TM Asset Management Ltd (“we” “us” “our”) is committed to protecting and respecting your privacy. We are the data controller and will process your personal data in accordance with the Data Protection Act 1998 as amended or replaced by the General Data Protection Regulation 2016 and any national laws which relate to the processing of personal data (“data protection legislation”).
Please read the following carefully to understand our views and practices regarding Your Data and how we will treat it.
This policy applies to information we collect about:
We may collect and process personal data about you in the following circumstances:
We may also collect data in the following ways:IP Address
We may collect information about your device, including where available your Internet Protocol address, for reasons of fraud protection. We may also collect information about your device’s operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.Cookies
We may use your personal data for our legitimate interests in order to:
Our Site may, from time to time, contain links to and from the websites of third parties. Please note that if you follow a link to any of these websites, such websites will apply different terms to the collection and privacy of your personal data and we do not accept any responsibility or liability for these policies. Please check before you submit your information to these websites.
We will collect details such as name, address, email address, contact number, date of birth, national insurance number and financial information in order to provide services to clients. We may also receive details of credit checks undertaken where you have supplied these to us.
We will share client personal information with our employees to manage our relationship with you and we will retain client personal data in accordance with the guidelines set down by our Regulators.
We will use your personal data provided to comply with our contractual obligations arising from the agreements we enter into with our Clients and share the data with financial institutions who can assist in the provision of financial services to clients including product providers, lenders, banks, insurers, fund managers, platform providers and third party compliance advisers.
We will use client personal data for our legitimate interests including:
We will not transfer any client personal data outside the European Economic Area (“EEA”).
We will collect details such as contact names, address, email address and telephone number in order to contact you about goods and/or services we have ordered from you, to comply with our contractual obligations and to place further orders. We may share your personal data with our employees to manage our relationship with you and we will keep your personal data for as long as we require your goods and/or services subject to guidelines set down by our Regulators. We will not transfer your personal data outside the EEA.
We may use client personal data to provide you with details about our services, and business updates and events which we think may be of interest.
You have the right to opt-out of receiving this information at any time. To opt-out of receiving such information you can:
Where you have subscribed to receive marketing correspondence from us we will keep your personal data according to the guidelines set down by our Regulators from when you subscribed to receiving marketing information from us or until you unsubscribe from receiving such correspondence from us (whichever is earlier).
In accordance with data protection legislation we are required to notify you of the legal basis upon which we process your personal data. We process your personal data for the following reasons:
We will also process your personal data including personal sensitive data where we have obtained your explicit consent.
In addition to the third parties mentioned previously in this policy, we may disclose your personal data to third parties for the following legitimate business purposes:
We may disclose your personal data to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our agreements; or to protect our rights, property, or safety of our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We will not sell or distribute your personal data to other organisations without your approval.
We do not transfer personal data outside the EEA. Where this is required in the future, we will ensure that safeguards are in place so that such transfers comply with data protection legislation.
Information you provide to us is shared on our secure servers. We have implemented appropriate physical, technical and organisational measures designed to secure your information against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our Site; any transmission is at your own risk.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data we hold about you changes. Data protection legislation gives you certain rights in relation to your personal data. You have the right to object to the processing of your personal data in certain circumstances and to withdraw your consent to the processing of your personal data where this has been provided.
You can also ask us to undertake the following:
We may request specific information from you to help us confirm your identity. Data protection legislation may allow or require us to refuse to provide you with access to some or all the personal data that we hold about you or to comply with any requests made in accordance with your rights referred to above. If we cannot provide you with access to your personal data, or process any other request we receive, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Please send any requests relating to the above to our Data Privacy Officer specifying your name and the action you would like us to undertake. Note that in relation to requests to access personal data, we reserve the right to charge a reasonable fee to comply with your request.
Where you have provided your consent to the collection, processing and transfer of your personal data, you may withdraw that consent at any time. This will not affect the lawfulness of data processing based on consent before it is withdrawn. To withdraw your consent please contact us.
Last updated: 25 May 2018.