Privacy Notice

This privacy notice explains how we use any personal information we collect about you.

What information do we collect about you?

We collect information about you when you engage us to provide a discretionary management service. This information will include your personal and financial details. It will not however include special categories of personal data such as data about your health.

We may also collect information when you voluntarily complete client surveys or provide feedback to us.

Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We may use your information collected from the website to personalise your repeat visits to the site. Please refer to our website privacy policy at www.ironbright.com/privacy-policy/

Why do we need to collect and use your personal data?

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.

How will we use the information about you?

We collect information about you in order to provide you with the services for which you engage us.

Who might we share your information with?

We won’t share your information for marketing purposes with other companies.

In order to deliver our services to you effectively, we may send your details to third parties such as those that we engage for professional compliance, product and platform providers that we use on your behalf.

Where third parties are involved in processing your data we’ll have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.

Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit. In addition to postal services, where transferring data online, we utilise online secure portals.

To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.

How long do we keep hold of your information?

In principle, your personal data shouldn’t be held for longer than is required under the terms of our contract for services with you. However, we’re subject to regulatory requirements to retain data for specified minimum periods. We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us.

You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.

How can I access the information you hold about me?

You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all of your personal information, please email or write to us using the contact details noted below.

When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.

We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.

Marketing

We will not engage in marketing however, where you are an existing client, in order for you to be kept informed, we will send by email regular investment/fund updates.

You have a right at any time to stop us from contacting you for this purpose. If you no longer wish to be contacted in this regard, please contact us by email (team@ironbright.com) or post.

IronBright Website

Our website uses cookies to track visitor use of the website and to compile statistical reports on website activity. 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.

Further information regarding our website is confirmed in our website privacy policy.

Other websites

Our website may contain links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

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)

Changes to our privacy policy

We keep our privacy policy under regular review and we’ll place any updates on this web page (and/or) inform you of any changes when they occur.  This privacy policy was last updated on 24/04/2018.

How to contact us

Please contact us if you have any questions about our company privacy policy or information we hold about you: by email at team@ironbright.com.

You may contact our data controller, Andrew Weston, at compliance@ironbright.com

Or write to us at

IronBright Investment Management Ltd

Vertigo

Cheese Lane

Bristol

BS2 0JJ