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Edward T James & Company Privacy Policy

Introduction

The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union. It also addresses the export of personal data outside the EU. … The GDPR replaces the 1995 Data Protection Directive.

Principles of GDPR:

Article 5 of the GDPR requires that personal data shall be:

a) processed lawfully, fairly and in a transparent manner in relation to individuals;

b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;

e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and

f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

Article 5(2) requires that:

the controller shall be responsible for, and be able to demonstrate, compliance with the principles.

 

Edward T James & Company GDPR Privacy Statement

We respect privacy and your rights to control your personal data. Our principle guidelines are simple. We will be clear about the data we collect and why. Your data is sacredly protected by us. We do not and will not sell your data to third parties.

The prime purpose of collecting your data is to provide you with the most effective financial advice, or offer highly responsive customer support when something goes wrong.

This Privacy Statement (the ‘Statement’) explains the personal information we collect from you, either directly or indirectly, and how we will use it. Personal information is any information that can be used to identify you or that we can link to you. The Statement also elaborates on the choices you can make about the data we collect, and how you can control these decisions. It applies to all products offered by Edward T James & Company. It also applies to any Edward T James & Company related websites, as well as other offline interactions, such as visiting the Edward T James & Company office or attending a Edward T James & Company event (collectively referred to as, ‘Services’). Please read this Statement carefully to understand how Edward T James & Company may collect, use and share your personal information. The terms ‘we’, ‘us’, or ‘Edward T James & Company’ are each intended as reference to Edward T James & Company Ltd.

The Types of Personal Information We Collect

Information you provide to us

We collect information you voluntarily provide to us, such as your name, phone number and email address; for instance, when you want to learn more about Edward T James & Company Services or when you contact us for assistance.

Information we collect automatically

We automatically collect information about you, such as fund information. We may, for example, collect information about your general geographic location and whether you interact with content available on our websites and how.

Information obtained from other sources

We may receive information about you from other sources, including third parties, such as service partners and partners with whom we offer co-branded services or engage in joint-marketing activities. We may also receive information about you from social media platforms, for instance, when you interact with us on those platforms. We protect data obtained from third parties according to the practices described in this Statement and we also apply any additional restrictions imposed by the source of data.

Information of children

Edward T James & Company does not target and is not intended to attract children under the age of sixteen.

Customer Interactions with Edward T James & Company

To make the information in this Statement easy to understand, we have highlighted different occasions when Edward T James & Company could potentially collect personal information from clients. The client interactions with Edward T James & Company are broken down into the following segments:

Buying Products Edward T James & Company Recommends

Once you have decided to accept a Edward T James & Company recommendation, you will be asked to provide information so that we can complete the transaction suitably.

We collect: all the information needed to ensure we can make a suitable recommendation to you. This information is contained within a ‘client fact finding document’, and notes that we make.

Why: We use this information to assess your situation, needs and objectives and make a suitable recommendation. Processing your personal data for this purpose is necessary for the agreement we have with you. Please note, we do not store any payment or credit card information.

Updating your Edward T James & Company Recommendations

Once you receive documents from our recommendation, you will receive regular updates from the provider and we will initiate a regular financial review with you, at which time we will check up on the relevance and accuracy of the data we hold about you.

Doing Business with Edward T James & Company

There are three main reasons we collect information from you: (1) to offer you services which are necessary for the performance of the agreement we have with you, (2) to offer you control over your Edward T James & Company recommendations which is necessary for the performance of the agreement we have with you, and (3) to make your financial plan better over time which is our legitimate interest.

Functional Data:

This data is absolutely necessary for Edward T James & Company to perform its basic functions in a secure way and you will not be able to opt out from this data collection, sharing and/or processing if you want to continue to use Edward T James & Company.

Why we collect Functional Data: We collect this information to help ensure that your Products are working properly, to provide you with client support, and to guide product improvement and client support decisions. We also collect this information to guide product improvement and client support decisions which is our legitimate interest.

