This policy should be read in conjunction with our Website Terms of Use, our Terms & Conditions and Service Description where relevant
This privacy notice sets out the processing practices in relation to personal data which is collected, stored and retained through the use of this Website and any other electronic communications by Insignis Asset Management Limited, which is the data controller for that data.
References to “we”, “us” or “our” refer to Insignis Asset Management and references to “you” or “your” refer to any users of our website.
If you decide to take advantage of our services, we will ask you to provide us with certain information to enable us to verify your identity and address. This information may additionally be used for the prevention of money laundering as well as in the management of the services we provide you. We may check the data provided by you against corroborative sources of electronic data to validate the data and authenticate an individual’s geographic locale. We will also use the data provided to access a widely adopted source of structured intelligence on Politically Exposed Persons (PEPs), heightened risk individuals and organisations.
Insignis Asset Management Limited may use your postal address, email address and telephone number to contact you about our services for as long as you are a client, or a potential client, of this company.
If you are a direct client of Insignis Asset Management we may also use your postal and email address for the purposes of sending direct marketing information to you on other products and services we offer. You may ask us to stop sending such direct marketing information to you at any time.
We will only pass on your personal details to third parties when we are required to by law, or for the purposes of opening accounts in your name as part of the operation of our service.
We will maintain records of data held about you for at least as long as required by law, and in any event for a minimum of five years from the termination of any relationship between you and us.
Our website uses Google Analytics, a web analytics service provided by Google, Inc. (‘Google’). Google Analytics uses cookies (please see below) to help us analyse how you use the website. The generic, non-personal, information generated by cookies will be transmitted to, and stored by, Google on servers in the United States. Google uses this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.
Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.
Neither Insignis Asset Management Limited nor Google will associate this information with any other data held by Insignis Asset Management Limited or Google.
You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of our website.
By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
‘Cookies’ are small amounts of data sent in a text file from a web server to your web browser which help operators understand more about the way in which you use a website. The information collected through cookies on our website is only used by Google Analytics to help us analyse how you use the website.
Two types of cookie may be used on the website, “session” or “persistent”.
If you would prefer not to accept cookies then you can alter your settings within your web browser (e.g. Internet Explorer, Google Chrome, Mozilla Firefox). Please visit the help section within your browser for instructions on how to do this.
Please note that if you do not permit cookies to be used, we may not be able to offer you an online service.
If you have any questions would like further information about our privacy and information handling practices, would like to discuss opt-outs or withdrawing consent, please contact our Data Protection Officer by e-mailing at manjinder.gahir@insigniscash.com or writing to the address below.
Insignis Cash
St John’s Innovation Centre,
Cowley Road,
Cambridge
CB4 0WS
We are committed to working with you to settle any complaint or concern about privacy. If you are not happy with how we have dealt with your complaint or concern, you can complain to the data-protection authority of the United Kingdom contacting the Information Commissioners Office:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone
We may provide links to external websites on our website. We are not responsible for the content of any external websites.
We do:
We don’t:
We may need to collect personal information by law, or under the terms of a contract we have with you. If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your accounts. It could mean that we cancel a product or service you have with us. Any data collection that is optional would be made clear at the point of collection.
We may need to confirm your identity before we provide products or services to you or your business. Once you have become a customer of ours, we will also share your personal information as needed to help detect fraud and money-laundering risks. We use Fraud Prevention Agencies to help us with this.
Both we and fraud prevention agencies can only use your personal information if we have a proper reason to do so. It must be needed either for us to obey the law, or for a ‘legitimate interest’.
A legitimate interest is when we have a business or commercial reason to use your information. This must not unfairly go against what is right and best for.
We will use the information to:
We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent and prosecute crime.
FPAs can keep personal information for different lengths of time. They can keep your data for up to five years if they find a risk of fraud or money-laundering.
These are some of the kinds of personal information that we use:
These are only used in the provision of our services.
The information we have for you or your business is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.
Our products and services may be provided using resources and servers located in various countries around the world. Therefore, your personal data may be transferred outside the country where you use our services, including to countries outside the European Economic Area (EEA). We will transfer data in such circumstances only if the level of data protection in that jurisdiction is deemed adequate and if there are appropriate safeguards in place to protect your privacy.
Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of information on an international basis. Therefore, by browsing the Website and communicating electronically with us, you acknowledge and agree to Insignis processing personal data in this way.
We will keep your personal data only for so long as it is reasonable for us to do so, depending upon the nature of the data and our processing, and the grounds upon which we collected it. In general, we will delete redundant account information within 14 days of our relationship ending. However, we are obliged to keep certain records of our relationship to comply with the FCA’s and other regulatory rules, in which case we will instead restrict access through our archiving processes. Subject to any actual or potential legal claim or regulatory investigation, the maximum time that we envisage retaining any of your information is 7 years, after which time it will be destroyed.
Information we use for marketing purposes will be kept by us until you notify us that you no longer wish to receive this information. If you do notify us that you no longer wish to receive marketing information we will keep an encrypted version of your contact information to ensure we respect your wishes.
After you stop being a customer, we may keep your data for up to 7 years for one of these reasons:
We may keep your data for longer than 7 years if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.
You have the right to request information on and access to the personal data we hold about you.
You also have the right to request that we correct or delete any incomplete, incorrect, unnecessary or outdated personal data we hold about you. However, we cannot delete personal data that is necessary for compliance with our binding legal or regulatory obligations or if the personal data must be retained according to applicable laws, or is required for the exercise or defence of a legal or regulatory claim.
In case you consider your personal data collected by us to be inaccurate but you do not wish your personal data to be deleted, if we have used your personal data unlawfully or you have objected to the processing and the existence of legitimate grounds for processing is still under consideration, you may request restriction of processing of your personal data.
You may also at any time object to your personal data being processed for direct marketing purposes, sending promotional materials, profiling, or for the performance of market research. Where your personal data is processed based on your consent, you have the right to withdraw your consent for such processing at any time.
In case you wish to make use of your rights mentioned above, you may, as appropriate and in accordance with applicable laws, exercise such rights by contacting us through the contact points referred in the marketing materials or below in this notice. In some cases, especially if you wish us to delete or cease the processing of your personal data, this may also mean that we may not be able to continue to provide the services to you.
Please note that we may need to identify you and to ask for additional information in order to be able to fulfil your requests. Please also note that applicable law may contain restrictions and other provisions that relate to your above rights.
You have a right to a copy of and details of the personal data held about you. To obtain a copy of the personal data Insignis holds about you, please write to us at manjinder.gahir@insigniscash.com . No charge will normally be made by Insignis for providing this information. If your request is considered to be repetitive, wholly unfounded and/or excessive, we are entitled to charge a reasonable administration fee.
You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this.
If you do, we will take reasonable steps to check its accuracy and correct it.
You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.
There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.
We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.
You can ask us to restrict the use of your personal information if:
If you want to object to how we use your data, or ask us to delete it or restrict how we use it or, please contact us.
You can withdraw your consent at any time. Please contact us if you want to do so.
If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.