Website Privacy Statement
 

This privacy notice explains how Full Circle Asset Management Limited (‘we’), whose registered office is at 6 East Point, High Street, Seal, Sevenoaks, Kent, TN15 0EG (company number 02486204) collect, use, disclose, transfer and store your personal information.


We have developed this privacy notice because we want you to feel confident about the privacy and the security of your personal information. We are committed to complying with the data protection laws in the United Kingdom.


When we refer to “personal information” or “personal data" in this privacy notice, we mean information which identifies you as an individual, or is capable of doing so. In the context of this privacy notice, the terms “personal information” and “personal data” may be used interchangeably.


We may hold and use data about you in your capacity as a consumer, business customer, individual, or any other capacity in which you may visit our website. Please read this privacy notice carefully. By clicking ‘I Agree’ when you register in the Loop and continuing to visit our website or use of any of our services, you indicate your agreement to our use of your personal information as set out in this privacy notice.


 

When do we collect information?

 


We will collect information from you when you register with us, apply to use any of our services, become our client, or contact us in person, by telephone, by e-mail or by post. We also collect information from you when you provide feedback or complete a contact form on our website.


We may collect information about you from fraud prevention agencies and other organisations when we undertake checks such as identification verification checks, as explained further below.


Information may also be collected about you when you visit our website (for example via cookies), such as your IP address and other browser-generated information.


We may record and monitor phone calls made to or by us in order to comply with regulatory obligations.


 

What information will we collect?

 


We may collect the following information:


• Your contact details, such as your name, address, telephone number and email address


• Your date of birth, nationality, country of birth, country of residence, employment status and tax identification number (i.e. National Insurance Number)


• Passport details, driving licence and utility bills


• Details of the services you request from us


• Any records held by financial crime prevention agencies, on the Electoral Register and by providers of utility services


• Details of your employment status, income and source of wealth


In some cases, you are not obliged to provide any personal data to us, but if you have requested information or a service from us, we will not be able to provide it without certain information, such as your contact details. Before we can begin providing you with our services, we need to obtain certain information about you, so that we can verify your identity in order for us to meet our obligations under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 and any other applicable legislation and for the purposes of crime prevention and fraud prevention. You are obliged to provide this information and if you do not provide it, we will be unable to provide you with our services.


 

How we will use your information?
 

We use information held about you in the following ways:


• To process your application to use our services


• To undertake checks such as identification verification checks with fraud prevention agencies


• To enable us to comply with our anti-money laundering obligations and for the purposes of crime prevention and fraud prevention


• Automated decision making may be used in order to comply with our KYC/AML checks or to evidence that we are providing a suitable and appropriate service to its clients


• To comply with our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us


• To help protect your information and prevent unauthorised access to it


• To deal with any queries, complaints or problems reported by you


• To generate statistics relating to use of our website, such as the popularity of certain features or services, newsletter readership or pages visited.


• If required to do so by law and to the extent necessary for the proper operation of our systems, to protect us/our clients, or for the enforcement of any agreement between you and us


• To notify you of changes to our services


• To help improve the services we provide to you


Unless otherwise stated in this privacy notice, the legal basis for our use of your personal data will be that this information is required for one or more of the legitimate interests described above.


 

How we protect your information?


We take appropriate security measures (including physical, electronic and procedural measures) to help protect the confidentiality, integrity and availability of your personal information from unauthorised access and disclosure. For example, only authorised employees are permitted to access personal information and they may do so only for permitted business functions. In addition, we use firewalls to help prevent unauthorised persons from gaining access to your personal information.


You are responsible for maintaining the confidentiality of your User ID and password which relate to your access to certain pages of our website or any account you set up with us. You agree to accept responsibility for all activities which occur in relation to the same.


You should not permit other people to use your user ID or password. Please contact us promptly if you believe your user ID or password may have been compromised. We will not be responsible to you if there is unauthorised access to your login details or unauthorised activity on our website as a result of someone else using your login details, unless we caused this to happen because of our negligence.


Despite our efforts regarding security it is important to bear in mind that internet communication, including email, is not secure. The protection of data by encryption is possible, provided that the encryption method (protocol) used is current and the correct procedure for encryption and decryption is followed at all times. We cannot accept any responsibility for unauthorised access by a third party or for the loss, theft or modification of data while it is being sent to us by email. For security purposes we may monitor emails received or issued by us.


