we are

We are Tatton Investment Management Limited, (Tatton), a private limited company registered in England and Wales under number 08219008. Our Registered Office is: Paradigm House, Brooke Court, Wilmslow, Cheshire SK9 3ND.

(“Tatton”, “we”, “our”, and “us”).

We are registered with the UK Data Commissioner’s Office (“ICO”) under registration number ZA229009. Tatton Investment Management Limited is authorised and regulated by the Financial Conduct Authority. Firm Reference Number 733471.

Contacting us

We are not required to appoint a formal data protection officer under data protection laws. However, our Head of Compliance is responsible for data protection in Tatton.

If you have any questions about our Data Privacy Policy or your data, or to exercise any of your rights as described in this Data Privacy Policy or under data protection laws, you can contact us:

By post:

Head of Compliance Tatton Investment Management Limited, 17, St Swithin’s Lane, London. EC4N 8AL

By telephone: +44 (0)207 139 1490

By email: [email protected]

You have the right to make a complaint at any time with a supervisory authority, in the EU (or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is ICO who can be contacted at https://ico.org.uk or telephone on 0303 123 1113.

Data we collect

You choose to provide us with personal data when you are introduced to us, when we meet you in person, or when we are in contact by phone, email, via our website or otherwise.

The categories of personal data you provide includes:

Identity data
Contact details
Technical and device data

Data we collect from third parties

Wealso receive personal data from third parties who we work closely with and who are entitled to share that data, e.g. Financial Advisers, investment Platforms and Regulators, but only as permitted by applicable law.

Data we collect online

Each time you visit Tatton websites we automatically collect the following data:

Technical data, including the Internet Protocol (IP) address used to connect your computer to the internet, your login data, browser type and version, time zone settings, browser plug-in types and versions, operating systems and platforms, etc.; and
Data about your visit, including the full Uniform Resource Locators (URL) of the internet sites you came through to our websites and which pages you visited (including date and time); page response times; download errors; length of visits to certain pages; page interaction data; and methods used to browse away from the page, provided we can do so lawfully.

Cookies (small text files)

The Tatton websites use cookies to distinguish you from other users of our websites to help us improve our applications and services. We do not use cookies to store any personally identifying data from users except to identify a user who has chosen to log in to the site. We do not use cookies to track user activities beyond our websites.

You can control and/or delete cookies as you wish – for details, see aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you will have to manually adjust some preferences every time you visit a site and some services and functionalities will not work.

Sensitive personal data

We do not collect sensitive (or special categories of) personal data. Sensitive personal data is defined by data protection laws to include personal data revealing a person’s racial or ethnic origin, religious or philosophical beliefs, or data concerning health.

Children

We do not knowingly collect data relating to children.

Legal basis for processing personal data

Our legal basis for processing your personal data is to carry out our obligations arising from any contracts between you and us and to provide you with the data and services that you request from us. This is not overridden by your data protection interests or fundamental rights and freedoms. We also collect personal data from you via our websites where we have your consent to do so or where we need the personal data to perform a contract with you. We also have a legal obligation to collect personal data from you to fulfill our regulatory and legal obligations.

How we use your data

The purpose for which we use and process your data is explained below:

To provide our investment services to you as detailed in any contracts between you and us. This includes but is not limited to investment performance data for research and analysis purposes
To comply with our legal and regulatory requirements such as Financial Conduct Authority requests for information
For the detection, prevention, and investigation of illegal or prohibited criminal activities and in the protection of our legal rights (including liaison with regulators and law enforcement agencies)
To review and analyse the investment services we provide
To provide you with access to applications in relation to services you have requested
To notify you about changes to our investment services
To reconcile the fees due to us for our services and received from the retail investment Platform
To administer the website and secure portals so we can improve the use, presentation, performance and security of the services.
To monitor emails received by and sent to Tatton Investment Management staff to ensure compliance with professional standards and our internal compliance policies. Monitoring is not continuous or routine but will be undertaken on the instruction of senior management where there are reasonable grounds for doing so. Occasional spot checks or audits will also be undertaken on the instruction, or with the authority of senior management.
Our websites cookies are not used to identify you personally, they are used to make the site work better and allow us to analyse how it is being used. You can delete these cookies any time you want, but some aspects of the websites may not work correctly without cookies.

