When contacting us, whether online (via our “Contact Us” page), via telephone, via email, in writing, or otherwise, you may provide Personal Information to us (such as your name, address, telephone number, job title and function).
If you consider investing with us, you may also provide us with financial information and various other necessary Personal Information relevant for due diligence to carry out necessary anti-money laundering checks (e.g. your national insurance, social security or tax payer identification number, investment history and bank details).
If you provide services to us, have a business dealing with us, or are employed or engaged by an organisation which provides services or has a business dealing with us, we may acquire your name, contact details, bank account, employment information, information necessary for processing payments, employment information or information relevant for due diligence to carry out any necessary anti-money laundering checks.
We sometimes ask members of our staff to provide details of their next of kin for the purpose of out emergency scenario planning in case an incident occurs at work. In such circumstances, we may acquire your name, telephone number, address or email address).
We collect Personal Information about your preferences in receiving marketing information from us, your communication preferences and information about how you use our website – please see our Cookies Policy for more information.
Where you apply for a job with us, we may collect from you (and third parties) additional Personal Information such as your CV and references.
We may also collect “Sensitive Personal Information” (such as information concerning an individual’s racial or ethnic origin, political opinions, religious beliefs, physical or mental health or condition, sexual life of orientation, or commission or alleged commission of any offence or proceedings for any offence committed or alleged to have been committed by an identifiable individual) in relation to an application to invest with us, our provision of investment services to you, job applications, or otherwise.
We use your Personal Information and/or Sensitive Personal Information:
to provide our services;
in the ordinary course of business, including internal record keeping;
to carry out verification checks – for example, in relation to anti-money laundering and know your client procedures;
to comply with our legal obligations, including reporting obligations;
to protect the security of our communications and other systems to prevent and detect security threats, frauds or other criminal or malicious activities;
to send business or marketing communications (such as investment updates), which shall, at all times, include an option for you to unsubscribe if you wish; and/or
to organise and hold marketing events in connection with our business.
The legal basis on which we hold your Personal Information is primarily for the purpose of pursuing our legitimate interests as a business. We may also rely on your express consent to use your Personal Information (and will give you the opportunity to withdraw consent where we do so). In some instances, we may also use your Personal Information to enable us to perform a contract which we have in place with you.
We will only ever keep your Personal Information for as long as is reasonably necessary and, in any event, only for as long as we are permitted under Data Protection Legislation.
This website may include links to third party websites from time to time. Please note that when you click on a link to such a website you will be leaving our website and accessing their website. As such, operators of those websites are responsible for any Personal Information they collect about you once you have left our website and accessed their website, and such data will be collected in accordance with their own privacy policies.
In some circumstances, it may be necessary to transfer your Personal Information outside of the UK or EEA (for example, in order to perform a contract we have in place with you). Your Personal Data may also be accessed by staff members who work outside of the UK or EEA. Where this is the case, we will take all steps reasonably necessary to ensure that your Personal Information is treated securely and we will comply with this Policy and the Data Protection Legislation when it is processed in, or otherwise accessed from, a location outside of the UK or the EEA. Where we transfer such data pursuant to a contract, you may request a copy of the relevant parts of such contract and will carry out all the necessary analysis of local laws prior to entering into such contract.By submitting Personal Information to us, you acknowledge this transfer, storing or processing of your Personal Information.
You have certain rights in relation to your Personal Information, such as the right to request that we erase all (or part of) Personal Information we hold about you. You also have the right, subject to certain exemptions, to:
request a copy of the Personal Information we hold about you
ask us to make changes to the Personal Information you hold about you to make sure that it is complete and accurate; and/or
ask us to transfer any information we hold about you to a specified third party.
If you wish to exercise any of these rights, please contact us at the email address set out in the Contact Us and Complaints section.
We may make changes to this policy at any time. Any changes to this Policy will be posted to our website at www.ethosinvest.co.uk.
Should you wish to exercise any of the rights set out above, or if you have any questions about the way in which we handle your Personal Information, please contact us via email at email@example.com. Alternatively, you have the right to make a complaint to the Information Commissioner’s Office, the supervisory body in the UK, or, if you are an EU data subject, one of the competent European supervisory authorities (https://edpb.europa.eu/edpb_en).
For the purpose of this Policy, “Data Protection Legislation” shall mean (i) the General Data Protection Regulation (Regulation (EU)) 2016/679; and (ii) all applicable data protection and privacy legislation in force from time to time in the United Kingdom including the General Data Protection Regulation (Regulation (EU)) 2016/679 as incorporated into the law of the United Kingdom pursuant to the European Union (Withdrawal) Act 2018; the Data Protection Act 2018, the Privacy and Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended, and any UK national implementing laws, regulations and secondary legislation and any successor legislation.