EDISTON PROPERTIES LIMITED AND EDISTON INVESTMENT SERVICES LIMITED
1. Important information
Ediston Properties Limited, together with Ediston Investment Services Limited (“We”, “Ediston”, “us” or “our”) are committed to protecting and respecting the confidentiality, integrity and security of personal information which has been entrusted to us.
Ediston processes data in respect of the following groups:
- investors in the funds that it manages (as processor)
- visitors to our website (as controller)
- business contacts (as controller)
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, and how Ediston complies with its responsibilities under applicable data protection laws, including, when and to the extent in force, the General Data Protection Regulation (Regulation (EU) 2016/679) and the Privacy and Electronic Communications Regulations 2003 (or a successor regulation) (“Data Protection Laws“). Please read this policy carefully.
2. Data controller
For the purpose of the Data Protection Laws, the data controller of your personal information is Ediston Properties Limited (registered number 04910369) of 39 George Street, Edinburgh EH2 2HN.
3. Personal data collection
We hold personal data about you which you provide by corresponding and/or contracting with us, investing in funds which we manage, through our website or by some other means (such as via a business card, social media (such as LinkedIn) or other public sources).
We may collect the following information from you:
- contact details (including name, title, address, telephone number, personal email address);
- date of birth;
- copies of passport, driving licence and utility bills;
- bank account details; and
- technical detail (including internet protocol (IP) address, [you login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website, usage data (including information about how you use our website, products and services], and marketing and communications preferences (including your preferences in receiving marketing from us and your communication preferences)].
4. Purposes for which personal data is used
We will use personal data which you provide us as follows:
- to provide you with information about investments which we manage in which you are invested and to manage and administer these investments;
- to use data analytics to improve our website, marketing, customer experiences on the basis of our legitimate interests;
- to carry out anti-money laundering checks and other actions in an attempt to detect, prevent, investigate and prosecute fraud and crime, which we consider necessary for compliance with our legal obligations, for the performance of a task being carried out in the public interest or to pursue our legitimate interests (including for the prevention of fraud, money laundering, sanctions, terrorist financing, bribery, corruption and tax evasion);
- to scan and monitor emails sent to us (including attachments) for viruses or malicious software, to process and encrypt personal data to protect and manage email traffic, and to store personal data on our systems to pursue our and/or the Trust’s legitimate interests, including for document retention purposes; and
- to comply with legal or regulatory requirements.
5. Legal basis for processing
We will use your personal data in the following circumstances:
- where we need to perform the contract we have entered into with you;
- where we need to comply with a legal obligation;
- where we have your consent;
- 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.
Such processing may include the use of your personal data for the purposes of sending you electronic marketing communication, in relation to which you can at any time unsubscribe by following the instructions contained in each marketing communication.
Where you provide personal information to us on our website, you will be asked if you consent to us sending marketing materials to you. If you give your consent, we are processing your personal information based on your consent. Where we collect personal information about you (such as via a business card, social media (such as LinkedIn) or other public sources), we are processing it on the basis that in doing so, we are pursuing our legitimate business interests. In either case, you have the right to object at any time to us processing your personal data for marketing purposes.
6. Accuracy of personal data
We try to ensure that the information we hold about you is accurate and kept up-to-date by contacting you at regular intervals. However, if in the meantime you believe that any information we are holding about you is inaccurate, out-of-date or incomplete, please notify us at 39 George Street, Edinburgh, EH2 2HN as soon as possible. We will promptly correct or delete any information found to be incorrect.
We have put in place what we consider to be appropriate security measures against unlawful or unauthorised processing of personal data we hold, and against the accidental loss of, or damage to, personal data.
8. Disclosure and sharing of your personal data
We will not disclose personal information we hold about you to any third party except as set out below.
We may disclose personal data to third parties who are providing services to us, including IT, marketing (if you agree) and data cleansing, or for any other purposes specifically permitted by the Data Protection Laws or for any other purpose which you may authorise.
We may also disclose personal data we hold to third parties:
- in the event that we sell any business or assets, in which case we may disclose personal data we hold to the prospective buyer of such business or assets; and/or
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.To the extent we transfer any personal data to any third party, we will only do so if that third party agrees to put in place appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, the personal data.
9. Transferring personal data outside the EEA
We will not transfer any personal data we hold about you to a country outside the European Economic Area (“EEA”) without notifying you in advance in writing. If we transfer any data outside the EEA, we will provide you with details of the country to which data is being transferred, along with details of the measures we have put in place to protect it (which you may see a copy of, on request).
10. Retention of data
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, or reporting requirements. To determine the appropriate retention period, 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.
We will take all reasonable steps to destroy, or erase from our systems, all personal data which is no longer required.
Please note that you may contact us at any time at 39 George Street, Edinburgh, EH2 2HN and ask for your details to be removed.
12. Links to other websites
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
13. Your legal rights
In certain circumstances, by law you have the right to:
- request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
- request correction of the personal information we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
- request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below);
- object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes;
- request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
- request the transfer of your personal information to another party; and/or
- withdraw your consent. If we are processing your personal data on the basis of your consent, you have the right to withdraw such consent at any time. Withdrawing your consent will not affect the lawfulness of processes based on consent before its withdrawal. To withdraw your consent, please contact us at 39 George Street, Edinburgh, EH2 2HN or follow the unsubscribe instructions included in each electronic marketing communication. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you wish to exercise any of the rights set out above, please contact Neelum Yousaf or the Data Privacy Manager in writing.
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.
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. 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.
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.
14. Changes to this policy
We may make changes to this data protection policy at any time. Any changes we make will be posted on this page and, where appropriate, notified to you in writing. Please refer back to this page regularly to see any changes or updates to this policy.
If you have any queries about this policy or your data, or you wish to submit an access request or raise a complaint about the way your personal information has been handled, please do so in writing and address this to Neelum Yousaf or the Data Privacy Manager at Ediston Properties Limited, 39 George Street, Edinburgh, EH2 2HN or by email to firstname.lastname@example.org.
Ediston Properties Limited is a limited company registered in England and Wales (registered number 04910369) and its registered office address is Level 13, Broadgate Tower, 20 Primrose Street, London EC2A 2EW. It has its principal place of business at 39 George Street, Edinburgh EH2 2HN.
Ediston Investment Services Limited is a limited company registered in England and Wales (registered number 09626337) and its registered office is Level 13, Broadgate Tower, 20 Primrose Street, London EC2A 2EW. It has its principal place of business at 39 George Street, Edinburgh EH2 2HN. Ediston Investment Services Limited is authorised and regulated by the Financial Conduct Authority.
© Ediston Properties Limited. All rights reserved.
18 May 2018