If you do not wish to provide us with your personal data and processing such data is necessary for the performance of a contract with you, we will not be able to perform our obligations under the contract between us.

Tatton will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you in a timely manner and we will explain the legal basis which allows us to do so.

Who we share your personal data with

We do not share your personal data with third parties except as provided in this Data Privacy Policy. We will not sell or rent it to third parties, nor will we share it with third parties for marketing purposes.

We will share your personal data (including storage and transfer of data) with:

Any members of Tatton Investment Management Limited and Tatton Asset Management Plc. for the purposes set out in this Data Privacy Policy
Any third party so we can meet our legal and regulatory obligations, including statutory or regulatory bodies, law enforcement agencies and company auditors
Our service providers and agents (including their sub-contractors) or third parties who process data on our behalf in relation to, for example, printing services, bulk communication purposes and internet services. We only disclose the data that is necessary to deliver the service and we have a contract in place that requires them to keep your data secure and not use it for their own direct marketing purposes.
Any third party in the context of actual or threatened legal proceedings provided we can do so lawfully

Transfers outside of the European Economic Area

We do not transfer any personal data that we collect from you to service providers (and their employees) operating outside the EEA. Should we need to do this we would take steps to ensure all appropriate measures and controls are in place to protect your personal data in accordance with applicable data protection laws and regulations in the UK.

Security of your personal data

The security and storage of your personal data is very important to us.

The personal data we collect from you is stored by us on secure servers, protected through a combination of physical and electronic access controls, firewall technology and other security measures.

We will not disclose any personal data, under any circumstances, unless we are satisfied that the individual requesting it has the appropriate authority.

Although we use market standard security software to protect your personal data, we cannot guarantee the security of personal data transmitted by you to our websites, secure portals, applications, or services; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorised access.

If we have given you (or you have chosen) a password to access certain areas of our websites, applications or services please keep this password safe. We will not share this password with anyone. If you believe your account has been compromised, please contact us by any method given above so we can take additional steps to protect your personal data as appropriate.

How long we keep your personal data

Your personal data will not be kept for longer than is necessary for the purposes for which it was collected and processed and for the purposes of satisfying any legal, accounting, or reporting requirements.

Your rights

You have the following rights:

To be informed about how we obtain and use your data
To ask for a copy of the data that we hold about you
To have your data rectified
To request us to restrict processing of your personal data
To request to have your data erased (Right to be forgotten)
To have data you provided to us, returned to you or sent directly to another company, in a structured, commonly used and machine readable format where technically feasible (Data Portability)
Where the processing of your data is based on your consent, the right at any time to withdraw that consent; and
To lodge a complaint with the Data Commissioner’s Office (ICO), the supervisory authority responsible for data protection matters.

You cannot opt out of receiving regulatory or legal data or updates (e.g. data about a change to our product terms and conditions).

If you withdraw your consent to the processing of your personal data or you ask for your data to be erased, we will not be able to provide you with access to all or parts of our website, applications, products or services. If we are not able to comply with your request, we will confirm this to you along with confirmation of the lawful basis which we will rely on to continue processing your personal data.

Exercising your rights

You can exercise any of your rights as described in this Data Privacy Policy and under data protection laws by contacting us as provided in “Contacting us” above.

Save as described in this Data Privacy Policy or provided under data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we will either: (a) charge a reasonable fee taking into account the administrative costs of providing the data or taking the action requested; or (b) refuse to act on the request.

Where we have reasonable doubts concerning the identity of the person making the request, we will request additional data necessary to confirm your identity.

Other sites and social media

If you follow a link from our websites, applications or services to another site or service, this Privacy Data Notice will no longer apply. We are not responsible for the data handling practices of third-party sites’ or services and we encourage you to read the Privacy Data Notices appearing on those sites or services.

Changes to our Data Privacy Policy

From time to time, we may change this Data Privacy Policy. The current version will always be available from us in hard copy or on our website. We will post a prominent notice on our website to notify you of any significant changes to the Data Privacy Policy or update you by other appropriate means.

