Please read the following information carefully. This privacy notice contains information about what data we collect and store about you and why. It also tells you who we share this information with, the security mechanisms we have put in place to protect your data and how to contact us if you have a complaint.
Who we are?
Thompson Taraz collects, uses and is responsible for personal information about you. When we do this we are the ‘controller’ of data for the purposes of the General Data Protection Regulation and other applicable data protection laws. Where we are provided with the information from another source we are considered a processor of data. Thompson Taraz refers to the Thompson Taraz group, which comprises Thompson Taraz Group plc and its subsidiaries and associated companies, and Thompson Taraz LLP.
What do we do with your information?
Information collected by us
When carrying out activities that are contractually or legally required when providing our fund services we collect the following personal information that you provide to us:
- Contact details that enable communication with you
- Information to carry out fund services. Depending on the activity, this may include contact details, facts about you to enable confirmation of your identity, detail to support reporting to the authorities and information required for transactions with you.
Communications to or from Thompson Taraz may be monitored and recorded to ensure the quality of the service being provided.
Thompson Taraz also holds contact details of people that are active in the organisations that operate in the sector it works in and which are the basis of email updates and briefings.
Information collected from other sources
We collect the following information from other sources:
- Where you have authorised us to do so, we may collect the personal information referred to above from your IFA or authorised representative.
- For our update briefing database we may use publicly available sources to obtain contact details. These sources would be professional associations or directories and websites of organisations that you work for.
How we use your personal information
We use your personal information for the following purposes:
- Communicating with you.
- To provide contracted fund services.
- To comply with applicable legal requirements; or
- To provide sector updates and insights.
Whether information has to be provided by you, and why?
Other than the contact details need for the circulation of the sector email updates, the personal information described must be provided by you to us as a contractual or statutory requirement, to enable us to carry out our fund services. When we collect information from you, we will inform you whether you are required to provide this information to us.
Legal reasons we collect and use your personal information
We rely on contractual terms and statutory requirements as the legal basis for processing your information. For sector update recipients we rely on consent or legitimate interest
Who will we share your personal information with?
We have relationships with third party service providers that we may share your personal data with. The third parties would either be contractors or service providers that help us to meet our contractual obligations or identity checking organisations that help us to comply with legal requirements.
We will share personal information with the bodies that regulate us, HMRC and law enforcement agencies if required by applicable regulations or law.
We will not share your personal information with any other third parties without your consent.
Transfer of your information outside the European Economic Area (EEA)
We will not transfer your personal information outside the EEA.
If this position changes and we commence work with a third party who is or has some of it activities outside of the EEA we will update this privacy notice and inform the clients this activity will affect. Any future transfer of data outside of the EEA should it be applicable will be subject to safeguards such as end to end encryption where it is possible, password protection and limited access to data at the receiving end by virtue of system designed. These safeguards are designed to protect your privacy rights and provide you with remedies in the unlikely event that your personal information is misused. You are entitled to obtain a copy of how your data will be protected should it become necessary for it to be transferred outside the EEA.
How long will we store your personal data?
We hold your personal data in accordance with legal and regulatory requirements including rules specific to the financial services industry.
The retention period for your data is dependent on a number of factors including but not limited to:
- The sensitivity of the data we have collected
- The legal obligations we may have to store data specified periods
- The time a data subject is entitled to raise a complaint or claim
- The contract we have with our public liability insurers
- Any specific instructions provided by yourself
- As a general rule we will store your file for a period of six years or as determined by the factors above. You will be advised how long your file is stored for when your matter is concluded.
We do not generally rely on your consent to hold personal data. In respect of the sector update we may be relying on your explicit consent to use, store, disclose and retain your information as described above. You provided this consent when you submitted your information to Thompson Taraz.
You have the right to withdraw this consent at any time, but this will not affect the lawfulness of any processing activity we have carried out prior to you withdrawing your consent. You can opt-out by contacting us at firstname.lastname@example.org.
Under the General Data Protection Regulation, you have a number of important rights that you can exercise free of charge. In summary, these rights are:
- Transparency over how we use your personal data and fair processing of your information;
- Access to your personal information and other supplementary information;
- Require us to correct any mistakes or complete missing information we hold on you;
- Require us to erase your personal information in certain circumstances;
- Receive a copy of the personal information you have provided to us or have this information be sent to a third party;, this will be provided to you or the third party in a structured, commonly used and machine-readable format;
- Object at any time to processing of your personal information for direct marketing;
- Object in certain other situations to the continued processing of your personal information;
- Restrict our processing of your personal information in certain circumstances;
- Request not to be subject to automated decision making which produce legal effects that concern you or affect you in a significantly similar way.
If you want more information about your rights under the GDPR please see the Guidance from the Information Commissioners Office on Individual's rights under the GDPR.
If you want to exercise any of these rights, please:
- Email, call or write to us on the contact details set out below.
- Provide further information so that we can identify you (name and ID number).
- Let us have proof of your identity and address (certified copy of valid passport or photo driving licence and a copy of a utility bill dated within 3 months). We may need to contact you to request further information to verify your identity;
- State the right or rights that you wish to exercise.
We will respond to you within one month from when we receive your request. Please note if you wish to unsubscribe from any email you can do so by contacting us at email@example.com. It may take 48 hours for this to become effective.
How to make a complaint?
We hope that you are happy with our service and that we can resolve any issues or complaints that arise. Please get in touch if you have any concerns (see ‘Get in touch’ below).
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where the alleged infringement of data protection laws occurred. The UK supervisory authority is the Information Commissioner’s Office who can be contacted at https://ico.org.uk/concerns/
We are committed to safeguarding the information we have on our systems and have put in place the necessary procedures to ensure the safety of the information we collect. Whenever you are about to view pages over a secure connection, a box will pop up advising you that information you exchange with our website cannot be viewed by anyone else on the web.
However, Thompson Taraz makes no warranty regarding the security of this site, including with respect to the ability of unauthorised persons to intercept or access information transmitted by you through this service.
Internet communications are not secure unless the information being sent is encrypted. Thompson Taraz cannot accept any responsibility for the unauthorised access of such communication by a third party or the corruption of data being sent to Thompson Taraz.
We do not intend to process your personal information for any reason other than stated within this privacy notice. If this changes, we will inform you by updates on the Thompson Taraz website.
Changes to this privacy notice
This privacy was published 25 May 2018 and last updated on 26 April 2021.
We constantly review our internal privacy practices and may change this policy from time to time. When we do we will inform you by updates on the Thompson Taraz website.
Get in touch
If you have any questions about this privacy notice or the information we hold about you, please contact us.
The best way to reach us is to email firstname.lastname@example.org or alternatively, please call 020 7907 8777.