Getting Help from Edward T James & Company

From time to time, you may decide to contact us for assistance. To be able to offer you the best service possible, we may collect certain data from you or your Edward T James & Company Products.

We collect: This may include contact information, such as your name, email address, phone number, social media identifiers (if you contact us using a social media channel), and the content of your chats and other communications with Edward T James & Company .

Why: We collect this information to give you the best and most efficient client support possible. For instance, for client inquiries and technical questions, we use contact information to respond to the customer in their preferred channel (phone, email, social). Using these types of data is necessary to fulfil the agreement we have with you.

How We Use Personal Information

Edward T James & Company uses the data we collect to provide you with the Products and Services we offer, which includes using data to improve and personalise your experiences. We also use the data to communicate with you, for example, informing you about your account, new products or services available, security and other types of updates.

Edward T James & Company uses the data for the following purposes:

  • Providing our Product Experience
  • Client Support
  • Product Improvement
  • Security, Safety, and Dispute Resolution
  • Business Operations
  • Communication, Marketing and Advertising
Providing our Product Experience

We use data to provide, operate, support and improve the Edward T James & Company Products and Services we offer. This processing is necessary for the performance of the agreement we have with you.

Customer Support

We use data to respond to client enquiries, diagnose problems and provide other client care and support services. This processing is necessary for the performance of the agreement we have with you, as well as to serve our legitimate interest.

Product Improvement

We continually use data for research purposes and to develop and improve our Edward T James & Company Products and Services, including maintaining and improving the performance of our Edward T James & Company Products and Services, developing and adding new features or capabilities. This processing is necessary to serve our legitimate interest.

Security, Safety and Dispute Resolution

We use data to protect the security and safety of our Edward T James & Company Products and our clients, to detect and prevent fraud, to resolve disputes and enforce our agreements. This processing is necessary to serve our legitimate interest.

Business Operations

We use data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business. This processing is necessary to serve our legitimate interest.

Communication, Marketing and Advertising

We use the data we collect to deliver and personalise our communications with you. For example, we may contact you by email or other means of electronic communication (including through the Edward T James & Company app when established) to inform you about new Edward T James & Company Products or Services, security or software updates, update you on a support issue, invite you to take part in a survey. This processing is necessary to serve our legitimate interest. For information about managing email and promotional communications, please refer to our client agreement or call us to discuss.

How We May Share Personal Information

Edward T James & Company does not and will not sell personal information about our clients. We only disclose your data as described in this Statement. We may share information with the following types of third parties.

Third Party Vendors

Edward T James & Company uses a variety of third-party vendors to carry out services like website management and hosting, online Product services and email communications. We only share your personal data as necessary. To complete a transaction, provide a Product or Service you have requested or authorised and only with vendors or agents working on our behalf for the purposes described in this Statement. In this case, your personal information will be shared with these agents or contractors but only for the purpose of performing services on behalf of Edward T James & Company and in accordance with this Statement. It is our legitimate interest to process your personal data for these purposes. For questions about third-party vendors, please email Edward T James & Company at: enquiries@edwardtjames.co.uk

Edward T James & Company-controlled affiliates and subsidiaries

We do not have any affiliates or subsidiaries at this time. However, in the future we may share information with Edward T James & Company-controlled affiliates and subsidiaries for business purposes, such as, internal administration, promoting Edward T James & Company services and providing clients with our Edward T James & Company Services. It is our legitimate interest to process your personal data for these purposes.

Compelled Disclosure

When legally required, strictly necessary for the performance of the services or to protect our rights, or the rights of our affiliates or users, we disclose your personal information to law enforcement authorities, investigative organisations, our affiliates or in legal proceedings.

Sale or Merger

We may share your personal information in the event of a merger, acquisition, or sale of all or a portion of our assets. Of course, we shall notify you and inform you of your rights.

