Privacy Policy

BACKGROUND:

Gallium Fund Solutions Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our website, www.gallium.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with your rights, and our obligations as a Controller, under data protection laws.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

 

“Cookie”

means a small   text file placed on your computer or device by Our Site when you visit certain parts of Our Site   and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and

“Cookie Law”

 

 

 

means the   relevant parts of the Privacy and Electronic Communications (EC Directive)   Regulations 2003;

 

 

2. Information About Us

Our Site is operated by Gallium Fund Solutions Limited, a limited company registered in England under company number 06634506, authorised and regulated by the Financial Conduct Authority, FRN: 487176.

Registered address:  Gallium House, Unit 2 Station Court, Station Approach, Borough Green, Sevenoaks, TN15 8AD

Data Protection Officer: Marina Watts

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

 5. What Are My Rights?

Under the GDPR, you have the following rights, which We will always work to uphold:

a) The right to be informed about Our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.

b) The right to access the personal data We hold about you. Part 13 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that We have. Please contact us using the details in Part 15 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data. For example, while a complaint about the accuracy of the data we hold is in progress.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to data portability. This means that, if you have provided personal data to us directly, We am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

Please note that these some rights do not apply in certain circumstances.

For more information about Our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about Our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

6. What Data Do We Collect?

Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data (please also see Part 14 on Our use of Cookies and similar technologies):

Personal details you knowingly provide us through online forms and emails, including, but not limited to: name, address, email address, telephone number

  • Information about your preferences;
  • IP address (this is a string of numbers unique to your computer that is recorded by our web server when you request any page or component on the Website. This information is used to monitor your usage of the Website);
  • Web browser type and version;
  • Operating system;
  • Data recorded by the Website which allows us to recognise you and your preferred settings, this saves you from re-entering information on return visits to the site. Such data is recorded locally on your computer through the use of cookies. More information on the Cookies we use can be found in Part 14.

 7. How Do You Use My Personal Data?

Under the GDPR, We must always have a lawful basis for using personal data. This may be because the data is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data, because it is in Our legitimate business interests to use it or because we must comply with Our legal obligations. Your personal data may be used for one or more of the following purposes:

  • Providing and managing your Account;
  • Providing and managing your access to Our Site;
  • Verifying your identity to comply with anti-money laundering rules as part of the steps required before entering a contract with you;
  • Personalising and tailoring your experience on Our Site;
  • Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you;
  • Personalising and tailoring Our products and services for you;
  • Communicating with you. This may include responding to emails or calls from you;
  • Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.

8. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. . We shall retain your data for as long as you are our customer and for a period after which we decide is reasonable in order to comply with any regulatory or legal requirements.

However, we review the personal data held on a regular basis in accordance with internal policy and if we conclude that certain personal data is no longer needed, that personal data will generally be destroyed.

 9. How and Where Do You Store or Transfer My Personal Data?

Personal data is held on paper and computer systems. We must process this information fairly and lawfully.

We only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.

10. Do You Share My Personal Data?

We may share your personal data with:

 

  • Gallium entities and associated companies involved in the management and administration of your investment account
  • Judicial or governmental bodies (such as HMRC, Financial Conduct Authority, Financial Ombudsman Service) in order to comply with our legal and regulatory obligations – we can be fined and subject to other action if we fail to provide certain information to these authorities
  • Someone acting on your behalf, such as an independent financial adviser or Trustee
  • Service and software providers to assist with IT and security
  • Our professional advisers, including legal advisers
  • Credit reference and fraud prevention agencies to help us detect and prevent money laundering and financial crime

If any of your personal data is required by a third party, as described above, We will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, Our obligations, and the third party’s obligations under the law, as described above in Part 9.

 

11. How Can I Control My Personal Data?

11.1In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict Our use of your personal data.

11.2You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Can I Withhold Information?

You may access Our Site without providing any personal data at all. You may restrict Our use of Cookies. For more information, see Part 14.

 13. How Can I Access My Personal Data?

If you want to know what personal data We have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything We need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Our administrative costs in responding.

We will respond to your subject access request within one month of receiving it.  Normally, We aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date We receive your request. You will be kept fully informed of Our progress.

 14. What Are Cookies and How Do You Use Them?

Cookies are small files that are stored on a user’s computer. They are designed to hold data specific about a particular user and their use of websites.  They can be accessed either by the web server or the user’s computer. The information stored by the cookie allows the server to deliver a page tailored to the user. Alternatively, the page itself can contain scripts which can read the data in the cookie and is able to carry information from one visit to the website (or related site) to the next.

Cookies are integral to modern websites. They allow us to distinguish visitors from each other and (anonymously) record the traffic to the website. This helps ensure a good user experience, and the data is valuable in assessing and improving the website.

Our Site may place and access certain first-party and third-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. Third-party Cookies are cookies that are set by a website other than our own. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

All Cookies used by and on Our Site are used in accordance with current Cookie Law. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

Name of   Cookie

Description

Strictly   Necessary

Session cookie

This cookie is integral to the code that runs the content management   system. It only lasts for the duration of a visit.

Yes

Download log in

This is set when users agree to our Disclaimer and is ‘strictly   necessary’.

Yes

Google Analytics cookie (utma, utmb, utmz, utmc)

These are performance cookies. We collect them anonymously and   assessing the data they provide allows the site to be improved. Google   provides details of all the cookies used by Google Analytics.

You can find   more information about these cookies here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

No

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. The following Cookies may be placed on your computer or device:

In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

 15. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of Marina Watts):

  • Email address: admin@gallium.co.uk (Subject:           Data Protection).
  • Telephone number: 01732 882 642.
  • Postal Address: Gallium House, Unit 2 Station Court, Station Approach, Borough Green, Sevenoaks, TN15 8AD.

 16. Changes to this Privacy Policy

This notice is the latest version as at May 2018 and We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if We change Our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.