Privacy Policy

Note regarding ‘Brexit’

Any reference to the General Data Protection Regulations (“EU-GDPR”) also includes the UK Data Protection Act 2018 (“UK-GDPR”). Where there is any discrepancy, UK-GDPR regulation will take precedence.

Who Are We

UCAT Services Limited (“UCAT” “we”, “us”) are committed to protecting and respecting your privacy. This privacy policy applies to the website www.ucatservices.co.uk owned and operated by UCAT Services (acting as data controller) and subscriptions to our services. This privacy policy describes how we collect and use the personal data you provide. It also describes the choices available to you regarding our use of your personal data and how you can access and update this information. Please ensure that you read this policy in full before providing us with any personal data.

Sharing Your Personal Information

We will treat personal data confidentially and except so far as is necessary in order to provide our services to you, we will not share your information with any third party unless we have a legal basis to do so. Should we need to share data with third parties in order to provide our services this will be done securely through passworded files either via email. The specific parties in question will only be relevant to the services we are providing; these may include the following:

· Client Account Provider

· Other outsources services e.g. IT or Platform hosting firms

· The bond issuer (if you are an investor with that firm)

Safeguards And Security

No data transmission over the internet can be entirely secure, so we do not guarantee the security of your personal information and/or use of our website. However, we use reasonable endeavours to protect the security of your personal information from unauthorised access or use by using encryption technology. In addition to these safeguards, your personal information is protected in the UK by the Data Protection Act 2018. This provides that the information which we hold about you should be processed fairly and lawfully, should be accurate, relevant and not excessive, not be retained for longer than is necessary and, if applicable, be kept up to date. For more information on the Data Protection Act 2018 and your related rights please see www.ico.gov.uk.

Use of Your Information

By using our website, you agree that we may collect, hold, process and use your information (including personal information) for the purpose of providing you with our services and developing our business which includes:

· personalisation of content, business information or user experience

· account set up and administration

· delivering marketing and events communication

· carrying out polls and surveys

· internal research and development purposes

· providing goods and services

· legal obligations (e.g. prevention of fraud)

· meeting internal audit requirements

How The Law Protects You

Your privacy is protected by law. This section explains how that works. Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside Northern Provident Investments. The law says we must have one or more of these reasons:

• To fulfil a contract we have with you, or

• When it is our legal duty, or

• When it is in our legitimate interest, or

• When you consent to it, or

• When it is necessary to protect a life, or

• When it is in the public interest.

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is. We may also rely on consent, but this will only be if you opt into marketing from us or contact us to enquire about our services. We will not process special category personal data.

Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so.

Groups of Personal Information

We use many different kinds of personal information, and group them together like this.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Collecting Personal Information

We may collect the following personal information from you when you contact us requesting services or information from us. We need to collect this information so that we can provide our services or that information to you:

· Information that you provide to us by filling in forms on our website. This includes contact information such as name, email address, mailing address, phone number, financial information such as bank or brokerage account numbers, unique identifiers such as user name, account number, password, date of birth and preferences information such as favourites lists, transaction history, marketing preferences.

· If you choose to list your company with us, we may ask for information about your business such as company name, company size, business type and personal data such as a professional profile.

· Information that you provide to us when you write to us (including by email).

· Information that you provide to us when we speak to you by telephone. We may make and keep a record of the information you share with us.

· Information that you provide to us by completing surveys.

· Details of transactions you carry out through our website and of the fulfilment of your orders.

· Information obtained by us from third parties in accordance with this Privacy Policy. For example, if you chose to list your business with us, we may obtain additional information from credit reference agencies as a supplementary source.

As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, to

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Collecting Personal Information

We may collect the following personal information from you when you contact us requesting services or information from us. We need to collect this information so that we can provide our services or that information to you:

· Information that you provide to us by filling in forms on our website. This includes contact information such as name, email address, mailing address, phone number, financial information such as bank or brokerage account numbers, unique identifiers such as user name, account number, password, date of birth and preferences information such as favourites lists, transaction history, marketing preferences.