Sharing and Disclosure of Aggregate Data

We share data in aggregate form and/or in a form which does not enable the recipient of such data to identify you, with third parties, for example, for industry analysis.

Please note, our services may include links to Products or services of third parties whose privacy practices may differ from Edward T James & Company. If you provide personal data to any of those third parties or their products, your data is governed by their privacy statements, and we encourage you to read these privacy statements carefully.

When sharing data with third parties, your personal information may be transferred to countries where data protection laws may provide a lower standard of protection for your personal information than your country. We take great care in protecting your personal information and have put in place adequate mechanisms to protect it when it is transferred internationally. We will transfer your personal information in compliance with applicable data protection laws and will implement suitable safeguards to ensure that your personal information is adequately secured by any third party that will access your information (for instance, by using the Standard Contractual Clauses as approved by the European Commission). If you have questions or wish to obtain more information about the international transfer of your personal information or the implemented safeguards, please send us an email.

The Legal Bases for Using Personal Information

There are different legal bases that we rely on to use your personal information, namely:

Performance of a contract

The use of your personal information may be necessary to perform the agreement you have with us. For example, to complete the transaction of your Edward T James & Company recommendation, to register and maintain your account and to make sure that your Edward T James & Company recommendation performs its basic functions in a secure way or to respond to your requests.

Legitimate interests

We may use your personal information for our legitimate interests. For example, we rely on our legitimate interest to analyse and improve our Services and the content on our websites and app, to send you notifications about updates or information about Edward T James & Company Services or to use your personal information for administrative, fraud detection or legal purposes.

Where we process your personal information based on our legitimate interest and no opt-out mechanism is available to you (e.g. in your Edward T James & Company Product settings), you may exercise your right to object by sending an email to: enquiries@edwardtjames.co.uk

Security, Storage and Retention of Personal Information We Collect

Security

Edward T James & Company is committed to protecting the security of your personal information. However, while we take reasonable precautions to guard the personal information we collect, no security system is impenetrable.

While no Service is completely secure, Edward T James & Company takes precautionary measures to help prevent information about you from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction. For example, we store the personal data you provide on computer systems that have limited access and that are in controlled facilities. We also ensure that our third-party data centre vendors provide adequate security measures. Additionally, your data is protected with encryption, such as Transport Layer Security (TLS), during transition over the Internet.

You can only access your Edward T James & Company account information and our service through the use of an individual user login and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please notify us immediately if you believe your password has been misused. You should always log out and close your browser when you finish your session. Please note, we will never ask you to disclose your password in an unsolicited phone call or email.

If you have any questions about the security of your personal information, you can contact us.

Storage

Personal data collected by Edward T James & Company may be stored and processed in your region, or in any other country where Edward T James & Company or its affiliates, subsidiaries or service providers are located or maintain facilities. Edward T James & Company has put in place adequate mechanisms to protect personal information when it is transferred internationally, for example by using the Standard Contractual Clauses as approved by the European Commission.

Retention

Edward T James & Company will retain your personal information for as long as we deem it necessary to enable Edward T James & Company to provide services to you, to comply with applicable laws (including those regarding document retention), resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. All personal information we retain will be subject to this Privacy Statement and our internal retention guidelines. If you have a question about a specific retention period for certain types of personal information we process about you, please send an email to: enquiries@edwardtjames.co.uk

Your Rights and Choices

Your Rights

We want you to be in control of how your personal information is used by us. Subject to local law, you can do this in the following ways:

  • you can ask us for a copy of the personal information we hold about you;
  • you can inform us of any changes to your personal information, or if you want us to correct any of the personal information we hold about you;
  • in certain situations, you can ask us to erase, block or restrict the personal information we hold about you, or object to particular ways in which we are using your personal information; and
  • in certain situations, you can also ask us to send the personal information you have given us to a third party.

Where we are using your personal information on the basis of your consent, you are entitled to withdraw that consent at any time. Moreover, where we process your personal information based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal information.

