Vartan Ravenscroft

Privacy Policy

Introduction

A Vartan Limited trading as Vartan Ravenscroft ("We") are committed to protecting and respecting your privacy.

In the course of providing our services to you, we may collect, record, store, adapt, transfer or otherwise process your personal data in accordance with Data Protection Laws and we act as a data controller of your personal data when doing so.

“Data Protection Laws” means the Data Protection Act 1998, the Privacy and Electronic Communications Regulations (2011) (as amended), the Investigatory Powers Act 2016, and any other successor legislation (including Regulation (EU) 2016/679 of the European Parliament and of the Council, the ‘General Data Protection Regulation’).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, or which is provided to us by a third party acting for you or on your behalf, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.  We use different methods to collect data from you including our direct interactions in the course of providing services to you as well as technical information from, for example, analytics providers or third party and publicly available sources.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

•Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].

•Contact Data includes [billing address, delivery address, email address and telephone numbers].

•Financial Data includes [bank account and payment card details].

•Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us].

“Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

1. In limited circumstances, with your explicit written consent.

2. Where we need to carry out our legal obligations or exercise rights in connection with providing services to you.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information in the course of legitimate business activities with the appropriate safeguards.

Purposes for processing and legal bases for processing

We will only use your personal data when the law allows us to. Most commonly this will be for the following purposes, (the “Purposes”) for which our legal bases for processing are processing necessary for the performance of a contract and processing necessary for compliance with a legal obligation:

Purpose

i.              processing necessary to enable us, including Pershing Securities Limited (“PSL”)  on our behalf, to provide the services

ii.              account administration

iii.             credit enquiries or assessments

iv.             the fight against money laundering and terrorist financing purposes, to investigate or prevent fraud, or any other illegal activity

v.             for compliance with regulatory requirements and foreign laws

Personal data used for the Purposes, may include, your name, contact details (including postal or e-mail address), banking details, National Insurance Number and Tax Identification Number.

We may use your Identity and Contact data, 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 may contact you from time to time to make you aware of investment opportunities, social events and other related services. All of these information updates will originate from within the Ravenscroft Group.

Recipients of the personal data: we may share your personal data with any of our group of companies, regulatory bodies having competent jurisdiction over us, including tax authorities, auditors and tax advisers, exchanges, other third party data processors and to a prospective buyer or seller in the context of a transaction involving the sale of, or transfer of assets from, PSL or us.

We may transfer personal data to a variety of third party data processors, including PSL, for the purpose of eliciting a necessary service from these third party organizations (not for commercial gain, nor for direct marketing).

In some cases, personal data will be transferred outside the European Economic Area (EEA) to a country that may not have an adequacy decision by the European Commission, including the United States of America.  In these cases, suitable safeguards shall be implemented, such as EC standard contractual clauses.  You may request copies of relevant documentation for enabling such extra-EEA transfers by contacting us.

Personal data shall be processed by us as long as necessary for the Purposes. In accordance with legal and regulatory requirements, we and PSL will retain your records, for a period of up to ten years following the termination of any relationship between us. This period may be extended by force of law, regulatory requirement or agreement amongst us.

Data subject rights

You have rights in relation to your own personal data, upon proving your identity to us, in accordance with Data Protection Laws (under which, in some cases, one or more of the following rights may not apply), as follows:

  • to access a copy of your personal data;
  • to request rectification of the personal data;
  • to request restriction of processing of the personal data;
  • to object to the processing of personal data; and
  • to request to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit those personal data to an alternate data controller of your choosing.

You may contact us as follows:

Name:      Natalie Howman

Email:       Dataprotection@vartan-ravenscroft.com

Address: Vartan Ravenscroft, The Singing Men’s Chambers, 19 Minster Precincts,Peterborough, PE1 1XX 

Telephone: +44 (0)1733 315155

We fully intend for your personal data to be managed responsibly and for the Purposes.  In the event that you wish to make a complaint, you are advised to first address the complaint to us.  If the complaint still remains unresolved, you may lodge a complaint with the relevant data protection authority (or supervisory authority) concerned: the Information Commissioner’s Office (http://www.ico.org.uk/concerns).

 We may update our Privacy Policy from time to time and will notify you if we make any material amendments.

 

Web site privacy - Introduction

This privacy policy sets out how Vartan Ravenscroft uses and protects any information that you give Vartan Ravenscroft when you use this website, in accordance with The Data Protection Act 1998. Vartan Ravenscroft is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

Vartan Ravenscroft may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 7th October 2015.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. These are the types of cookies Vartan Ravenscroft uses and the purpose they serve:

Cookie NameValiditySourceTypeUseInformation Collected
_ga2 yearsGoogle AnalyticsFirst-Party CookieUsed to distinguish usersNo personal information. Browsing Statistics.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to Other Websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.