Website Privacy Policy

This privacy policy was last updated on 25/05/2018. We may change this privacy policy from time to time. You should check this policy occasionally to ensure you are aware of the most recent version which will apply each time you access this website.

This privacy policy does not apply to your use of the Ascentric Wrap Platform. The Ascentric Wrap Platform may be entered by logging in using the link on the website.

Platform privacy policies can be found below:

• Adviser Privacy Policy
• Client Privacy Policy

Investment Funds Direct Limited (“we”, “our” or “us”) is registered as a data controller with the Information Commissioner’s Office and our registration number is Z7560064. As a data controller, we are responsible for deciding how we hold and use personal information about you. Our Data Protection Officer is Yvonne Collins and you can contact us using any one (or more) of the following:

• Ascentric, Trimbridge House, Trim Street, Bath, BA1 1HB;
• Marketing@ascentric.co.uk; or
• 0345 600 5361

For the purpose of the Data Protection Act 1998 and the General Data Protection Regulation 2018, the data controller is Investment Funds Direct Limited, a company registered in England and Wales (registration number: 1610781), whose registered office is at Trimbridge House, Trim Street, Bath, BA1 1HB.

We take the privacy of our website users seriously. We request that you read this privacy policy (“the Policy”) carefully as it contains important information about how we will use your personal data. We are the company responsible for, and which controls, the processing of your personal data.

We will obtain personal data about you (such as your name, address, email, contact number) whenever you complete an online form, such as the online contact form.
When you use the website we may automatically collect the following information:

• Web usage information (e.g. your IP address), your login information, browser type and version, time zone setting and operating system; and
• Information about your visit, including which pages you have visited, links you have clicked on, searches you have made and other page interaction information.

We may also obtain other sensitive personal data about you should you volunteer it during the completion of online forms.

You have the right to receive information about the personal information we maintain on you. If you are concerned that any of the information we hold is incorrect, please contact us.

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

• Give consent on his/her behalf to the processing of his/her personal data;
• Receive on his/her behalf any data protection notices; and
• Give consent to the transfer of his/her personal data abroad.

We will collect, store and use personal data you provide to us in order to carry out the activities relevant to the provision of our services to you. We will only do this where:

• It is necessary for us to do so to enable us to provide you with the services that you have requested from us;
• It is necessary in order to fulfil our legitimate interests and your interests and fundamental rights do not override those interests; or
• The law otherwise permits or requires it.

We will use your personal data for:

• Administration;
• Statistical Analysis;
• Website activity analysis;
• Customisation of this website and its content to your particular preference needs; and
• Improving our services

where we consider that such processing is legitimised.

We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance and training.

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Unfortunately, the transmission of your personal data via the internet is not completely secure and although we do our best to protect your personal data, we cannot guarantee the security of data transmitted to us over the internet and you acknowledge that any transmission is at your own risk.

The website may link to other sites and we are not responsible for their data policies, procedures or content.

Your personal data will only be seen or used by those of our employees who have a legitimate business need to access your personal data for the purposes set out in this privacy policy. We take your privacy seriously and have implemented appropriate physical, technical and organisational security measures designed to secure your personal data against accidental loss, destruction or damage and unauthorised access, use, alteration or disclosure.

We may disclose your personal data to:

• Other companies within our group;
• Our agents, service providers, our business providers, and third parties who provide services to us in relation to provision of information to you where you have requested it; and
• Law enforcement agencies in connection with any investigation to help prevent unlawful activity.

You are aware and acknowledge that we are permitted to disclose to the Financial Conduct Authority (“FCA”) and to other regulatory authorities to which we are subject, or to any person empowered to require such information by or under legal enactment, any information they may request or require relating to you. In most cases, the ability of our third parties to use your data is limited and we will only allow them to use your personal data for specific purposes in accordance with our instruction and not for their own purposes. We will ensure that where these third parties process your personal data they do so in the way set out in this privacy policy and in compliance with law.

The data that we collect from you may be transferred to, and stored at a destination outside the European Economic Area (“EEA”) and in countries which are not deemed by the European Union to offer a standard of data protection equivalent to that under the applicable data protection legislation. If we do transfer your personal data outside the EEA we will ensure that the model contract clauses from controller to processor, as approved by the European Commission for the purposes of Article 26(2) of Directive 95/46/EC, or other such clauses as may replace them from time to time, are at all relevant times incorporated into the data processing agreement between us and any third party.

The website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates, and other websites operated by third parties. Please note that this privacy policy applies only to the personal information that we collect in connection with this website and we cannot be responsible for personal information that third parties may collect, store and use through their websites or their services. If you follow a link to any of these websites, you should always check the privacy policies of such websites before you submit any personal data to these websites.

We will keep your personal data for no longer than is necessary for the purposes we have set out above.

We (or our agreed suppliers) may retain personal data about you for statistical purposes (for example, to help us better provide our services). Where data is retained for statistical purposes it will always be anonymised, meaning that you will not be identifiable from that data.

You have a number of rights in relation to your personal data. You have the right to request that we:

• Provide you with a copy of the information we hold about you;
• Update any of your personal information if it is inaccurate or out of date;
• Delete the personal data we hold about you – if we are providing services to you and you ask us to delete personal data we hold about you then we may be unable to continue providing those services to you;
• Restrict the way in which we process your personal data. Please note that, if we are providing services to you and you ask us to restrict the processing of personal data we hold about you, we may be unable to continue providing those services to you;
• Stop processing your data if you have valid objections to such processing; and
• Transfer your personal data to a third party.

There are circumstances in which your rights may not apply.

For more information on your rights and how to use them, or if you would like to make any of the requests set out above, please contact us using the details provided in the section“About Investment Funds Direct Ltd”. We will respond to all such requests within the time period required by law.

Performance cookies
These are cookies used to improve a website, for example, analytics let companies see how their site is used and where to make improvements.

We use these performance cookies:

Functionality cookies
These are cookies that are needed for a specific piece of functionality, often as a result of something you are doing as a user, but are not directly requested by you. For example, in order to stop you from being repeatedly offered a service that you have previously said no to. We do not use any functionality cookies.

Targeting cookies
These cookies can be quite intrusive as they track a user’s browsing behaviour from website to website, often to be used for targeted advertising. We do not use any targeting cookies.

Disabling/Enabling cookies
This can be done through your browser or by using the “Cookie Control” function in the bottom left hand corner of the screen when you visit the website.

Deleting Cookies
If you want to remove any cookies already set, you can do so from your browser. You can find out how to do this by going to the help menu in your browser. For more information about how to control and disable cookies in your browser please visit: aboutcookies.org Please note that if you attempt to delete cookies while you are logged in, the system will automatically log you out.