The Firms are authorised and regulated by the Financial Conduct Authority.
We are committed to preserving the privacy of our clients, direct investors and any other individuals with whom we establish a relationship either directly or through this website.
Personal data, or personal information, means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
If you contact us by post, telephone, email, secure message through our investor portal or through our website, we may keep a record of that correspondence.
Telephone conversations with you may be recorded, where required to do so by law or regulation. In particular, we are required to record all telephone conversations and electronic communications that are intended to result in the execution of an order e.g. where you give a specific instruction to execute a trade on your behalf.
We collect and process information held about you in the following circumstances:
(i) when it is necessary for the performance of a contract to which you are a party or seek to become a party to;
(ii) when we are required to comply with a legal obligation; and / or
(iii) if the processing is for our legitimate interests or those of a third party.
We collect and process information about you for the following specific purposes:
We may contact you by post, telephone, email and secure message if you use our investor portal service. If you change your mind about how you wish to be contacted, then please let us know. Should we require to process your information for any purpose not included within this policy, we shall communicate this to you in advance of doing so.
We process all data in accordance with Data Protection Laws. We may share your information with third-party business partners with whom we have contracted to help us provide our service to you.
We may have to send your data to organisations which help us to confirm your identity, to comply with Anti-Money Laundering regulations, or for other purposes such as the detection of crime. To confirm your identity, such processing may require the use of automated decision making by the relevant organisation. If the relevant organisation cannot confirm your identity, we will take additional measures to enable us to do so.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party business partners to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We will not share your information for marketing purposes with any organisation outside the Firms.
Data Protection Laws give you rights in relation to your personal information.
In addition to the rights set out above, you have the right to lodge a complaint with the Information Commissioner’s Office, or its successor.
If you are a discretionary investment management client or a direct investor in one of our unit trusts, and you ask us to stop processing or erase your personal information, we will be unable to continue to provide any investment management service to you. In such circumstances we will have no option but to terminate any contract with you for the provision of investment management or fund services. You would therefore be required to sell or transfer any investments.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Data Protection Laws allow us to retain your personal information for as long as is necessary for the purposes for which your personal information was obtained, or for longer periods where a statutory or regulatory requirement exists. Our record retention policy is to remove your personal information from our records 6 years after our business relationship with you has ended, unless i) there is a statutory or regulatory reason why we require to retain your personal information for longer or ii) we have already erased your personal information following an earlier request to do so.
A cookie is a piece of software that places a text file on the hard drive of your computer that remembers information about the configuration of your computer (and its IP address) and collects standard internet log and visitor behaviour information. The information is used to track visitor use of the website and to personalise any repeat visits you make to our website.
Our registration numbers with the UK Information Commissioner’s Office are Z5037103 (McInroy & Wood Limited) and Z2965605 (McInroy & Wood Portfolios Limited).