This policy summarises how Clipstone uses, shares and stores the data collected from you when you become an investor in a fund managed by Clipstone, when you become a tenant in a property owned by one of our funds or when you apply for a job with Clipstone.
Clipstone is committed to safeguarding the personal information which you may provide to us and to the extent that Clipstone collects any personal information, Clipstone will hold it in confidence in accordance with the Data Protection Act 1998 and the General Data Protection Regulation (GDPR) (EU) 2016/679 which came into force on 25 May 2018.
Information we collect from you
Information you share with us
You may be asked to voluntarily provide certain personal information details about you such as your name, address, telephone number, email address and other information in connection with Clipstone’s customer or tenant registration procedures and job application process. Clipstone will use this information for the administration and servicing of your investments, performing its obligations under lease contracts, evaluating job applications and other related activities and to ensure compliance with its obligations under the UK regulatory regime. Clipstone may disclose the information to its agents and service providers.
Please note that by submitting personal information you are consenting to such information being processed for the purposes referred to above. You agree that Clipstone has the right to use and store such data on its internal systems and to transfer it to its associated companies and third- party agents and service providers where applicable, whether inside or outside the European Union to countries having an adequate level of data protection.
Your Rights and Your Personal Data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of your personal data which Clipstone holds about you;
- The right to request that Clipstone corrects any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary for Clipstone to retain such data;
- The right to withdraw your consent to the processing at any time;
- The right to request that Clipstone provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data;
- The right to lodge a complaint with the Information Commissioners Office.
How long we keep your Data
We are required under the Markets in Financial Instruments Directive II (MIFID II) rules to retain all client related information for up to 7 years, after which time it will be destroyed. Personal information that we use for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information. After you stop being a client, we may keep your data for up to 7 years for one of these reasons:
- To respond to any questions or complaints;
- To show that we treated you fairly; or
- To maintain records according to rules that apply to us.
CVs in respect of unsuccessful applicants are deleted promptly following completion of the job application process.
For more information about our privacy policies or if you have any questions, we welcome your comments. Please contact us at: firstname.lastname@example.org or by telephone on 020 7043 0270.