PRIVACY POLICY - PROTECTING YOUR DATA

1. Who are Throgmorton UK Limited?
Throgmorton UK Limited (“Throgmorton”) is part of Link Asset Services (“Link”) a trading name of companies which offer a range of services, principally shareholder, treasury management, banking, debt, fund and corporate administration services. Please refer to the “Legal and Regulatory Status” page on the Link Asset Services website (https://www.linkassetservices.com/) for more details on the trading companies in the Link Asset Services division.  All of the companies are wholly owned subsidiaries of Link Administration Holdings Limited (“Link Group”). For more information on Link Group, please visit www.linkgroup.com. For more information on Throgmorton please visit www.throgmorton.co.uk.

2. What is this Privacy Policy?
At Throgmorton we collect personal information about you and are committed to protecting this information and your privacy. Set out below is an explanation of how we use, collect and safeguard your personal information. This Privacy Policy applies where Throgmorton receives personal data through its website, or in connection with any services that we are engaged to provide to you (“Services”).
 
3. What personal information do we collect?
You may provide us with your personal information where you enter your personal information via our website, engage with us in respect of our Services, or correspond with us by phone, email or otherwise. It is provided entirely voluntarily.
Depending on the Services or information you request from us, we may ask you to provide the following personal information:
• name, date of birth, address, email address, telephone number and other contact details;
• bank account details or other payment or financial information;
• information about your personal circumstances including employment, business interests, property or other assets, or other information about you which we require to provide you with particular aspects of our Services.

We may keep a record of any correspondence you have with us, including certain telephone calls which we may be legally required to record (but we will inform you at the beginning of the telephone conversation if recording will be necessary).

With regard to each of your visits to our website we may automatically collect technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.

We may receive information about you from a third party source in connection with our Services. For example, we may receive information about you from your employer or company in order to provide you with personal tax advice or provide you directly with any other aspects of our Services.

We may, from time to time, receive information about you from other companies in the Link Group or our network, or from publically available sources. We may use this information in connection with our marketing activities (subject to section 11 below).

4. Why do we collect your information?
We collect your information in order for you to use our website, to provide any Services to you, and to carry out our marketing activities (subject to section 11 below).
 
In addition, we are required by law to obtain “know your client” information as detailed in our terms of engagement for our Services, and this includes certain personal information including information contained in a formal identification document or social security or other unique reference relating to you.

5. How we use your personal information?
We will use the information we hold about you for the following purposes:

In connection with a CONTRACT for Services with you

We will use and process your personal information where we have supplied you (or continue to supply you) with Services, where we have arranged for the supply of another company’s Services to you, or where you are in discussions with us about any new service.  We will use this information in connection with our contract with you for the supply of those Services, (or when it is needed to enter into the contract); and so that we can communicate with you in relation to those Services (including notifying you of any changes to our Services).
 
Where you have provided CONSENT
 
We may use and process your personal information where you have consented for us to do so in connection with our marketing activities (see section 11 below).

You may withdraw your consent for us to use your information in this way at any time. Please see Withdrawing your consent in section 9 for further details.

Where it is necessary to comply with a LEGAL OBLIGATION

We may use, store and share your information where we are under a legal obligation to do so. This may include use of your information:
• to verify your identity;
• in connection with any legal obligation on us to report any fraud or other criminal activity (including money laundering or tax avoidance schemes);
• in connection any with workforce pensions assessment, where we are engaged to make this assessment on behalf of your employer.

Where we have a LEGITIMATE INTEREST  

We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes:
• analysis to inform our marketing strategy, and to enhance and personalise your client experience;
• for the detection and prevention of fraud and other criminal activities;
• marketing activities (other than where we rely on your consent to contact you by email or text with information about our products and services or share your details with third parties to do the same);
• to verify the accuracy of data that we hold about you and create a better understanding of you as a client;
• network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
• to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
• assess and improve our service to clients through recordings of any calls; and
• management of queries, complaints, or claims.

