Ascencia Investment Management is part of Frenkel Topping Group which includes Frenkel Topping Group Plc, Frenkel Topping Limited, Frenkel Topping Associates Limited (trading as Fletchers Financial Investment Solutions), Obiter Wealth Management Limited, ExpressFT Limited, HCC Investment Solutions Limited, Hudgells Financial Management Services Limited, Forth Associates Limited (trading as Forths Forensics and Equatas Accountants), Partners in Cost Limited and A & M Bacon Limited.
This privacy notice explains how we use any personal information we collect about you.
Ascencia Investment Management is committed to protecting the privacy of the people that we receive information about. This means that we take steps to lawfully, fairly and transparently process any personal data that is made available to us, in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679) and any other applicable domestic legislation (the “Data Protection Laws”). This Privacy Notice, together with our website Terms and Conditions set out the basis on which we will process your personal data. If you have any queries about this Notice or how we use your data, you can contact us using the contact details below.
When we refer to “personal information” or “personal data” in this Notice, we mean information which identifies you as an individual, or is capable of doing so. In the context of this Notice, the terms “personal information” and “personal data” may be used interchangeably. Please read this Notice carefully. By providing your personal data to us and/or applying to use our services, you acknowledge that your personal data will be used in accordance with this Notice and our Terms and Conditions.
When Do We Collect Information?
We may collect personal information about you when:
- you, or someone acting on your behalf, enquires about our services;
- you register with us, apply to use any of our services, become our client, or contact us in person, by telephone, by e-mail or by post and we go on to provide services to you;
- you voluntarily complete customer surveys, provide feedback or complete a contact form on our website;
- we receive some personal data about you through the course of providing services to one of our clients, for example if you are; – the professional adviser, guardian or attorney of one of our clients; or – a relative or an associate (such as the employer) of one of our clients and we receive your personal data whilst providing services to them.
In most instances, we will be the data controller, as defined under applicable Data Protection Laws, of any personal data which we collect from or about you.
We may collect information about you from fraud prevention agencies and other organisations when we undertake checks such as identification verification checks.
Information may also be collected about you when you visit our websites (for example via cookies). We record all calls for training and quality purposes and to enable us to deal effectively with queries or complaints and in the case where customers place transactions on regulated markets, in order to comply with our regulatory obligations.
In order for us to provide services to our clients we may need to process some personal data about other people who are connected to them (third parties).
Typically, the personal data we will collect will either be:
- data that has been provided to us directly by the third party (for example, because they have contacted us about one of our clients); or else
- data that has been provided to us by our client or their representative (for example, because records about our clients’ affairs also contain personal data about third parties). This personal data may be contained in telephone call recordings, electronic communications, minutes of face-to-face meetings and written correspondence.
What Information Will We Collect?
We may collect the following information:
- Your contact details, such as your name, address, telephone number and email address;
- Your date of birth, nationality, country of birth, country of residence, employment status and tax identification number (i.e. National Insurance Number);
- Passport details, driving licence and utility bills;
- Details of the services you request from us;
- Details of any records held by financial crime prevention agencies, on the Electoral Register and by providers of utility services; and
- Details of your employment status, income and source of wealth.
In some cases, you are not obliged to provide any personal data to us, but if you have requested information or a service from us, we will not be able to provide it without certain information, such as your contact details. Before we can begin providing you with our services, we need to obtain certain information about you, so that we can verify your identity in order for us to meet our obligations under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (the “Money Laundering Regulations 2017”) and any other applicable legislation and for the purposes of crime prevention and fraud prevention.
You are obliged to provide this information and if you do not provide it, we will be unable to provide you with our services.