We rely on you to ensure that your personal information is complete, accurate and up to date. Please do inform us promptly of any changes to or inaccuracies in your personal information by contacting us.

We will respond to your request as soon as possible but certainly within 30 days.

Your Choices

Your Communication, Marketing and Advertising Preferences

We do not market or advertise to our existing clients

Please note, regardless of your communication settings, we will continue to communicate with you regarding changes to terms and conditions, policy updates, routine customer service messages such as information about current or past purchase, service interruptions, data breaches or other significant information about a Product you hold, such as discontinuation of support or safety issues.

How to Contact Us

If you have any questions about the use of your personal information, please email us at: enquiries@edwardtjames.co.uk

Unless otherwise stated, Edward T James & Company is a data controller for personal data we collect through our Services subject to this Privacy Statement. Our address is:

4c Falmouth Business Park, Bickland Water Road, Falmouth TR11 4SZ

Changes to Our Privacy Statement

Edward T James & Company may modify or update this Statement when necessary, to reflect customer feedback and changes in our Edward T James & Company Products and Service. Please review it regularly. When we update this Statement, we will revise the ‘Last Update’ date at the top of the Statement. If there are material changes to the Statement or in how Edward T James & Company uses your personal data, we will inform you either by posting a notice of such changes, prior to them taking place, or by directly sending you a notification. We encourage you to regularly review this Statement to learn more how Edward T James & Company is using and protecting your information.

FAQ

The following are basic questions you may have about our privacy statement. We recommend that you read the detailed statement above for additional details.

Why is Edward T James & Company updating its privacy statement?
We now meet the high standards required by the European Union’s General Data Protection Regulation (GDPR) and have updated our privacy statement to reflect that. We also strive to simplify language and remove jargon, to make our privacy statement easier to read and understand.

What is the GDPR?
The GDPR is a regulation intended to strengthen and unify data protection for everyone within the European Union (EU). The GDPR requires greater openness and transparency from companies on how they collect, store and use personal data, while also imposing tighter limits on the use of personal data.

How often do you anticipate updating your privacy statement?
We will update our privacy statement as necessary to ensure that our policies are in line with international regulations, our product and business practices.

How is my information used?
Edward T James & Company uses data for the following purposes:

  • Service Improvement
  • Future Service Development
  • Client Support
  • Security, Safety, and Dispute Resolution
  • Service Performance Analysis
  • Communication and Marketing

Does Edward T James & Company sell information to third parties?
No. We never have. And we never will.

Can I opt out of sharing my information with Edward T James & Company?
Yes, you can opt out of submitting certain types of personal information to Edward T James & Company. Certain types of data that we collect are a necessity and you will not be able to opt out from this data collection, sharing and/or processing (‘Functional Data’).

How do I delete my personal data from Edward T James & Company and what are the consequences?
You can always send us an email via: or contact us and request that your data be deleted. Please note, however, that by deleting your personal data your service from Edward T James & Company may be affected.

How long does Edward T James & Company keep my information?
Edward T James & Company retains personal data for as long as necessary to provide Services, support your Product and fulfil transactions you have requested, or for other essential purposes such as complying with our legal obligations, and resolving disputes and enforcing our agreements. Because these needs can vary for different data types in the context of different Products or Services, actual retention periods can vary significantly. For example, we will keep all functional data on file for at least as long as you have an active relationship with Edward T James & Company.

How is information stored and secured on Edward T James & Company’ servers?
Edward T James & Company is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorised access, use or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. Any data we transmit over the internet is protected using encryption.

What safeguards are in place for children who have access to Edward T James & Company products?
Edward T James & Company does not target and is not intended to attract children. Edward T James & Company does not knowingly solicit personal information from children or send them requests for personal information.

How can I contact Edward T James & Company if I have questions regarding Edward T James & Company privacy statement?
If you have any questions about the use of your personal information, please send us an email to:

enquiries@edwardtjames.co.uk

 

 

Version 1 21/05/2018