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 (anonymised data).
This Website is not intended for children and we do not knowingly collect data relating to children.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We use different methods to collect personal data from and about you including the following:
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:
We do not rely on consent as a legal basis for processing your personal data although we will always ask for your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Marketing: We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Third-party Marketing: We will never share your data with any third party for marketing without your consent.
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.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that 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 we are required to do so by law.
We may share your personal data with the parties set out below:
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.
We share your personal data within the Caplin group. This will involve transferring your data from the United Kingdom to the European Economic Area (EEA) and vice versa.
Whenever we transfer your personal data out of the United Kingdom or the EEA, we ensure a similar degree of protection is afforded to it. 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.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the United Kingdom and 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.
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.
By law, we have to keep basic information about our customers for six years after they cease being customers.
In some circumstances you can ask us to delete your data: see Section 10 (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.
You may 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.
You may request correction 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.
You may 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 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 will be notified to you, if applicable, at the time of your request.
You may 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 personal data which override your rights and freedoms.
You may request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
You may request the 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. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the personal data to perform a contract with you.
You may 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 products or 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 above, please contact DataProtectionOfficer@caplin.com.
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.
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 could 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.
At times we obtain information from your device to improve our services, which will be used for statistical purposes about our visitors and how they use our Website. This information will not contain any personal details.
The personal data will be collected through a cookie file. Cookies are automatically downloaded to your device. The cookie file is stored on your hard drive, as cookies contain information that is transferred to your hard drive. This action will help us improve our Website and the service we offer you.
You can contact our Data Protection Officer by email at DataProtectionOfficer@caplin.com or the following postal address:
Caplin Systems Limited
107 Leadenhall Street,
London EC3A 4AF
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