 

How long do we keep your information?


We are committed to only keeping your personal data for as long as we need to in order to fulfil the relevant purpose(s) it was collected for, as set out above in this notice and for as long as we are required or permitted to keep it by law or specified by our regulator.


If you are not (and have never been) a client of ours, we will keep your information unless you ask us to ‘forget me’ in which case we will permanently delete your records.


If you are, or were, a Full Circle Asset Management Limited client, we will keep most of your information after closure of your account. By law or regulation, we keep documents relating to pension transfers, pension conversions, pension opt-outs or Free Standing Additional Voluntary Contributions indefinitely. However we will ensure that your information is not accessible. We will not share your information with anyone, or send you unsolicited information.


 

Who do we share your information with?
 

• Our IT providers and services providers, in order to provide and maintain the provision of our services


• Our appointed auditors, accountants, lawyers and other professional advisers, to the extent that they require access to the information to provide advice


• Fraud prevention agencies and other organisations to allow us to undertake the relevant checks


• Providers of investments or services, including providers of pensions, offshore bonds, onshore bonds, trusts, investment platforms, custodians, insurance products, or other such products or services. We may also be required to share information with the auditors appointed by the providers of such products or services


• The Financial Conduct Authority, the Information Commissioner’s Office, or any relevant regulatory authority where they are entitled to require disclosure


• If required to do so to meet applicable law, the order of a Court or market rules and codes of practice applicable to the circumstances at the time


• Relevant authorities to investigate or prevent fraud or activities believed to be illegal or otherwise in breach of applicable law


• If tax regulations require us to collect information about tax residency then, in certain circumstances (including if we do not receive a valid self-certification from you), we may be obliged to share information about your account with the relevant tax, payments and customs authority, who may pass this on to tax authorities in other jurisdictions


• In the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets


• We will not lend or sell your information to third parties with the exception of a sale of the business assets.


We may share your personal information with our service providers and this may involve transferring it to countries outside the European Economic Area (EEA) whose data protection laws may not be as extensive as those which apply to us. Where we do so, we will ensure that we do this in accordance with the Acts and take appropriate measures to ensure that the level of protection which applies to your personal information processed in these countries is similar to that which applies within the EEA. Such measures may include only transferring your data to jurisdictions in respect of which there is a European Commission adequacy decision or, where this is not the case, by using model clauses which have been approved by the European Commission.


 

Fraud Prevention Checks


As part of our application process we will carry out automated checks using your personal data, such as your name, postal address, date of birth, telephone numbers and employment status. These checks include identification verification checks and financial crime checks and involve us obtaining information from fraud prevention agencies and any records held by financial crime prevention agencies, on the Electoral Register and providers of utility services.


We need to carry out these checks in order to meet our obligations under the Money Laundering Regulations (and any other applicable legislation). The information obtained from these checks is used by us to determine if we can accept you as a client, whether further information is required or whether the application is rejected, based on factors such as whether we have been able to verify your identity.


We may make periodic searches with fraud prevention agencies during the course of our relationship with you to verify the information we hold remains correct and that there has been no change in your status (for example when you are a politically exposed person or if you have been subject to a financial sanction). We and other organisations may use and access the information recorded by fraud prevention agencies.


We may also provide information to financial and other organisations involved in fraud prevention to protect ourselves and our customers from theft and/or fraud. If false or inaccurate information is provided and fraud is identified or reasonably suspected, details will be passed to fraud prevention agencies who will record this. This information may also be accessed by law enforcement agencies. This information may be used by us other organisations to prevent fraud and money laundering.


 

Children
 

We understand the importance of taking extra precautions to protect the privacy and safety of children using our services. Children under the age of 13, or equivalent minimum age in the relevant jurisdiction, are not permitted to use our services, unless their parent provides verifiable consent.


 

Marketing
 

If you agree, we may send you information about our products and services by email which may be of interest to you. We would also like to send you news and information about the financial markets and financial services. Where it is in our legitimate interests, we may send you information about our products and services by post. We may also use your name and address to post to you invitations to events


You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us using the information at the end of this notice.