6. Who we share personal information with?
We will only disclose your personal information in accordance with applicable laws and regulations. We may disclose your information to the following third parties:
• your employer (to the extent your employer is engaged by us as a Client for our services);
• any person with legal or regulatory power over us (such as the Financial Conduct Authority, HMRC, the police or the National Crime Agency or the Serious Fraud Office that may require disclosure on legal grounds);
• service providers engaged by us to help us run our business and perform the Services. Such service providers may include, for example, cloud or archive storage providers (engaged by us to provide electronic or physical storage facilities for our business data and your information), or providers of software or other IT resources;
• any member of the Link Group which means our subsidiaries, our ultimate holding company and its subsidiaries (from time to time) as necessary to perform the Services.

Some of these third parties (including Link Group subsidiaries and service providers) may be outside of the European Economic Area (EEA). If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection. Please contact us using the details at the end of this policy for more information about the protections that we put in place.
 
7. How do we keep your information secure?
We store the information you provide about yourself in a secure database and take appropriate security measures to protect such information from unauthorised access.  For example, we have adopted internal data protection procedures and trained our staff on them with a view to preventing breaches of security.  Where we make available to you any online portal or web-hosted platform to provide any Services to you, all exchanges of information between you and any such portal or platform go through encrypted channels in order to prevent interception of your information. Public access to your information via and any portal or platform is protected by a login using your user ID and password. You should ensure that these are kept secret and not divulged to other people.

You recognise that that your use of our website is entirely at your own risk. As the Throgmorton website is grouped to the internet, which is inherently insecure, Throgmorton cannot guarantee the information you supply will not be intercepted while being transmitted over the internet.  Accordingly, Throgmorton has no responsibility or liability for the security of personal information transmitted via our website.

8. How long will we store your information for?
We generally hold your personal data on our systems for as long is necessary to provide the Services.  This is ordinarily 6 years from the date you cease to use the Services or the termination of our Agreement in order to allow us to refer to your information in correspondence with you, or in connection with legal or regulatory proceedings.
 
9. Your rights
You have the following rights in relation to how we use your information. If you’d like to exercise these rights please contact us using the contact details listed at section 14 “Who can you speak to at Throgmorton about this Privacy Policy?
• Right of access – you have the right to know if we are using your information and, if so, the right to access it and information about how we are using it. 
• Right of rectification – you have the right to require us to rectify any errors in the information we hold about you.
• Right to erasure – you have the right to require us to delete your information if our continued use is not justified.
• Right to restrict processing - in some circumstances, although you may not be entitled to require us to erase your information but may be entitled to limit the purposes for which we can use your information.
• Right of data portability – you have the right to require us to provide you with a copy of your information in a commonly used machine-readable format or to transfer your information directly to another controller (e.g. a third party offering services competing with ours).

Where we rely on your consent as the legal basis for processing your personal information, as set out under section 5, you may withdraw your consent at any time.  If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so by clicking HERE. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

10.  How does the Throgmorton website use my Internet Protocol (IP) address and collect cookies?
Like many other websites, we use Cookies to help us gather and store information about visitors to our website. 

We may collect information about your computer, including your IP address, operating system and browser type, for system administration and our own internal purposes.  This is statistical data about our website users’ browsing actions and patterns, and does not identify you as an individual. 

A Cookie is a small text file that is downloaded on to your computer’s hard disk when you access certain websites. Cookies allow the website to recognise your computer. A Cookie can identify the pages that are being viewed and this can assist us to select the pages that the visitor sees. 

“Session” Cookies only exist whilst visitors are online on a particular occasion. These are temporary Cookies that aid your journey around the Site and remember the preferences you have selected during your session. 

"Persistent" Cookies, which are not session-based, remain on a visitor’s computer, so that you can be recognised as a previous visitor when you next visit our Site. This allows us to collect information about your browsing habits whilst on our website, and this can be useful in assisting us to monitor and improve our services. 

We do not store sensitive information such as account numbers or passwords in persistent Cookies and Cookies in themselves do not contain enough information to identify you. You will only become personally identifiable in relation to your browsing habits after you have formally provided us with your personal data for the purposes outlined in section 3 “What personal information do we collect? above.

In addition to using Cookies, we might also use GIFs and other web tools, such as Google Analytics, to collect information about your browsing activities whilst on our website. In this respect the information that is provided is similar to the information supplied by Cookies, and we use it for the same purposes.