How We Will Use Your Information
We use information held about you in the following ways:
- to process your application to use our services;
- in the case of a third party whose personal information is provided to us, to process a potential client’s application to use our services;
- to undertake checks such as identification verification checks with fraud prevention agencies to enable us to comply with our anti-money laundering obligations and for the purposes of crime prevention and fraud prevention;
- to comply with our obligations arising from any contracts entered into between you and us, including the Terms, and to provide you with the information, products and services that you request from us;
- to help protect your information and prevent unauthorised access to it;
- to deal with any queries, complaints or problems reported by you;
- for payment verification, debt tracing and debt recovery;
- to enable you to participate in our promotions;
- to provide you with information about other services we offer that are similar to those that you have already engaged us to provide, or enquired about. You may opt out of receiving this information when we collect your details or at any time by contacting us using the contact details below;
- if required to do so by law and to the extent necessary for the proper operation of our systems, to protect us/our customers, or for the enforcement of our Terms;
- to notify you of changes to our services; and
- to help improve the services we provide to you.
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
Data protection laws define the following as special categories of data:
- data revealing your racial or ethnic origins, your political opinions, religious or philosophical beliefs, or any trade union membership you may hold;
- genetic data or biometric data about you;
- data concerning your health, your sex life or your sexual orientation.
Where special category data is required we’ll obtain your explicit consent in order to collect and process this information.
How We Protect Your Information
We take appropriate security measures (including physical, electronic and procedural measures) to help protect the confidentiality, integrity and availability of your personal information from unauthorised access and disclosure. For example, only authorised employees are permitted to access personal information, and they may do so only for permitted business functions. In addition, we use firewalls to help prevent Disclosure of Your Information We may disclose your information:
- to businesses that are legally part of the same group of companies as Ascencia Investment Management, or that become part of that group;
- to our custodian, IT providers, services providers and agents in order to provide and maintain the provision of the services;
- to our appointed auditors, accountants, lawyers and other professional advisers, to the extent that they require access to the information in order to advise us;
- to fraud prevention agencies. We will supply details of such agencies on request;
- to your properly appointed Professional Adviser or, where the investments we manage on your behalf are held via a pension, offshore bond, onshore bond, trust, investment platform or other such product or service, to the providers of such products or services in order to provide our services to you. We may also be required to share information with auditors appointed by the providers of such products or services;
- if required to do so by the Financial Conduct Authority or any relevant regulatory authority where they are entitled to require disclosure;
- if required to do so to meet applicable law, the order of a Court or market rules and codes of practice applicable to the circumstances at the time;
- to investigate or prevent fraud or activities believed to be illegal or otherwise in breach of applicable law;
- if tax regulations require us to collect information about each investor’s tax residency. In certain circumstances (including if we do not receive a valid self-certification from you), we may be obliged to share information about your account with HMRC, who may pass this on to tax authorities in other jurisdictions;
We will not lend or sell your information to third parties persons from gaining access to your personal information.
Transferring Information Overseas
The organisations to whom we may pass your details also have their own obligations to deal with your personal information appropriately. Sometimes a product or service may be administered from a country outside Europe. If this is the case, the firm must put a contract in place to ensure that your information is adequately protected.
You have the following rights (unless exemptions apply), which can be exercised by contacting us using the details provided below. The right:
- To ask us not to process your personal data for marketing purposes;
- To access personal information held about you and to obtain a copy of it;
- To obtain the rectification or completion of personal data which are inaccurate or incomplete;
- To restrict or object to the processing of your personal data and to request its erasure under certain circumstances;
- In certain circumstances, to receive your personal data, which you have provided to us, in a structured, commonly-used and machine readable format and the right to transmit that data to another data controller without hindrance, or to have that personal data transmitted to another data controller, where technically feasible;
- To be informed about any use of your personal data to make automated decisions about you, and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of this processing; and
- To lodge a complaint about the way in which your personal data is being used to the Information Commissioner’s Office (https://ico.org.uk/global/contact-us)
When you contact us to exercise any of the rights above, we may ask you to provide some additional information in order to verify your identity, such as your name, your address and proof of identity.
Where we rely on your consent to use your personal data, you have the right to withdraw that consent at any time.
For further information visit http://www.allaboutcookies.org/
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.
What can you do if you are unhappy with how your personal data is processed?
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
0303 123 1113 (local rate)
How to contact us