· If you choose to list your company with us, we may ask for information about your business such as company name, company size, business type and personal data such as a professional profile.

· Information that you provide to us when you write to us (including by email).

· Information that you provide to us when we speak to you by telephone. We may make and keep a record of the information you share with us.

· Information that you provide to us by completing surveys.

· Details of transactions you carry out through our website and of the fulfilment of your orders.

· Information obtained by us from third parties in accordance with this Privacy Policy. For example, if you chose to list your business with us, we may obtain additional information from credit reference agencies as a supplementary source.

As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, to analyse trends, to administer our website, to track users’ movements around our website and to gather demographic information about our user base as a whole. In addition, we may collect data from third parties we work with:

· Companies that introduce you to us

· Credit reference agencies

· Comparison websites

· Social networks

· Fraud prevention agencies

· Payroll service providers

· Public information sources such as Companies House

· Agents working on our behalf

· Market researchers

· Government and law enforcement agencies.

Who we share your personal information with

We may share your personal information with these organisations:

· Agents and advisers who we use to help run your investment and explore new ways of doing business

· HM Revenue & Customs, regulators (such as the Financial Conduct Authority “FCA”)) and other authorities

· Credit reference agencies

· Fraud prevention agencies, including Lexis Nexis who we use to complete Know Your Customer (“KYC”) checks

· Any party linked with your product or service

· Reviews companies who collect your feedback should you choose to respond

· Companies we have a joint venture or agreement to co-operate with

· Organisations that introduce you to us

· Companies that we introduce you to

· Market researchers

· Independent Financial Advisors

· Price comparison websites and similar companies that offer ways to research and apply for financial products and services

· Companies you ask us to share your data with.

We may need to share your personal information with other organisations to provide you with the product or service you have chosen:

· We will share transaction details with companies which help us to provide our products.

· We will share your details with companies which help us to store your information.

· If you use direct debits, we will share your data with the Direct Debit scheme.

· We may also share your personal information if the make-up of UCAT Services changes in the future.

· If any change in the make-up of UCAT Services takes place, then other parties will use your data in the same way as set out in this notice.

Cookie Policy

In addition to personal information, we may collect information about you automatically when you visit the Site. The collection of information may involve the use of cookies and web beacons. A web beacon is a small graphic image placed on a web page that is designed to allow us to monitor traffic on the Site. A cookie is a small text file that is placed on your computer’s hard drive by your web browser when you first visit the Site. The cookie allows us to identify your computer and find out details about your last visit. Most internet browsers accept cookies automatically, but usually you can alter the settings of your browser to erase cookies or prevent automatic acceptance if you prefer. If you choose not to receive our cookies, we cannot guarantee that your experience with the Site will be as quick or responsive as if you do receive cookies.

The information collected by cookies and web beacons is not personally identifiable, it includes general information about your computer settings, your connection to the internet e.g. operating system and platform, IP address, your browsing patterns and timings of browsing on the Site and geographical location.

Sending data outside of the EEA

The United Kingdom left the European Union (“EU”) and therefore ceased to be a Contracting Party to the EEA Agreement after its withdrawal from the EU on 31 January 2020, as it was a member of the EEA by virtue of its EU membership, but we will ensure that the protections referred to below apply to any such transfers from the EEA to the United Kingdom.

Whenever we transfer your personal data out of the UK, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

· We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data;

· Model Clauses (also known as Standard Contractual Clauses) are standard clauses in contracts to ensure that any personal data leaving the EEA will be transferred in compliance with EU data- protection law.

· Transfers permitted in specific situations where a derogation applies as set out in Article 49 of the GDPR. For example, where it is necessary to transfer information to a non-EEA country to perform our contract with you.