 

Cookies
 

Cookies are small text files that are sent by websites and stored on your device. They collect information about how the website is being used by those accessing it and allow websites to remember information. Our website uses cookies to distinguish you from other users to enable us to provide you with a better experience when you browse our website and to allow us to improve our site.


For further information about cookies, visit www.aboutcookies.org or www.allaboutcookies.org


We have to obtain your consent before placing cookies on your device. We will ask you to consent to our use of cookies and to the terms of use of our website when you try to access our website. Clicking ‘continue’ when prompted will indicate your consent.


You can set your browser settings not to accept cookies and the above websites tell you how to remove cookies from your browser. However, if you do not consent to cookies being placed on your computer or you set your browser not to accept cookies, some of our website features may not function or you may not be able to access parts of our website.


The cookies we use and our reasons for using them are set out below:


Google Analytics


These cookies are used to collect information about how our visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.


Click here for an overview of privacy at Google. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.


Disclaimer cookie


This cookie relates to the pop-up disclaimer on our website. It enables the website to remember your user type so that our disclaimer does not pop up every time you visit our website.


Content cookie


This cookie enables us to sort content within the web site to help improve your experience of our website.


Java Script cookie


This cookie tells our website whether or not you have Java Script enabled. Java Script is a scripting language that improves the functionality of our website.


Session cookie


This cookie stores user session information. This is used to improve your experience of our website. This cookie does not collect or hold any personal information.


Log-in cookie


This improves the experience of our website for clients who log in to view information about their portfolios.


Initialisation cookie


We use a cookie to enable decryption of certain data on our website when you log in. This cookie does not collect or hold personal information.

 


 

Your rights


You have the following rights (unless exemptions apply), which can be exercised by contacting us using the details provided below.


The right:


• To ask us not to process your personal data for marketing purposes

 

• To access personal data held about you and to obtain a copy of it

 

• To prevent any processing of personal data that is causing or is likely to cause unwarranted and substantial damage or distress to you or another individual

 

• To request the rectification or completion of personal data which are inaccurate or incomplete

 

• To restrict or object to the processing of your personal data (from 25th May 2018 onwards)

 

• To request its erasure under certain circumstances

 

• In certain circumstances, to receive your personal data, which you have provided to us, in a structured, commonly-used and machine-readable format and the right to transmit that data to another data controller without hindrance, or to have that personal data transmitted to another data controller, where technically feasible (from 25th May 2018 onwards)

 

• To be informed about any use of your personal data to make automated decisions about you and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of this processing

 

• To lodge a complaint about the way in which your personal data is being used to your Data Protection Authority, the Information Commissioner's Office

 

• Where we rely on your consent to use your personal data, you have the right to withdraw that consent at any time


If you contact us to exercise any of the rights above, we may ask you to provide some additional information in order to verify your identity, such as your name, your address and proof of identity.


We will endeavour to keep your information accurate, however if at any time after giving us this information it becomes out of date, then we ask you to notify us directly and we shall remove or amend the information within a reasonable time frame and in accordance with legislative requirements.


In order to exercise these rights, or if you have any concerns about our use of your personal information, please contact the Data Protection Officer using the information at the end of this notice. You can also contact the ICO in its capacity as Full Circle Asset Management Limited’s supervisory body.


 

Changes to our Privacy Notice

 

We keep our privacy notice under regular review and we will place any updates on our website. This privacy notice was last updated in May 2018. We reserve the right to update this privacy notice at any time.

 

 

How to contact us


If you have any queries, comments or requests regarding this notice or you would like to exercise any of your rights set out above, you can contact us at:


Email: info@fullcircleasset.co.uk


Post: Data Protection Officer

Full Circle Asset Management Ltd

6 East Point

High Street

Seal

Sevenoaks

Kent TN15 0EG



Full Circle Asset Management

Full Circle Asset Management Limited

6 East Point, High Street, Seal, Sevenoaks, Kent, TN15 0EG. Telephone: 01732 746700


Authorised and Regulated by the Financial Conduct Authority, Registered in England no. 02486204, 6 East Point, High Street, Seal, Sevenoaks, Kent, TN15 0EG,