This website is not intended for children aged under 18 years and we do not knowingly collect data relating to children aged under 18 years.
Our contact details are set out in table 1 below:
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This version was last updated in January 2021.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, or withdraw your consent at any given time, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have signed up for or purchased with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you, as set out in table 3 below:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• where you have consented for us to do so;
• where we need to perform the contract we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• where we need to comply with a legal or regulatory obligation.
See table 4 below to find out more about the types of lawful basis that we will rely on to process your personal data.
We have set out below in table 4 descriptions of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the contact details set out at the top of this Policy if you need details about the specific legal ground(s) we are relying on to process your personal data where more than one ground has been set out in table 4 below:
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by:
· by following the opt-out or “unsubscribe” links on any marketing message sent to you; or
· by contacting us using the contact details set out at the top of this Policy at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.
We 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the contact details set out at the top of this Policy.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may sell Aggregated Data, which has been stripped of any personally identifiable information and which cannot be directly attributed to you, to third parties, some who may use the Aggregated Data to assist us in providing our services, and others who may use that Aggregated Data for their own purposes. Any Aggregated Data that we sell will be completely anonymised, and we will not sell any data that can be attributed to you or otherwise identified as yours. If you do not want your anonymised Aggregated Data sold in this way and for these purposes, you should not use our services.
We may have to share your personal data with third parties in order to provide our services.
We may share your personal data with competition partners who we engage with to market our services.
We may also share your personal information with social media platforms who provide marketing and advertising services, in order to market to and advertise to our audience and potential audiences.
We may also share your personal data with service providers who we engage to work with our business, including but not limited to those providing IT support, administrative support, and professional advice such as legal and financial advisers.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Please contact us using the contact details set out at the top of this Policy if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, regulatory or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements in line with our Retention Policy and Schedule.
In some circumstances you can ask us to delete your data: see clause 1.9.3 below regarding Request erasure below for further information.
In some circumstances we may use your anonymised data indefinitely without further notice to you.
You have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
9.1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
9.2. Request correction of your personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
9.3. Request erasure of your personal data.
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see clause 9.4below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
9.4. Object to processing of your personal data Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
9.5. Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful, but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
9.6. Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
9.7. Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us using the contact details set out at the top of this Policy.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month from receiving the request from you. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated on expected timeframes.
Cookies are small data files of information that a website or mobile application transfers to your hard drive or mobile device to store and sometimes track information about you. Although cookies do identify a user’s device, cookies do not personally identify users.
We may use the following cookies:
1. Strictly necessary cookies: these are cookies that are required for the operation of a website and App, such as to enable you to log into secure areas.
2. Performance cookies: these types of cookies recognise and count the number of visitors to a website and users of an App and to see how users move around in each. This information is used to improve the way the website and App work.
3. Functionality cookies: these cookies recognise when you return to a website or App, enable personalised content and recognise and remember your preferences.
4. Targeting cookies: these cookies record your visit to a website or App, including the individual pages visited and the links followed.
Generally, the strictly necessary cookies and some performance and functionality cookies only last for the duration of your visit to a website or expire when you close an App: these are known as ‘session cookies’. The functionality cookies and some targeting and performance cookies will last for a longer period of time: these are known as ‘persistent cookies’.
Some of the persistent and session cookies used by our website and App may be set by us, and some are set by third parties who are delivering services on our behalf. For example, we use Google Analytics to track what users do on the App so we can improve the design and functionality.
Most websites, mobile devices and apps automatically accept cookies but, if you prefer, you can change your browser, device or app settings to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser or device. To block the IDFA on your iOS mobile device, you should follow this path: Settings > General > About > Advertising and then turn on ‘Limit Ad Tracking’. To block Android ID on your Android device, you should follow this path: Google Settings > Ads and then turn on ‘Opt out of interest-based ads’.
Please note however, that (as with other websites and apps) by blocking or deleting cookies used on our website or App you may not be able to take full advantage of our website or App.
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Thesis Portfolio is a trading name of Pynk One Ltd (FRN 12940786). Pynk One Ltd is an Appointed Representative of Wealthkernel Ltd (FRN 723719) who are authorised and regulated by the Financial Services Authority. As such your deposits and investments may be protected by an investor compensation scheme i.e the FSCS if Pynk One Ltd is unable to meet its obligations.