PRIVACY POLICY

 

This notice describes how Broad Street Investment Management (Broad Street) will collect, use and protect your personal data. It outlines Broad Street's data protection obligations and your data protection rights under the regime introduced by the EU General Data Protection (Regulation 2016/679, the "General Data Protection Regulation").

 

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.

 

Broad Street Investment Management needs to use your personal data to provide its services to you, so this notice outlines the following points about the processing of your personal data:

 

  • which data items are used, how they are used and who they are shared with;

  • why this is done and the lawful basis;

  • your rights and Broad Street's obligations.

 
Why Broad Street needs to process personal data:

 

Your Data is collected to effectively and properly manage your account(s) with us. Data is stored for specific purposes and only data that is relevant to that purpose will be stored. We will use the Data for several different purposes, including:

 

  • to provide our services and to carry out obligations arising from any agreements entered into between you and Broad Street;

  • to provide you with information, products or services that you request from us (including through our website) or which we feel may interest you, where you have consented to be contacted for such purposes;

  • to make our procedures more efficient, to implement security measures and to combat fraud and other crimes;

  • to competent authorities (including tax authorities), courts and bodies as required by law or requested or to affiliates for internal investigations and reporting and

  • to notify you about changes to our products and services and your investments.

 

If at any time you wish to be removed from marketing mailing lists or for any limits to be applied with respect to marketing materials received by you, please let us know. You can do this by e-mailing your relationship manager or our data protection officer. Contact details are available at the bottom of this notice.

 
How we collect information

 

Broad Street may collect data:

 

  • when you or an agent of yours contacts Broad Street by phone, Email or post in relation to business and services offered;

  • when you complete documents or forms during the course of business with Broad Street;

  • from Service Agents and other third parties that assist us in conducting business;

  • when you use the Broad Street website or online services.

 

The Data that is collected or held in relation to you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who works for us or for one of our Service Agents. In some cases, the laws of the destination country may not provide the same level of data protection as countries within the EEA. However, all Data wherever they are held by Broad Street will be afforded a high level of protection against any unauthorised or accidental disclosure, access or deletion. By submitting your Data, you agree to this transfer, storing or processing.

 

Unfortunately, the transmission of information via the internet is not completely secure. Although Broad Street will do its best to protect your Data, we cannot guarantee the security of your Data transmitted electronically. Any such transmission is at your own risk.

 

The Information we collect, hold and process about you

 

During Broad Street's relationship with you we will collect and process Data about you, including:

 

  • Title

  • Full name and residential address and previous address.

  • Telephone contact number(s).

  • Email address

  • Date of Birth

  • National Insurance Number

  • Country of Residence

  • Expected Retirement Age

  • Whether you are married or in a registered civil partnership

  • Spouse's or registered civil partner's date of birth

  • Details of children including date of Birth

  • Employment Status

  • Employer's name and address

  • Financial information about you and your family

  • Your personal bank details

  • Agent details

  • Supporting information to verify your identity and address

  • Outcome of identity searches and anti-money laundering due diligence

  • All communications to and from you by telephone, email, post or otherwise

 

Cookies

This site and associated domains use cookies and similar technologies with the aim of understanding more about users and improving the website experience on an ongoing basis. More information on cookies is available at: www.allaboutcookies.org and www.youronlinechoices.eu.

Session (Transient) cookies: These cookies are erased when you close your browser, and do not collect information from your computer. They typically store information in the form of a session identification that does not personally identify the user.

Persistent (Permanent or Stored) cookies: These cookies are stored on your hard drive until they expire (i.e. they are based on a set expiration date) or until you delete them. These cookies are used to collect identifying information about the user, such as Web surfing behaviour or user preferences for a specific site.

This site also uses Google Analytics, a cookie-based software tool, to collect information on how users interact with the site, which includes data on devices used to gain access, the pages visited and the paths used to enter and exit the site. More information on Google Analytics’ data practices and commitment to protecting the confidentiality and security of data can be found here. https://support.google.com/analytics/answer/6004245.

You can set your browser to not accept cookies any time. We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website.

Disclosure of your information

 

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

 

  • Any member of the Broad Street Group.

  • Agents selected by you and for whom you have given prior consent for us to share personal information.

  • Any third party in order to meet our legal and regulatory obligations, including statutory or regulatory bodies, law enforcement agencies, credit reference agencies and company auditors.

  • Our service providers and agents or third parties who process information on our behalf.

 

Data retention

 

Broad Street will retain your personal information for a period of up to seven years following the point where the business relationship has ceased.

 

It may be necessary to retain your personal information beyond this period depending on additional legal/regulatory obligations. Thereafter, Broad Street will refrain from collecting any further personal information on you and shall take appropriate steps to dispose of any records containing your personal information to the extent this is operationally feasible and proportionate.

 

Data subject rights

 

You have the following rights, in certain circumstances, in relation to your personal information:

  • Right to access your personal information (in an easily readable form);

  • Right to rectify your personal information;

  • Right to restrict the use of your personal information (in certain specific circumstances);

  • Right to request that your personal information is erased (in certain specific circumstances). Please note that the right for your data to be erased (the "right to be forgotten") that applies in some contexts under the General Data Protection Regulation is not likely to be applicable to most, if not all, of the personal information you provide to Broad Street Investment Management, given the specific nature of the purposes for which Broad Street Investment Management uses the data, as described above

  • Right to object to processing of your personal information (in certain specific circumstances);

  • Right to data portability (in certain specific circumstances);

  • Right to withdraw consent (in certain specific circumstances); and

  • Right to receive information regarding any entities we disclose your data to.
     

Where Broad Street requires your personal information to comply with AML or other legal requirements, failure to provide this information means Broad Street will not be able to accept you as a client or investor.

 

Broad Street will notify you of any personal information breach affecting you that is likely to result in a high risk to your rights and freedoms.

 

Changes to this notice

 

Broad Street will need to update its privacy notice in response to regulatory requirements or changes to its business. The latest notice will always be available on the Broad Street website.

 

How to contact Broad Street

 

Under the GDPR, data subjects can make a complaint to the supervisory authority including the Member State in which they reside or work or the place of the alleged infringement.

 

If you have any questions or concerns about personal data or this privacy policy or you wish to make a complaint about how Broad Street has processed your personal data, please contact Broad Street in writing by post at the following address:

 

Data Protection Officer
Broad Street Investment Management Ltd
Loretta Lodge
Tilley Lane
KT18 6EP

 

Broad Street Investment Management
Loretta Lodge,

Tilley Lane,

Headley,

Surrey,

KT18 6EP

E: info@broadstreetim.com
T: +44 (0)203 962 8613

Broad Street Investment Management Ltd is an appointed representative of Thornbridge Investment Management LLP which is authorised and regulated by the Financial Conduct Authority.

© 2019 Broad Street Investment Management. All rights reserved.

 

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