Website Terms of Use

Browse at your own risk

Please note that you access and use the Tatton Investment Management Limited (Tatton) website(s) at your own risk. We will not be responsible for any type of loss or damage which you may sustain by accessing and using these. We will assume no responsibility for the contents of any other websites to which these websites have links and if you access a linked website you do so at your own risk. Our inclusion of links to websites does not imply any endorsement by us of the materials on these websites. We do not permit any third party to operate a link to our websites nor do we permit any third party to frame the websites without obtaining our prior written consent.

The Tatton websites are accessed via the world-wide web (“WWW”) which is independent of us. Your use of the WWW is at your own risk and subject to all applicable national and international laws and regulations. We have no responsibility for any data or services obtained by you on the WWW. Tatton reserves the right to modify, supplement, move or delete portions of or add to the websites at any time with or without notice.

Intellectual property

All copyright and other rights (including database rights, trademarks (whether registered or unregistered) and all other intellectual property rights) in and to the websites and their contents (which for the avoidance of doubt shall include all data contained in or available from the websites (“the Contents”)) are owned by or licensed to Tatton or are otherwise used by us as permitted under applicable laws. Unless we explicitly state otherwise in writing, you may use, view, download, copy, or print textual or graphic content of the websites if it is solely used by you for the purpose of enquiring about the services provided by us and if you do not change or delete any copyright, trademark, or other proprietary notices on such content.

Under no circumstances may you use any Content in a manner that may give a false or misleading impression of Tatton.

You agree not to copy, reproduce, store in any medium (including in any other websites), distribute, transmit, modify, alter, disseminate, create derivative works from all or any part of any of the websites or edit any part of any of it other than as permitted above without obtaining our prior written consent.

Specific Prohibitions

You may not use any device, software, or routine to interfere or attempt to interfere with the proper working of the websites nor may you attempt to decipher, de-compile, disassemble or reverse engineer any of the software comprising or in any way making up a part of any of them.

You agree to use the websites for lawful purposes only and so that it does not infringe the rights of, or restrict the use of the website for any third party.

Liability

The websites and their Contents are provided for general data purposes only and whilst Tatton has taken every care in the preparation of them, we cannot guarantee that the Contents will be completely up to date and free of mistakes. To the extent permitted by applicable law Tatton makes no warranties, representations and/or undertakings (express or implied) in respect of the websites and their Content (including the accuracy, reliability, suitability, quality, availability, or completeness thereof). We exclude all liability (other than for death or personal injury caused by its negligence) in relation to the websites and their Contents, whether such liability arises in contract, tort, negligence, breach of statutory duty or otherwise (including, without limitation, liability in respect of any losses, damages, costs or expenses of any nature whatsoever incurred or suffered by you of an indirect or consequential nature, such as loss of profits, data, business or goodwill).

We make no claims or representations that any or all the Contents may be lawfully viewed or downloaded outside England and Wales and unless otherwise specifically stated, the Contents and the website are directed solely at consumers and/or businesses that access the websites from England and Wales. Access to such materials may not be legal by certain persons or in certain countries. If you choose to access the websites from outside England or Wales, you do so at your own risk and are responsible for compliance with the laws of your jurisdiction.

Computer Viruses and Errors

Tatton will use reasonable efforts to ensure that the websites does not contain or promulgate any errors, viruses, bugs, other malicious code, or harmful components and will be uninterrupted. However, we cannot guarantee that this will be the case.

We recommend that you should virus check all materials downloaded from the websites and regularly check for the presence of errors, viruses, bugs, other malicious code, and harmful components.

Tatton excludes to the fullest extent permitted by applicable laws all liability (other than liability for death or personal injury caused by our negligence) in connection with any damage or loss caused by errors, viruses, bugs, other malicious code or harmful components originating or contracted from the website and any interruptions in its running.

Termination

Tatton shall have the right to immediately terminate your use of the websites if we determine (in our sole discretion) that you have breached these terms and conditions or have otherwise been engaged in conduct which we consider to be unacceptable.