Marketing

We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’. The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with. We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you. You can ask us to stop sending you marketing messages by contacting us at any time. Whatever you choose, you’ll still receive statements, and other important information such as changes to your existing products and services.

We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business. If you change your mind you can update your choices at any time by contacting us.

The information we use

These are some of the kinds of personal information that we use:

· Name

· Date of birth

· Residential address

· History of where you have lived

· Contact details, such as email addresses and phone numbers

· Financial data

· Data relating to your or your businesses products or services

· Employment details

· Data that identifies computers or other devices you use to connect to the internet. This includes your Internet Protocol (IP) address.

If you choose not to give personal information

We may need to collect personal information by law, or under the terms of a contract we have with you. If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your product. It could mean that we cancel a product or service you have with us. Any data collection that is optional would be made clear at the point of collection.

How long we keep your personal information

We will never hold your data for longer than is reasonably necessary. Should you enter into a contract with us we will remove your data six years after our service to you ends in line with FCA requirements.

If we have obtained your details only as a result of your consent and we are relying on this as a processing condition we will remove your data within one year of you supplying this to us (unless you have subsequently reconfirmed your opt in to us).

Personal data will be securely disposed after we no longer need it. In the case of electronic copies these will be deleted. For hard copy personal data this will be securely shredded. Please note, we may keep your data for longer than 6 years if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.

Your rights in relation to personal data

Under the General Data Protection Regulations (“GDPR”), you have rights in relation to access and control of your personal data. Specifically:

· access;

· correction and deletion;

· withdrawal of consent (if we are processing data on condition of consent);

· data portability

· restriction of processing and objection

· lodging a complaint with the Information Commissioner’s Office

If you wish to undertake any of the above in relation to the personal data, we hold about you, or have any other queries please write to us (including full details of your request) at the address in the “How to get a copy of your personal information” section below.

Should you submit a data subject access request (“DSAR”), we will respond to you within one calendar month from receipt of the request. If the request does not provide enough information to identify you, we may require further information. Where further information is requested, the deadline is extended to one calendar month from the further information being received. When we receive a DSAR from you we will write to you to:

· confirm receipt of the DSAR, and

· indicate when we are likely to respond.

Please be aware that there may be circumstances in which data subject rights may be limited, e.g. if fulfilling the data subject request may expose personal data about another person, or if you ask us to delete data which we are required to keep by law.

How to get a copy of your personal information

You can access your personal information we hold by writing to us at info@ucatservices.co.uk

Letting us know if your personal information is incorrect

You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this. If you do, we will take reasonable steps to check its accuracy and correct it.

What if you want us to stop using your personal information

You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’. There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted. If you want to object to how we use your data, or ask us to delete it or restrict how we use it, please contact us. You can ask us to restrict the use of your personal information if:

· It is not accurate.

· It has been used unlawfully but you don’t want us to delete it.

· It not relevant any more, but you want us to keep it for use in legal claims.

· You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it.

How to withdraw your consent for marketing

Should you wish to opt out of any marketing from us if you have previously consented to it please email info@ucatservices.co.uk, and make this intent clear. If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.

Security

We will use all reasonable efforts to safeguard the information we collect about you by having security and organisational procedures in place. All personal information we hold is securely stored, and we conduct regular testing or our cyber and physical security procedures to ensure this is maintained. If at any time we believe there has been a breach of your personal data, we will notify you immediately. You are responsible for keeping any personal passwords or similar security information private, including personal information you disclose on social media.

How to contact us?

Should you wish to contact us with questions or concerns about our privacy practices, your personal information, or if you wish to file a complaint you can contact us via the following methods: · Email: info@ucatservices.co.uk

How to complain

Please let us know if you are unhappy with any part of the service we have provided, including how we have used your personal information. You can contact us on info@ucatservices.co.uk

You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern.

Monitoring

This policy will be reviewed (and updated where necessary) on a yearly basis or as and when the relevant data protection rules are amended.