1. Important information and who we are
More information on Eighteen48 and related Group companies is provided at www.eighteen48.com.
Please refer to the Glossary to understand the meaning of some of the terms used.
This website is not intended for children and we do not knowingly collect data relating to children.
Our Contact details
Full name of legal entity: Eighteen48 Partners Limited
Email address: firstname.lastname@example.org
Postal address: Montpelier House, 106 Brompton Road, London SW3 1JJ
Telephone number: +44 (0)20 7590 1855
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.
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.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
In addition to the above, we will collect the following information from you when required:
We do not collect, use or share Aggregated Data such as statistical or demographic data for any purpose. We also do not collect, use or share 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).
If you fail to provide personal data
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, 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 product or service you have with us. We will notify you if this is the case.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
4. How we use your personal data
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:
Each of these categories is a ‘legal basis’ that allows us to process your information under data protection law. Click here to find out more information about what this actually means, in terms of how we process your personal data, and the purposes for processing your personal data relevant to each legal basis.
You have the right to withdraw consent to processing your personal data at any time by contacting us.
Marketing by us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you, which may include communications via post or email (or other electronic means) containing investment-market related reports, information and insights. This is how we decide which services may be relevant for you (we call this marketing).
You will receive such marketing communications from us if you have requested information from us or used our services previously and you have not opted out of receiving that marketing.
Please note that we will use your personal data to perform any contract, transaction or service we have agreed with you, for example to contact you for approval of investment decisions, or to provide you with reports, information, insights and updates on your existing or prospective investment activities or portfolio, where these are in line with your agreed investment management mandate. This is not classed as marketing. See the ‘Performance of a Contract’ section below for further details.
No third-party marketing
We will not share your personal data with any third party for marketing purposes.
You can ask us to stop sending you marketing at any time by following the opt-out links on any marketing message sent to you, or by contacting us at any time.
Where you opt out of receiving marketing, this will not apply to our use your personal data to perform any contract, transaction or service we have agreed with you, in line with your agreed investment management mandate.
Change of purpose
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 which 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.
If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis for this.
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.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out above.
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. If you have any questions about the third parties we share your personal information with, please contact us.
6. International transfers
We share your personal data within the Eighteen48 Group. This may involve transferring your data outside of the UK. We will ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”.
Some of our external third parties are based outside of the UK so their processing of your personal data will involve a transfer of data outside of the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
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 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.
8. Data retention & deletion
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
We will, in relation to our client investment management activities, retain all relevant client records, reports and other information (including certain personal data) for a period of six years, or such other period as required by relevant law (including the UK Financial Conduct Authority Handbook of Rules and Guidance). Further details of this are available in your Investment Management Agreement which you can request from us by contacting us.
Deleting & anonymising your personal data
Our data privacy manager is responsible for the continuing process of identifying personal data that has met its required retention period and for supervising its destruction in line with our data retention periods.
In some circumstances you may ask us to delete your data: see Your Legal Rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact us.
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 could refuse to comply with your request in these circumstances.
What we may need from you
As a security measure, we may 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).
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests, in which case you will be notified and updated.
Consent means we have offered you a real choice and control as well as the right to withdraw such consent. We typically obtain your consent to process your personal data for the purposes of and/or when entering a contractual relationship with you. We will obtain your separate consent for anything that is not covered by the contractual relationship.
Legitimate Interest means processing your data in the interests of pursuing and managing our business interests, including to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You may obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Our legitimate interests which are applicable to our processing of your personal information include:
Performance of a Contract means processing your data where it is necessary for us to perform a contract with you, including fulfilling our obligations under any product or service you have with us (or to take steps at your request before entering into such a contract). This could include:
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. This could include:
Internal Third Parties
Other companies in the Eighteen48 Group who are based in the United Kingdom or overseas.
External Third Parties
Third parties who have a duty to keep your data secure and confidential, where we have a lawful reason for doing so, as explained above, include the following types of organizations:
YOUR LEGAL RIGHTS
You have the right to:
Be informed about the collection and use of your personal data.
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.
Request rectification of the 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.
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 it being processed (see below), 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 (where applicable) we will notify to you.
Object to processing of your personal data where we are relying on a legitimate interest and your situation 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 legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to suspend the processing of your personal data in the following scenarios:
Request the portability 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. 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.
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 prior to the withdrawal of your consent. If you withdraw your consent, we may not be able to provide certain products or services to you, which (where applicable) we will notify to you.