Introduction and Contact Information
This privacy statement tells you what to expect when we collect your personal information. We will explain what data we hold about you, how we collect and use your data and whether we share it with other organisations.
This privacy notice applies to:
- Information we obtain about you
- How we use your information
- Sharing your information
- Where we store your personal information
- International data transfers
- Your rights of access to information
- Other rights you might have
- Changes to this policy statement
When someone visits our websites we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. Cookies help us to provide you with a good experience when you browse our website and allow us to improve our site.
Information About You
We will generally only collect data about you directly from you and this will be done when you communicate with us and is likely to include your name, address, e-mail address, telephone numbers and if you are a shareholder, information about your current or past shareholding and (if you elect to receive dividends by bank transfer) your bank account and sort code details.
Sometimes information about you will come from other organisations such as our brokers, PR consultants or our registrar if you have made an enquiry to them which they have to pass to us. We may also receive information about you from people instructed by you such as solicitors, brokers and nominees who hold shares (directly or indirectly) on your behalf. These businesses will mainly be data controllers themselves and we encourage you to read their privacy notices for information about how they deal with information about you. A number of organisations will deal with data about you on our behalf and we will therefore deal with any matters that arise about the way they handle your data; these include our registrars (whose details can be found on our website) and the companies that host our website and our other computer systems.
If we have asked for your consent to use your data you may withdraw that consent us.
During our recruitment process we may collect information directly from you, from other organisations and/or from publicly available information, including media profiles. If necessary, we will share your information in order only to assess your application, equality monitoring and to meet legal or policy requirements for pre-employment checks. This may include checking your identity, work and education activity, criminal record and credit history. Your information will be securely stored. Unsuccessful applicant details are held for 12 months and then destroyed.
How We Use Your Information
If you are a shareholder we use your information to keep track of your shareholding, to pay dividends (through our registrars) and to deal with enquiries you make of us. In any other circumstances we will only use your data in connection with any business that we or our subsidiaries might have with you.
Sharing Your Information
We will only share data about you where we have a legitimate interest to do so. Other than in a purely business context we are only likely to share details of our shareholders with companies that process your data on our behalf or our business advisers such as brokers and PR consultants or with other parties instructed by you (such as your brokers, advisers or nominees). We may have to disclose, or allow inspection of, our share register where such a request is made in the form laid down by statute and we have to comply unless we can prove that the information is not being requested for a “proper purpose” (a broad term that is not defined in the relevant legislation).
Where We Store Your Personal Information
All information you provide to us is stored securely. Where we have given you, or where you have chosen a password which enables you to access certain parts of our systems (including any hosted for us such as by our registrars), you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
International Data Transfers
We do not generally process personal information outside of the European Economic Area but should this occur from time to time (for example our use of Google analytics involves some personal data being transferred to the USA) it will be done only in a way that complies with current laws and regulations.
Access to Information
You may obtain the information we hold about you by making a written request to us using the contact details above.
Subject to compliance with any laws and regulations, when you ask us about the information we hold on you we will give you confirmation that your data is being processed, access to it and any other supplementary information we consider relevant to your request.
Your Other Rights
In addition to having access to your information (see above) and your right to the information set out in our privacy statements you have the rights to ask us to rectify any incorrect information about you, to delete information we hold about you, to restrict what we do with information about you, to require us to send information we hold about you either to you (or someone you designate) in a commonly used machine readable form, additionally you may object to how we are using information about you and the right not to have automated decisions made about you.
The above rights are not all absolute and whether you can use one of these rights may depend on the way we obtained your information or the legal basis on which we use your personal information. More information about how and when you can exercise these rights is available from the Information Commissioner’s Office.
We are committed to protecting and respecting information about you in compliance with relevant laws and regulations and for this reason we take complaints we receive about this very seriously. Please address any concerns to us at the contact address given above or to email@example.com. We encourage you to contact us directly if you are unhappy, but if you are not satisfied with our response or if you prefer not to raise the issue with us you may at any time complain to the Information Commissioner’s Office; for more information on this see the ICO’s report a concern links, their contact links or at one of its regional offices.
Links to other sites
This privacy notice does not cover the links within this site linking to other websites. These websites have their own privacy statements and we encourage you to read the privacy statements on the other websites you visit.
A “cookie” is a bite-sized piece of data that is stored on your computer’s hard drive. They are used by nearly all websites and do not harm your system.
