What do we mean by “Personal Information”?
Personal information means information which identifies you, like your name or email address. Any information that falls outside of this is “non-personal information.” If we store your personal information with information that is non-personal, we will consider the combination as personal information. If we remove all personal information from a set of data then the remaining is non-personal information.
Information we may collect from you
We may collect and process the following data about you:
• Information you give us. You may give us information about you by filling in forms on our sites or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our sites, subscribe to our services, participate in discussion boards or other social media functions on our sites. We collect information when you search for an investment and when you report a problem with the site(s). The information you give us may include your name, address, e-mail address and phone number, FCA registration number (if applicable), financial and credit card information or other personal information or description.
• Information we collect about you. With regard to each of your visits to our sites we may automatically collect the following information:
o technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform.
o information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our sites (including date and time); investments you viewed or searched for; products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
o Telephone calls that you make to us may be recorded and those recordings may be used for training purposes or to meet our regulatory requirements. Any data provided during the call will be used and held in accordance with provisions of this policy.
• Information we receive from other sources.
o We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
• Strictly necessary cookies, required for the operation of our website. These cookies will enable you to log into secure areas of our website and ensure your session is secure.
• Functionality cookies, used to recognise you for the next time you visit our website. These allow us to personalise content and remember your preferences from your previous visits. Our website may also offer live chat services (if available).
• Analytics and performance cookies, used to collection information about how you use our website. This will help us understand how our users navigate around our website and any errors that may be experienced. The information will be used to help us to improve our system for our users. We use Google Analytics for some of our website analytics.
Uses made of the information
We use information held about you in the following ways:
• Information you give to us. We will use this information:
o to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information that you request from us;
o to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
o to notify you about changes to our services;
o to ensure that content from our sites are presented in the most effective manner for you and for your computer.
• Information we collect about you. We will use this information:
o to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
o to improve our sites to ensure that content is presented in the most effective manner for you and for your computer;
o to allow you to participate in interactive features of our services, when you choose to do so;
o as part of our efforts to keep our sites safe and secure;
o to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
o to make suggestions and recommendations to you and other users of our sites about goods or services that may interest you or them.
• Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of your information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We may share your information with selected third parties including:
• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them.
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 users have clicked to view information on their investment on any given day). We may also use such aggregate information to help providers reach the kind of audience they want to target (for example, investors or advisors interested in investing in renewable energy investments). We may make use of the personal data we have collected from you to enable us to comply with our providers’ wishes by displaying their investment information to that target audience.
• Analytics and search engine providers that assist us in the improvement and optimisation of our sites. We may disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If Amberside Capital Ltd, DUGUUD or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where we store your personal data
Acceptable Use Policy
You may not use any of our services and products to:
• Do anything illegal or otherwise breach law.
• Threaten, harass, or violate the privacy rights of others; send unsolicited communications; or intercept, monitor, or modify communications not intended for you.
• Harm users such as by using viruses, spyware or malware, worms, trojan horses, time bombs or any other such malicious codes or instructions.
• Collect or harvest personally identifiable information, including, but not limited to, account names or email addresses.
• Engage in any activity that interferes with or disrupts our services or products (or the servers and networks which are connected to our services).
• Reproduce, duplicate, copy, sell, trade or resell our services or products for any purpose.
• Violate the copyright, trademark, or infringe the intellectual property rights of others.
• Upload, download, transmit, display, or grant access to content that:
o Is illegal or promotes illegal activities.
o Is inappropriate such as obscene or pornographic materials, graphic depictions of sexuality or violence, or images that exploit or harm children.
o Infringes anyone’s rights, including intellectual property or other proprietary rights or rights of privacy or publicity.
o Is deceptive, misleading, fraudulent or is designed to phish or perform other identity theft.
o Is intended to promote gambling.
o Engages in the advertisement of or encourages illegal or controlled products or services.
o Degrades, intimidates, incites violence against, or encourages prejudicial action against someone or a group based on age, gender, race, ethnicity, national origin, religion, sexual orientation, disability, religion, geographic location or other protected category or constitutes hate speech.
o Misleads a user into making a wrong decision.
• This list is illustrative, not definitive, and may be updated. We reserve the right to remove any notes you make or suspend any users that we deem in violation of these guidelines or the applicable product terms of service.
The period of time for which we retain your records and personal data is seven years from cessation of your client relationship with us as defined by our regulatory obligations under the relevant rules of the FCA Handbook.