Any information that we acquire about you using Cookies, GIFs, or other web tools is subject to the same restrictions and conditions as any other information we collect about you, as outlined in this Policy.
 
THE COOKIES USED ON OUR SITE

Cookies set by our Site:

_e-privacy
This Cookie is set in order to work out whether you have seen and/ or clicked the “dismiss” button in the box that draws your attention to this Policy. This will appear the first time you enter our website. This Cookie is strictly necessary in order to enable you to provide your consent for us to set Cookies on your browser.

_dm_lt_s_c
This is a functional session Cookie used to manage the pages and recognise visitors who return to the website.

Cookies set by Google:

_utma, _utmb, _utmc, _utmz, or others within the range _utma to _utmz.
Google Analytics is a web analytics service provided by Google, Inc. By default, Google Analytics sets four performance Cookies in order to evaluate your use of the website, including number of visits, duration of browsing and referring sites, and compiles reports for us on activity on the website. All information these Cookies collect is aggregated and therefore anonymous.

PREF, NID
Google Maps uses these Cookies in order to embed the Map in the Contact Us part of our Site. These Cookies help us manage the performance and design of the Site and provides the visitor with interactive maps within our Site.

Google stores the information collected by the Cookie on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google state that they will not associate your IP address with any other data held by Google.

For more information about the way in which Google Analytics uses these Cookies please visit the following link https://developers.google.com/analytics/resources/concepts/gaConceptsCookies

Cookies Set by Dotmailer:

Our website uses a functional session Cookie to provide us with data to track and identify visitors to our website from external sources. This measures our website performance in order to improve usability and user experience. This information is not shared with third parties.

By continuing to use this website, you are consenting to us placing session cookies on your device for the purposes detailed above.  Most users will be able to adjust their internet settings to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these, of course, means that certain personalised services cannot then be provided to that user. Please note that the websites to which this site may be linked may also make use of their own cookies. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

11. Marketing
We respect your privacy and ensure we carry out our direct marketing activities in accordance with applicable laws and guidance.

We may contact you with marketing information by post or by telephone or with targeted advertising delivered online through social media and platforms operated by other companies, unless and until you object.
 
If you are a corporate entity and have engaged us for Services, we may also contact you with marketing information by email or other electronic means unless and until you object. If you are an individual or a member of an unincorporated entity (and except where the following paragraph applies) we will only contact you by email or electronic means with marketing information where you have given us your consent.

Where we have obtained your email address in connection with our contract with you for any Services, or where you have made a positive enquiry about any of our services, we may also contact you with marketing information about similar services by email or other electronic means unless and until you object.

From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.

You have the right to opt-out of our use of your personal information to provide marketing to you by informing us (if we call you by telephone), or by clicking the “unsubscribe link” on any marketing email that we send to you, or by contacting us as set out in section 14 below.

12.  Following links from our websites
Our website may contain links to other sites. Such other sites may also make use of their own cookies and will have their own privacy policies. You should carefully review the privacy policies and practices of other sites, as we cannot control or be responsible for their privacy practices. We do not accept any liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

13. Changes to this Privacy Policy
Please note that this policy will be reviewed and may be changed from time to time so please check the page on our website at www.throgmorton.co.uk occasionally to ensure that you’re happy with any changes. This policy was last updated on 5 April 2018.

14. Who can you speak to at Throgmorton about this Privacy Policy?
Questions, comments and the exercise of your rights regarding this Privacy Policy and your information are welcomed and should be addressed to the Data Protection Officer by email at info@throgmorton.co.uk or by post at 65 Gresham Street, London EC2V 7NQ.
If you wish to make a complaint on how we have handled your personal information, you can contact our Data Protection Officer. If you are not satisfied with our response or believe we are processing your personal information not in accordance with the law you can complain to the supervisory authority in the UK responsible for the implementation and enforcement data protection law: the Information Commissioner’s Office (the “ICO”).  You have the right to complain to the ICO about our collection and use of your information.  You can contact the ICO via their website – https://ico.org.uk/concerns/ - or by calling their helpline – 0303 123 1113.