These also include social media plug-ins which enable you to share our website content via your social media account(s) or easily share information with others. We have a presence on YouTube, LinkedIn and Twitter, and if you click on any of these icons on our website, you will be taken to our pages or profiles on those platforms. The platforms may then start tracking your behaviour using cookies for their own purposes; for example, to better understand your interests so that they can present relevant content or advertising to you. Data about you may also be transmitted to the social media channel even if you do not click on the plug-in. The social media platforms will provide us with statistical information, which we use to help understand how you and our other users interact with our social medial presence. All these platforms provide you with some control over their use of non-essential tracking technology and you can find details of how to exercise this control by reviewing their privacy and cookie notices. We have contractual arrangements in place with the social media channels we use. Please contact us for more information.
Below we describe the cookies which are installed upon this website.
You can change your cookie preferences at any time by clicking on the icon at the bottom left of this webpage. You can then adjust the available sliders to “On” or “Off” and then click “Save and close”. You may need to refresh your page for your settings to take effect.
Alternatively, most web browsers allow some control of most cookies through the browser settings. Find out how to manage cookies on popular browsers:
If you use a smart phone, you can usually prevent cross-site tracking and block cookies in the settings section on your device. You may also be able to visit websites without leaving a history by turning private browsing on. You should visit the support section of the website of your device for more information on how to do this.
Strictly necessary cookies
These cookies are always active and are necessary for this website to function. They cannot be switched off. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences.
You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
These cookies allow us to count visits and traffic so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular, and see how visitors move around the site.
All information that is collected by these cookies is aggregated, and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
These cookies are set by the Google Analytics service, but hosted by Progressive Research.
We do not currently use targeting cookies.
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 and that reason is compatible with the original purpose. If you require further information please contact us by emailing firstname.lastname@example.org.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which 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 this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table above and with business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, and credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
- External Third Parties as set out below.
- Specific third parties such as HMRC.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
External third parties
- Service providers acting as processors based in the UK who provide Investor Registrar services, Nominated Adviser and Broker services, and marketing services.
- Professional advisers based in the UK who provide banking, legal, insurance, accounting and auditing services and company secretarial services.
- HMRC, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
- Fraud prevention agencies, credit reference agencies, HM Courts & Tribunals Service.
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 require further information please contact us by emailing email@example.com.
We do not transfer your personal data outside the European Economic Area (“EEA”) to be used by any other party. We do however use US-based cloud email and storage system providers. This will therefore involve transferring your data outside the EEA.
Whenever we transfer your personal data outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- 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.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
If you require further information please contact us by emailing firstname.lastname@example.org.
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. We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. We will store all the personal information you provide on our secure servers. All electronic transactions you make to or receive from us will be encrypted using SSL technology. Of course, data transmission over the Internet is inherently insecure, and we cannot guarantee the security of data sent over the Internet. You are responsible for keeping your password and user details confidential. We will not ask you for your password.
In addition, we limit access to your personal data to those employees, agents 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 also 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.
Data retention and storage
How long will you use my personal data for?
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. We review the personal data that we hold every 12 months.
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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for accounting, tax and legal purposes. This also helps us, for example, in the event that there is a complaint about our Services, to respond to you in full.
Details of retention periods for different aspects of your personal data are available from us by emailing us at email@example.com.
In some circumstances, you can ask us to delete your data: see “Request erasure” below for further information.
In other circumstances we may 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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
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 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.
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.
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 information which override your rights and freedoms.
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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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 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 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 set out above, please email us at firstname.lastname@example.org with specific details of who to contact for subject access rights.
No fee usually required
Data Subjects have the right to access their personal data and supplementary information. The right of access allows individuals to be aware of and verify the lawfulness of the processing.
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, or requires copies of previously provided information. Alternatively, we may refuse to comply with your request in these circumstances.
In the event of manifestly unfair or excessive requests, we may refuse to respond to the request and any such refusal will be notified to the requester with a reason for the refusal and, in addition, information as to your rights to complain to the ICO or judicial authority within one month of such a request being received.
What we may need from you
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.
Time limit to respond
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.
MiFID II Directive
The MiFID II Directive allows that written material from a third party that is commissioned and paid for by a corporate issuer or potential issuer to promote a new issuance by that company, or where the third party is contractually engaged and paid by the issuer to produce such material on an ongoing basis, should be deemed acceptable as a minor non-monetary benefit subject to disclosure and the open availability of that material.
Our research is commissioned and paid for by companies and corporate issuers and we are engaged and paid by those companies and issuers to produce and distribute such materials. When published, our research is publicly and freely available on our website and is distributed, free of charge, to a large list of recipients. We can confirm that our research carries no call to action or target price. Neither does Progressive Equity Research offer investors the ability to trade securities. Therefore, our research should not be considered an inducement under MiFID II regulations.